623. Lewinsky 8/13/98 Int. at 4; Lewinsky 8/26/98 Depo. at 61-63.
624. Podesta 2/5/98 GJ at 40-41. See also Lewinsky 7/31/98 Int. at 10. As previously discussed, Ms. Currie had earlier asked Mr. Podesta to help Ms. Lewinsky obtain a White House job.(625)
625. See supra at [].
626. Podesta 2/5/98 GJ at 40-45; Richardson 4/30/98 Depo. at 28. On Sunday, October 12, 1997, the President traveled to Latin America for one week. United States President, Weekly Compilations of Presidential Documents at 1608, 1609, 1653. On that trip, the President was accompanied by, among others, then-U.N. Ambassador William Richardson and the Deputy Chief of Staff, John Podesta. Richardson 4/30/98 Depo. at 28-29; Podesta 2/5/98 GJ at 44. Ambassador Richardson recalled that Mr. Podesta had first made the request prior to the trip to Latin America. Richardson 4/30/98 Depo. at 28.
627. Podesta 2/5/98 GJ at 45; Richardson 4/30/98 Depo. at 32.
628. Richardson 4/30/98 Depo. at 160-61; Clinton 1/17/98 Depo. at 73.
629. Richardson 4/30/98 Depo. at 26.
630. Watkins 5/27/98 Depo. at 11-12, 18.
631. Podesta 2/5/98 GJ at 46.
632. 828-DC-00000012 (faxed copy of Ms. Lewinsky's resume, produced by the U.N.); Currie 5/6/98 GJ at 174.
633. 828-DC-00000004 (U.N. phone records).
634. Lewinsky 8/13/98 Int. at 3.
635. Lewinsky 8/26/98 Depo. at 63-64. See also Lewinsky 8/26/98 Depo. at 63-64; Lewinsky 7/31/98 Int. at 12; Lewinsky 7/27/98 Int. at 5.
636. Lewinsky 7/27/98 Int. at 5.
637. Richardson 4/30/98 Depo. at 47-48; Watkins 5/27/98 Depo. at 27-29. Ms. Watkins further testified that she often placed calls from the Ambassador's line. Watkins 5/27/98 Depo. at 37-38.
638. Lewinsky 8/13/98 Int. at 3-4.
639. Lewinsky 8/13/98 Int. at 4.
640. Lewinsky 8/13/98 Int. at 4. See also Lewinsky 7/31/98 Int. at 12.
641. Lewinsky 8/26/98 Depo. at 64-65; Lewinsky 7/31/98 Int. at 13.
642. Lewinsky 8/26/98 Depo. at 65. Ms. Lewinsky wrote an email to her friend Catherine Allday Davis: "It was nice; the big creep called Thursday night to give me a pep talk because I was so afraid I'd sound like an idiot." 1037-DC-00000022 (spelling corrected).(643)
643. 1037-DC-000000022 (spelling corrected).
644. Lewinsky 7/31/98 Int. at 13. See also Lewinsky 8/26/98 Depo. at 65.
645. Clinton 1/17/98 Depo. at 74.
646. 828-DC-00000023 (Ambassador Richardson's diary reflecting 7:30 a.m. meeting with Monica Lewinsky). See also Ambassador Richardson 4/30/98 Depo. at 66-68; Sutphen 5/27/98 Depo. at 7; Cooper 1/27/98 Int. at 1-2; Lewinsky 7/31/98 Int. at 13-14. After meeting with Ms. Lewinsky, Ambassador Richardson spent the remainder of the day meeting individually with Senators and Members of Congress. 828-DC-00000023 (Ambassador Richardson's itinerary for October 31).
647. Richardson 4/30/98 Depo. at 68; Cooper 1/27/98 Int. at 1-2.
648. Richardson 4/30/98 Depo. at 39; Sutphen 5/27/98 Depo. at 15-16; Cooper 1/27/98 Int. at 2.
649. The draft was retrieved from Ms. Lewinsky's computer in the course of a consensual search on January 22, 1998.
650. MSL-55-DC-0179 (punctuation added)(italics in original).
651. MSL-55-DC-0179.
652. MSL-55-DC-0179. Ms. Lewinsky concluded the letter, "I was pleased the UN interview went well, but I'm afraid it will be like being at the Pentagon in NY. . . YUCK!" MSL-55-DC-0179 (ellipsis in original).
