Mr. Podesta said he asked Betty Currie to have Ms. Lewinsky call him, but heard nothing until about October 1997, when Ms. Currie told him that Ms. Lewinsky was looking for opportunities in New York.⁽³³⁴⁾ The Ambassador to the United Nations, Bill Richardson, said that Mr. Podesta told him that Ms. Currie had a friend looking for a position in New York.⁽³³⁵⁾

According to Ms. Lewinsky, Ambassador Richardson called her on October 21, 1997,⁽³³⁶⁾ and interviewed her soon thereafter. She was then offered a position at the UN.⁽³³⁷⁾ Ms. Lewinsky was unenthusiastic.⁽³³⁸⁾ During the latter part of October 1997, the President and Ms. Lewinsky discussed enlisting Vernon Jordan to aid in pursuing private-sector possibilities.⁽³³⁹⁾

On November 5, 1997, Ms. Lewinsky met Mr. Jordan in his law office. Mr. Jordan told Ms. Lewinsky that she came "highly recommended."⁽³⁴⁰⁾ Ms. Lewinsky explained that she hoped to move to New York, and went over her list of possible employers.⁽³⁴¹⁾ Mr. Jordan telephoned President Clinton shortly after the meeting.⁽³⁴²⁾

Ms. Lewinsky had no contact with the President or Mr. Jordan for another month.⁽³⁴³⁾ On December 5, 1997, however, the parties in the Jones case exchanged witness lists. Ms. Jones's attorneys listed Ms. Lewinsky as a potential witness. The President testified that he learned that Ms. Lewinsky was on the list late in the day on December 6.⁽³⁴⁴⁾

The effort to obtain a job for Ms. Lewinsky then intensified. On December 7, President Clinton met with Mr. Jordan at the White House.⁽³⁴⁵⁾ Ms. Lewinsky met with Mr. Jordan on December 11 to discuss specific job contacts in New York. Mr. Jordan gave her the names of some of his business contacts.⁽³⁴⁶⁾ He then made calls to contacts at MacAndrews & Forbes (the parent corporation of Revlon), American Express, and Young & Rubicam.⁽³⁴⁷⁾

Mr. Jordan also telephoned President Clinton to keep him informed of the efforts to help Ms. Lewinsky. Mr. Jordan testified that President Clinton was aware that people were trying to get jobs for her, that Mr. Podesta was trying to help her, that Bill Richardson was trying to help her, but that she wanted to work in the private sector.⁽³⁴⁸⁾

On the same day of Ms. Lewinsky's meeting with Mr. Jordan, December 11, Judge Wright ordered President Clinton, over his objection, to answer certain written interrogatories as part of the discovery process in Jones. Those interrogatories required, among other things, the President to identify any government employees since 1986 with whom he had engaged in sexual relations (a term undefined for purposes of the interrogatory).⁽³⁴⁹⁾ On December 16, the President's attorneys received a request for production of documents that mentioned Monica Lewinsky by name.

On December 17, 1997, according to Ms. Lewinsky, President Clinton called her in the early morning and told her that she was on the witness list, and they discussed their cover stories.⁽³⁵⁰⁾ On December 18 and December 23, she interviewed for jobs with New York-based companies that had been contacted by Mr. Jordan.⁽³⁵¹⁾ On December 19, Ms. Lewinsky was served with a deposition subpoena by Ms. Jones's lawyers.⁽³⁵²⁾ On December 22, 1997, Mr. Jordan took her to her new attorney; she and Mr. Jordan discussed the subpoena, the Jones case, and her job search during the course of the ride.⁽³⁵³⁾

The President answered the "other women" interrogatory on December 23, 1997, by declaring under oath: "None."⁽³⁵⁴⁾

On Sunday, December 28, 1997, Monica Lewinsky and the President met in the Oval Office.⁽³⁵⁵⁾ During that meeting, the President and Ms. Lewinsky discussed both her move to New York and her involvement in the Jones suit.⁽³⁵⁶⁾

On January 5, 1998, Ms. Lewinsky declined the United Nations offer.⁽³⁵⁷⁾ On January 7, 1998, Ms. Lewinsky signed the affidavit denying the relationship with President Clinton (she had talked on the phone to the President on January 5 about it).⁽³⁵⁸⁾ Mr. Jordan informed the President of her action.⁽³⁵⁹⁾

The next day, on January 8, 1998, Ms. Lewinsky interviewed in New York with MacAndrews & Forbes, a company recommended by Vernon Jordan. The interview went poorly. Mr. Jordan then called Ronald Perelman, the Chairman of the Board at MacAndrews & Forbes. Mr. Perelman said Ms. Lewinsky should not worry, and that someone would call her back for another interview. Mr. Jordan relayed this message to Ms. Lewinsky, and someone called back that day.⁽³⁶⁰⁾