653. Lewinsky 8/13/98 Int. at 4-5; Lewinsky 7/31/98 Int. at 14; Lewinsky 7/27/98 Int. at 5.
654. 828-DC-00000003.
655. Lewinsky 8/26/98 Depo. at 67; Lewinsky 7/27/98 Int. at
5; Lewinsky 7/31/98 Int. at 14; Lewinsky 8/13/98 Int. at 5.
According to Ambassador Richardson, the position offered to Ms. Lewinsky was not newly created. He testified that he intended to expand an open position in the U.N.'s Washington office and move it to New York. Richardson 4/30/98 Depo. at 39-40. Although Ambassador Richardson did not recall whether this opening was publicized, he testified that it would be common for the office not to post Schedule C (political appointment) positions. Richardson 4/30/98 Depo. at 71-72. Peter Aronsohn, who filled the position Ms. Lewinsky was offered, characterized the job as a "new position." Aronsohn 8/27/98 Int. at 2.
656. Sutphen 5/27/98 Depo. at 26.
657. Richardson 4/30/98 Depo. at 90-91; Sutphen 5/27/98 Depo. at 21-23.
658. Lewinsky 8/26/98 Depo. at 65-66; Lewinsky 8/13/98 Int. at 4.
659. Currie 5/6/98 GJ at 174-75, 181; Currie 5/14/98 GJ at 65-66.
660. Clinton 1/17/98 Depo. at 73.
661. Sutphen 5/27/98 Depo. at 32-33; Lewinsky 8/13/98 Int. at 5.
662. Sutphen 5/27/98 Depo. at 33. See also Richardson 4/30/98 Depo. at 110-11 (recalling Ms. Lewinsky's request for additional time to consider the offer).
663. Lewinsky 7/27/98 Int. at 5; Sutphen 5/27/98 Depo. at 38; 1013-DC-00000095 (toll records for Debra Finerman).
664. 921-DC-00000101 - 118 (Second Set of Interrogatories from Plaintiff to Defendant Clinton).
665. V002-DC-00000016; V002-DC-00000020-21.
666. See supra at IX.B. See also Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12.
667. MSL-55-DC-0179.
668. Lewinsky 7/31/98 Int. at 14.
669. Lewinsky 7/31/98 Int. at 14. Phone records reflect that
on November 4 at 3:54 p.m., Ms. Lewinsky placed a three-and-a-half-minute call to Mr. Jordan's office; at 4:09 p.m., Mr. Jordan
placed a one-minute call to Ms. Currie; and at 4:38 p.m., Mr.
Jordan placed a one-minute call to Ms. Currie. 833-DC-00017875
(Ms Lewinsky's phone records); V004-DC-00000134 (Akin, Gump phone
records).
670. T2 at 11-12. See also Lewinsky 7/31/98 Int. at 11.
671. Jordan 5/5/98 GJ at 47 (Mr. Jordan testified that he
believed the President had told Ms. Currie to "[c]all Vernon and
ask Vernon to help her").
672. Currie 5/6/98 GJ at 169-70, 176-78, 182-83, 198.
673. Clinton 1/17/98 Depo. at 81.
674. Clinton 1/17/98 Depo. at 82.
675. 1178-DC-00000011 (call logs).
676. Lewinsky 7/31/98 Int. at 14.
677. Lewinsky 7/31/98 Int. at 14-15.
678. Lewinsky 8/13/98 Int. at 3.
679. Lewinsky 8/6/98 GJ at 106; Lewinsky 7/31/98 Int. at 14-15; Lewinsky 7/27/98 Int. at 8, 10. Ms. Lewinsky later quoted
the remark in email to a friend.(680)
680. 1037-DC-00000017 (email retrieved from Ms. Davis's computer). --
681. 1037-DC-00000017 (email retrieved from Catherine Davis's
computer).
682. Jordan 3/3/98 GJ at 13.
683. V004-DC-00000135 (Akin, Gump phone records).
684. Jordan 5/5/98 GJ at 54.
685. 1178-DC-00000026 (WAVES record). Ms. Lewinsky would
learn of the meeting between the President and Mr. Jordan. In
email to a friend dated November 6, Ms. Lewinsky wrote that Mr.
Jordan had "[seen] the big creep yesterday afternoon." 1037-DC-00000017 (spelling corrected) (email to Catherine Davis).
686. Jordan 5/5/98 GJ at 34.
687. 833-DC-00000980 (letter retrieved from Ms. Lewinsky's
Pentagon computer)(spelling corrected).
688. 1037-DC-00000017 (email retrieved from Catherine Davis's
computer). Ms. Lewinsky wrote that she was "a little nervous to
do the whole name of the BF. His first name is Vernon." Id.
According to her aunt, Debra Finerman, Ms. Lewinsky used the code
name "Gwen" when discussing Mr. Jordan because "he's an important
person" and Ms. Lewinsky "always had the feeling somebody was
listening in" on their phone conversations, they did not want an
eavesdropper to know that Mr. Jordan was helping her find a job.
Finerman 3/18/98 Depo. at 60. See also Lewinsky 8/5/98 Int. at
3; Lewinksy 8/3/98 Int. at 9.
689. Jordan 3/3/98 GJ at 50.
690. Jordan 5/5/98 GJ at 26-30, 34.
691. Epass records reflect that Ms. Lewinsky entered the
White House at 6:20 p.m., admitted by Ms. Currie. 827-DC-00000018. Secret Service Movement logs show that the President
entered the State Floor at 5:23 and moved to the Oval Office at
6:34. V006-DC-00002156.
692. 1037-DC-00000318 (email retrieved from Catherine Davis's
computer).
693. Lewinsky 8/13/98 Int. at 5.
694. Lewinsky 8/13/98 Int. at 5. Many of Ms. Lewinsky's
previous visits with the President had occurred on holidays.
See, e.g., Lewinsky 7/30/98 Int. at 3, 13, 17 (describing visits
on New Year's Eve, Presidents' Day, Easter Sunday, and July 4).
695. 837-DC-00000008(courier receipt).
696. DB-DC-00000022. Ms. Lewinsky produced a draft of this
letter to the OIC on July 31, 1998. See also Lewinsky 7/31/98
Int. at 1 (confirming that she delivered a substantially similar
note).
697. DB-DC-00000022.
698. Lewinsky 8/13/98 Int. at 5-6. On November 12, 1997, the
President responded to Paula Jones's Third Set of
Interrogatories. In response to an interrogatory that asked the
President to provide information about all individuals who have
discoverable and relevant information regarding the disputed
facts at issue in the case, the President provided a list of
names that did not include Ms. Lewinsky. 849-DC-0000090 - 97.
699. 1037-DC-00000318 (email retrieved from Catherine Davis's
computer).
700. 1037-DC-00000318 (spelling corrected). Lewinsky 8/13/98
Int. at 6. On November 13, Ms. Hernreich was testifying before
Congress. Walsh, "Democratic Donor Chung Invokes 5th Amendment;
House Members Informally Interview Businessman Edward Walsh,"
Washington Post, November 15, 1997, at A6.
701. MSL-1249-DC-0140; Lewinsky 8/13/98 Int. at 6.
702. 1037-DC-00000318 (email retrieved from Catherine Davis's
computer).
703. Lewinsky 8/13/98 Int. at 6; 1234-DC-00000050 (movement
log); 986-DC-00003799 (Kearney Diary).
704. Lewinsky 8/13/98 Int. at 6.
705. Lewinsky 8/13/98 Int. at 6; 1037-DC-00000318 (email to
Catherine Davis).