Ms. Lewinsky interviewed again the next morning, and a few hours later received an informal offer for a position.⁽³⁶¹⁾ She told Mr. Jordan of the offer, and Mr. Jordan then notified President Clinton with the news: "Mission accomplished."⁽³⁶²⁾

On January 12, 1998, Ms. Jones's attorneys informed Judge Wright that they might call Monica Lewinsky as a trial witness.⁽³⁶³⁾ Judge Wright stated that she would allow witnesses with whom the President had worked, such as Ms. Lewinsky, to be trial witnesses.⁽³⁶⁴⁾

In a call on January 13, 1998, a Revlon employee formalized the job offer, and asked Ms. Lewinsky to provide references.⁽³⁶⁵⁾ Either that day or the next, President Clinton told Erskine Bowles that Ms. Lewinsky "had found a job in the . . . private sector, and she had listed John Hilley as a reference, and could we see if he could recommend her, if asked."⁽³⁶⁶⁾ Thereafter, Mr. Bowles took the President's request to Deputy Chief of Staff John Podesta, who in turn spoke to Mr. Hilley about writing a letter of recommendation. After speaking with Mr. Podesta, Mr. Hilley agreed to write such a letter, but cautioned it would be a "generic" one.⁽³⁶⁷⁾ On January 14, at approximately 11:17 a.m., Ms. Lewinsky faxed her letter of acceptance to Revlon and listed Mr. Hilley as a reference.⁽³⁶⁸⁾

On January 15, the President responded to the December 15 request for production of documents relating to Monica Lewinsky by answering "none." On January 16, Ms. Lewinsky's attorney sent to the District Court in the Jones case her affidavit denying a "sexual relationship" with the President.⁽³⁶⁹⁾ The next day, on January 17, the President was deposed and his attorney used her affidavit as the President similarly denied a "sexual relationship."

B. Summary

When a party in a lawsuit (or investigation) provides job or financial assistance to a witness, a question arises as to possible witness tampering. The critical question centers on the intent of the party providing the assistance. Direct evidence of that intent often is unavailable. Indeed, in some cases, the witness receiving the job assistance may not even know that the party providing the assistance was motivated by a desire to stay on good terms with the witness during the pending legal proceeding.⁽³⁷⁰⁾ Similarly, others who are enlisted in the party's effort to influence the witness's testimony by providing job assistance may not be aware of the party's motivation and intent.

One can draw inferences about the party's intent from circumstantial evidence. In this case, the President assisted Ms. Lewinsky in her job search in late 1997, at a time when she would have become a witness harmful to him in the Jones case were she to testify truthfully. The President did not act half-heartedly. His assistance led to the involvement of the Ambassador to the United Nations, one of the country's leading business figures (Mr. Perelman), and one of the country's leading attorneys (Vernon Jordan).

The question, therefore, is whether the President's efforts in obtaining a job for Ms. Lewinsky were to influence her testimony⁽³⁷¹⁾ or simply to help an ex-intimate without concern for her testimony. Three key facts are essential in analyzing his actions: (i) the chronology of events, (ii) the fact that the President and Ms. Lewinsky both intended to lie under oath about the relationship, and (iii) the fact that it was critical for the President that Ms. Lewinsky lie under oath.

There is substantial and credible information that the President assisted Ms. Lewinsky in her job search motivated at least in part by his desire to keep her "on the team" in the Jones litigation.

VIII. There is substantial and credible information that the President lied under oath in describing his conversations with Vernon Jordan about Ms. Lewinsky.

President Clinton was asked during his civil deposition whether he had talked to Mr. Jordan about Ms. Lewinsky's involvement in the Jones case. The President stated that he knew Mr. Jordan had talked to Ms. Lewinsky about her move to New York, but stated that he did not recall whether Mr. Jordan had talked to Ms. Lewinsky about her involvement in the Jones case. The testimony was false. A lie under oath about these conversations was necessary to avoid inquiry into whether Ms. Lewinsky's job and her testimony were improperly related.

A. President's Testimony in the Jones Case

The President was questioned in his civil deposition about his conversations with Vernon Jordan regarding Ms. Lewinsky and her role in the Jones case. Beforehand, the President was asked a general question:

Q: Did anyone other than your attorneys ever tell you that Monica Lewinsky had been served with a subpoena in this case?

WJC: I don't think so.⁽³⁷²⁾

The President later testified in more detail about conversations he may have had with Mr. Jordan concerning Ms. Lewinsky's role in the case:

Q: Excluding conversations that you may have had with Mr. Bennett or any of your attorneys in this case, within the past two weeks has anyone reported to you that they had had a conversation with Monica Lewinsky concerning this lawsuit?

WJC: I don't believe so. I'm sorry, I just don't believe so.