706. In a note to the President the next week, Ms. Lewinsky
would write of the gifts: "I forgot to tell you: . . . The
Gingko Blowjoba or whatever it is called and the Zinc lozenges
were from me." MSL-55-DC-0140 (spelling and grammar corrected).
707. Lewinsky 8/6/98 GJ at 183-85; Lewinsky 8/2/98 Int. at 4.
Ms. Lewinsky also saw a clipping of the Valentine's Day ad she
had placed in the Washington Post on the President's desk.
Lewinsky 8/6/98 GJ at 183-84. In a document composed soon after
this visit, Ms. Lewinsky wrote: "When I was hiding out in your
office for a half-hour, I noticed you had the new Sarah McLachlan
CD. I have it, too, and it's wonderful. Whenever I listen to
song #5 I think of you. That song and Billie Holiday's version
of 'I'll be Seeing You' are guaranteed to put me to tears when it
comes to you!" MSL-1249-DC-0140-41 (deleted file from Ms.
Lewinsky's home computer) (spelling and grammar corrected).
708. 1037-DC-00000318 (email to Catherine Davis).
709. Lewinsky 8/13/98 Int. at 6.
710. OIC 8/27/98 Memo.
711. 968-DC-00000187 (presidential schedule); 968-DC-00000303
(Kearney Diary). Ms. Currie initially testified that she could
not recall Ms. Lewinsky's November 13 visit. Currie 5/6/98 GJ at
12, 15. After viewing documentary evidence, she recalled that
this was the only time she surreptitiously escorted Ms. Lewinsky
into the White House. Id. at 85.
712. Lewinsky 8/11/98 Int. at 1; Lewinsky 7/31/98 Int. at 1-2; 837-DC-00000011 (courier receipt); MSL-1249-DC-0140-41
(document recovered from Ms. Lewinsky's home computer).
On November 17, 1997, the President responded to Paula
Jones's First Set of Requests for Production of Documents and
Things. One request sought documents sent to President Clinton
by any woman (other than Mrs. Clinton) with whom President
Clinton had sexual relations. V002-DC-00000056 - 92. President
Clinton objected to this request as one designed "solely to
harass, embarrass, and humiliate the President and the Office he
occupies." V002-DC-00000075. Nonetheless, the President
answered that he did not have any documents responsive to that
request.
713. Lewinsky 8/6/98 GJ at 105.
714. Lewinsky 8/6/98 GJ at 105. Phone and pager records
corroborate these contacts. 1205-DC-00000016; V004-DC-00000143;
831-DC-00000011. (Note that Ms. Lewinsky's pager records reflect
Pacific Time; throughout this referral, time has been adjusted to
Eastern Standard Time.)
715. MSL-1249-DC-0140 (spelling and punctuation corrected).
716. MSL-1249-DC-0139 (spelling and punctuation corrected).
717. 849-DC-00000128.
718. 849-DC-00000121-37
719. See infra at Section XI.F. See also Lewinsky 8/6/98 GJ
at 121-26.
720. Clinton 8/17/98 GJ at 84-85. In his Jones deposition,
the President acknowledged that he may have heard of the witness
list before he actually saw it. Clinton 1/17/98 Depo. at 70.
721. 833-DC-00003207 (Travel Voucher DOD).
722. Lewinsky 8/6/98 GJ at 107; Lewinsky 7/31/98 Int. at 1.
723. V006-DC-00000521 (guest list); VOO6-DC-00001859
(photograph of Ms. Lewinsky and the President at the reception).
724. Lewinsky 7/31/98 Int. at 1.
725. Lewinsky 7/31/98 Int. at 2; MSL-55-DC-0177. The wording
of the letter resembles, in part, a message on a cassette found
during the consensual search of Ms. Lewinsky's apartment: "Hi.
[Sniffling, crying.] I was so sad seeing you last night. I was
so angry with you that once again you had rejected me. . . . I
wanted to feel the warmth of you and the smell of you and the
touch of you. And it made me sad. And I -- you confuse me so
much. I mean I [sigh]. I thought I -- I thought I fell in love
with this person that -- that I really felt was such a good --
such a good person, such a good heart, someone who's had a life
with a lot of experiences.(726)
726. Search.001 transcript at 2. [get cite for tape itself]
727. MSL-55-DC-0177 (punctuation corrected).
728. MSL-55-DC-0177 (punctuation corrected).
729. MSL-DC-55-0177 (punctuation corrected).
730. MSL-55-DC-0177 (punctuation corrected).
731. Lewinsky 8/6/98 GJ at 108-09; Lewinsky 8/6/98 GJ at 27-29 & Exh. ML-7. The cigar holder, the tie, the mug, and the book
have been produced to the OIC. V002-PHOTOS-0011 (holder, tie,
and book); V002-PHOTOS-0005 (mug).
732. Lewinsky 8/6/98 GJ at 111-12.
733. Bryan Hall 5/21 98 Int. at 2; Bryan Hall 7/23/98 GJ at
10-11, 15-16; Niedzwiecki 7/30/98 GJ at 12-13; Lewinsky 8/6/98 GJ
at 109-11.
734. Lewinsky 8/6/98 GJ at 110-11; Niedzwiecki 7/30/98 GJ at
13-14.
735. Byran Hall 7/23/98 GJ at 12-13; Niedzwiecki 7/30/98 GJ
at 13, 15. Officer Hall recognized Ms. Lewinsky from a previous
occasion, when she was greeted by, and delivered something to,
Ms. Currie. Byran Hall 7/23/98 GJ at 6-10.
736. Tyler 7/28/98 GJ at 40; Chinery 7/23/98 GJ at 8.
737. Lewinsky 8/6/98 GJ at 111-12. Ms. Mondale recalled
visiting the President that morning. Mondale 7/16/98 Int. at 1.
See also 843-DC-00000004 (Epass records reflect that Ms. Mondale
entered the White House at 9:33 a.m.).
738. Lewinsky 8/6/98 GJ at 111-12. See also Currie 7/22/98
GJ at 88-89. Ms. Lewinsky suspected that Ms. Mondale was
romantically involved with the President. (739)
739. In a conversation on November 11, Ms. Lewinsky speculated that Ms. Mondale was
and the President were starting a "relationship." Ms. Lewinsky noted with bitterness: "Maybe
she's not sleeping with him yet. Anyway, there's the excitement. It's the President." LT16 at 91.
-
740. Lewinsky 8/6/98 GJ at 112-13. Ms. Currie testified that
Ms. Lewinsky angrily told her: "'You had lied to me, that the
President is in the office, and he's meeting with someone.' And
I said, 'Yeah, you're right.' She was not too happy about it,
and words were exchanged." Currie 1/27/98 GJ at 37.
741. Keith Williams 7/23/98 GJ at 24. See also Chinery
7/23/98 GJ at 10; Purdie 7/23/98 GJ at 13.
742. Keith Williams 7/23/98 GJ at 12. Some testimony
indicates that the President directly told Sergeant Williams
about the Northwest Gate incident. Three officers testified that
Sergeant Williams told them that the President had spoken to him
and had indicated that he wanted the officer responsible for the
disclosure of information fired. Niedzwiecki 7/30/98 GJ at 29,
37; Byran Hall 7/23/98 GJ at 25-26; Porter 8/13/98 GJ at 16-18.
For example, Officer Niedzwiecki testified that soon after the
incident, Sergeant Williams came to the Northwest Gate and said,
"[t]he President wants somebody's job." Niedzwiecki 7/30/98 GJ
at 29. Sergeant Williams testified, however, that the President
did not speak to him directly about the incident. Keith Williams
7/23/98 GJ at 31-32. According to Sergeant Williams, when he met
alone with Ms. Currie, he noticed that the door leading to the
Oval Office was at first shut but then was cracked open. Keith
Williams 7/23/98 GJ at 22, 30. Sergeant Williams testified that
he heard what he assumed to be a male voice coming from within
the Oval Office saying "[t]his person needs to be fired." Keith
Williams 7/30/98 GJ at 10-11. Sergeant Williams told the
officers at the gate that he spoke to the President only to get
their attention. Keith Williams 7/30/98 GJ at 16-17. However,
Sergeant Williams also told the supervisor who replaced him that
afternoon that the President had spoken to him directly about the
incident at the Northwest Gate. Deardoff 9/3/98 Depo. at 8-9.
743. Purdie 7/23/98 GJ at 13, 18-19. Captain Purdie
testified that he thought that the remedy of firing was "out of
proportion to the incident . . . [e]specially without doing an
investigation or a fact-finding mission."(744)
744. Purdie 7/23/98 GJ at 19.
745. Lewinsky 8/6/98 GJ at 113.
746. Lewinsky 8/6/98 GJ at 113-14.
747. Lewinsky 8/6/98 GJ at 114.
748. Lewinsky 8/6/98 GJ at 114.
749. 827-DC-00000018. Secret Service logs reflect that the
President was in the area of the Oval Office throughout this
period. V006-DC-00002158.
750. Lewinsky 8/6/98 GJ at 115-16. Specifically, Ms.
Lewinsky told the President "that I was supposed to get in touch
with Mr. Jordan the previous week and that things didn't work out
and that nothing had really happened yet." Id.
751. Lewinsky 8/6/98 GJ at 116. The President also told Ms.
Lewinsky that he had already gotten a Christmas present for her
and that he would give that to her during another visit.
Lewinsky 8/1/98 Int. at 2.
752. Lewinsky 8/6/98 GJ at 115.
753. 1037-DC-00000011 (spelling corrected).
754. Keith Williams 7/23/98 GJ at 25. Ms. Currie confirmed
that she told an officer, "Okay. Fine. This never happened."
However, she testified that she said this so that no officer
would get in trouble. Currie 7/22/98 GJ at 91-92.
When Ms. Currie left work that day, she stopped by a Secret
Service post and told an officer that "she spoke to the President
. . . and . . . they decided that the incident never happened,
they weren't going to pursue . . . discipline actions against
them, that they just wanted it to go away." Chinery 7/23/98 GJ
at 22-23. Later that week, Ms. Currie told that officer to
inform one of his supervisors "that everything was okay and just
to keep quiet about it." Keith Williams 7/23/98 GJ at 27-28.
755. Purdie 7/23/98 GJ at 32; Purdie 7/17/98 GJ at 3.
756. Purdie 7/17/98 GJ at 6; Bryan Hall 7/23/98 GJ at 31-32;
Chinery 7/23/98 GJ at 21.
757. Porter 8/13/98 GJ at 12.
758. Niedzwiecki 7/30/98 GJ at 30-31.
759. Niedzwiecki 7/30/98 GJ at 31, 44. See also Niedzwiecki
8/5/98 GJ at 4-6 (text of Niedzwiecki notes).
760. Purdie 7/23/98 GJ at 35.
761. Purdie 7/23/98 GJ at 34-36. While Deputy Chief O'Malley
testified that Captain Purdie notified him of the incident,
Deputy Chief O'Malley did not recall Captain Purdie discussing
with him, at any time, a decision not to generate an incident
report or a memorandum. Charles O'Malley 9/8/98 Depo. at 44, 47-48.
762. O'Malley 9/8/98 Depo. at 22, 40-41.
763. Clinton 8/17/98 GJ at 84-85, 87. Ms. Mondale stated
that she met with the President alone in the Oval Office study
that day. Mondale 7/16/98 Int. at 1.
764. Clinton 8/17/98 GJ at 86.
765. Clinton 8/17/98 GJ at 88-89.
766. Clinton 8/17/98 GJ at 89-90.
767. Clinton 8/17/98 GJ at 91-92.
768. Lewinsky 8/6/98 GJ at 151-52; Lewinsky 2/1/98 Statement
at 6. On December 23, Paula Jones's attorneys issued a subpoena
to the Secret Service.
769. Lindsey 3/12/98 GJ at 64-66; Lindsey 2/19/98 GJ at 9-10.
WAVES records reflect that Robert Bennett entered the White House
at 4:39 p.m. on Saturday, December 6. 1407-DC-00000005.
770. Lindsey 3/12/98 GJ at 65.
771. 964-DC-00000862 (Presidential mail notes).
772. Lindsey 3/12/98 GJ at 63-64. Mr. Lindsey refused to
answer questions about his December 6 meeting with the President,
claiming attorney-client privilege and Executive (presidential
communications) Privilege.(773)
773. Lindsey 3/12/98 GJ at 66. The U.S. District Court for
the District of Columbia Circuit rejected Mr. Lindsey's claim of
privilege, In re Grand Jury Proceedings, 5 F. Supp.2d 21 (D.D.C.
1998), and the Court of Appeals denied Mr. Lindsey's appeal, In
re Lindsey, __ F.3d __, 1998 WL 418780 (D.C. Cir. 1998). A
petition for Supreme Court review is currently pending.
__ U.S.L.W. __ (U.S. Aug. 21, 1998) (No. 98-316).
774. WAVES records reflect that Mr. Jordan entered the White
House at 5:21 p.m. on Sunday, December 7. 1178-DC-00000026.
775. Jordan 5/5/98 GJ at 83. He later testified that the
conversation was "[a]bsolutely not" about Ms. Lewinsky. Jordan
5/5/98 GJ at 116.
776. V004-DC-00000171 (Akin, Gump visitor records) (recording
visit of "Malensky"). Ms. Lewinsky recalled arranging the
meeting on December 8 or 9. Lewinsky 8/1/98 Int. at 3. See also
833-DC-00017886 (reflecting Ms. Lewinsky's call to Mr. Jordan on
December 8).
On December 8, Ms. Lewinsky sent Mr. Jordan a hat, a box of
chocolates, and a note gently reminding him of his promise to
help her find a job. Lewinsky 7/31/98 Int. at 15. She also sent
the President a note and some peach candies. Lewinsky 8/1/98
Int. at 2; Lewinsky 8/1/98 Int. at 2; 837-DC-00000017; 837-DC-00000020 (courier receipts).
777. Jordan 3/3/98 GJ at 41-42.
778. V004-DC-00000148 (Akin, Gump phone records). See also
Jordan 3/3/98 GJ at 54, 62-63, 70.
Mr. Halperin testified that Mr. Jordan had told him that
Ms. Lewinsky "was a bright young woman who was energetic and
enthusiastic and . . . encouraged me to meet with her." Halperin
4/23/98 GJ at 13. Similarly, Ms. Fairbairn stated that Mr.
Jordan had told her that he "would like to send [her] a resume of
a talented young lady and see if she matches up with any company
openings." Fairbairn 1/29/98 Int. at 1. Mr. Georgescu, however,
stated that Mr. Jordan "did not engage in a 'sales pitch' about
[Ms.] Lewinsky." Georgescu 3/25/98 Int. at 2.
779. Lewinsky 8/6/98 GJ at 121. Ms. Lewinsky left the
meeting with Mr. Jordan on December 8 with the impression that
Mr. Jordan was going to get her a job. Lewinsky 8/1/98 Int. at
4.
780. Lewinsky 8/6/98 GJ at 119.
781. Lewinsky 8/6/98 GJ at 120.
782. Lewinsky 8/6/98 GJ at 120.
783. Lewinsky 8/6/98 GJ at 120. In her handwritten proffer,
Ms. Lewinsky gave a very similar account of her second meeting
with Mr. Jordan: "Ms. L. met again with Mr. Jordan in the
beginning of December '97, at which time he provided Ms. L. with
a list of three people to contact and suggested language to use
in her letters to them. At some point, Mr. Jordan remarked
something about Ms. L. being a friend of the Pres. of the United
States. Ms. L. responded that she never really saw him as "the
President"; she spoke to him like a normal man and even got angry
with him like a normal man. Mr. Jordan asked what Ms. L. got
angry about. Ms. L. replied that the Pres. doesn't see or call
her enough. Mr. Jordan said Ms. L. should take her frustrations
out on him -- not the President.(784)