* * * *

Q. Has it ever been reported to you that [Vernon Jordan] met with Monica Lewinsky and talked about this case?

WJC: I knew that he met with her. I think Betty suggested that he meet with her. Anyway, he met with her. I, I thought that he talked to her about something else. I didn't know that -- I thought he had given her some advice about her move to New York. Seems like that's what Betty said.⁽³⁷³⁾

B. Evidence That Contradicts the President's Civil Deposition Testimony

Vernon Jordan testified that his conversations with the President about Ms. Lewinsky's subpoena were, in fact, "a continuing dialogue."⁽³⁷⁴⁾ When asked if he had kept the President informed about Ms. Lewinsky's status in the Jones case in addition to her job search, Mr. Jordan responded: "The two -- absolutely."⁽³⁷⁵⁾

On December 19, Ms. Lewinsky phoned Mr. Jordan and told him that she had been subpoenaed in the Jones case.⁽³⁷⁶⁾ Following that call, Mr. Jordan telephoned the President to inform him "that Monica Lewinsky was coming to see me, and that she had a subpoena"⁽³⁷⁷⁾ -- but the President was unavailable.⁽³⁷⁸⁾ Later that day, at 5:01 p.m., Mr. Jordan had a seven-minute telephone conversation with the President:⁽³⁷⁹⁾

I said to the President, "Monica Lewinsky called me up. She's upset. She's gotten a subpoena. She is coming to see me about this subpoena. I'm confident that she needs a lawyer, and I will try to get her a lawyer."⁽³⁸⁰⁾

Later on December 19, after meeting with Ms. Lewinsky, Mr. Jordan went to the White House and met with the President alone in the Residence.⁽³⁸¹⁾ Mr. Jordan testified: "I told him that Monica Lewinsky had been subpoenaed, came to me with a subpoena."⁽³⁸²⁾ According to Mr. Jordan, the President "thanked me for my efforts to get her a job and thanked me for getting her a lawyer."⁽³⁸³⁾

According to Mr. Jordan, on January 7, 1998, Ms. Lewinsky showed him a copy of her signed affidavit denying any sexual relationship with the President.⁽³⁸⁴⁾ He testified that he told the President about the affidavit, probably in one of his two logged calls to the White House that day:⁽³⁸⁵⁾

Q: [W]alk us through what exactly you would have said on the portion of the conversation that related to Ms. Lewinsky and the affidavit.

VJ: Monica Lewinsky signed the affidavit.

* * * *

Q: [L]et's say if it was January 7th, or whenever it was that you informed him that she signed the affidavit,⁽³⁸⁶⁾ is it accurate that based on the conversations you had with him already, you didn't have to explain to him what the affidavit was?

VJ: I think that's a reasonable assumption.

Q: So that it would have made sense that you would have just said, "She signed the affidavit," because both you and he knew what the affidavit was?

VJ: I think that's a reasonable assumption.

Q: All right. When you indicated to the President that she had signed the affidavit, what, if anything, did he tell you?

VJ: I think he -- his judgment was consistent with mine that that was -- the signing of the affidavit was consistent with the truth.⁽³⁸⁷⁾

Mr. Jordan testified that "I knew that the President was concerned about the affidavit and whether or not it was signed. He was, obviously."⁽³⁸⁸⁾ When asked why he believed the President was concerned, Mr. Jordan testified:

Here is a friend of his who is being called as a witness in another case and with whom I had gotten a lawyer, I told him about that, and told him I was looking for a job for her. He knew about all of that. And it was just a matter of course that he would be concerned as to whether or not she had signed an affidavit foreswearing what I told you the other day, that there was no sexual relationship.⁽³⁸⁹⁾

Mr. Jordan summarized his contacts with the President about Monica Lewinsky and her involvement in the Jones litigation as follows:

I made arrangements for a lawyer and I told the President that. When she signed the affidavit, I told the President that the affidavit had been signed and when Frank Carter told me that he had filed a motion to quash, as I did in the course of everything else, I said to the President that I saw Frank Carter and he had informed me that he was filing a motion to quash. It was as a simple information flow, absent a substantive discussion about her defense, about which I was not involved.⁽³⁹⁰⁾

The President himself testified in the grand jury that he talked to Mr. Jordan about Ms. Lewinsky's involvement in the case. Despite his earlier statements at the deposition, the President testified to the grand jury that he had no reason to doubt that he had talked to Mr. Jordan about Ms. Lewinsky's subpoena, her lawyer, and her affidavit.⁽³⁹¹⁾

C. Summary

In his civil deposition, the President stated that he had talked to Vernon Jordan about Ms. Lewinsky's job. But as the testimony of Mr. Jordan reveals, and as the President as much as conceded in his subsequent grand jury appearance,⁽³⁹²⁾ the President did talk to Mr. Jordan about Ms. Lewinsky's involvement in the Jones case -- including that she had been subpoenaed, that Mr. Jordan had helped her obtain a lawyer, and that she had signed an affidavit denying a sexual relationship with the President. Given their several communications in the weeks before the deposition, it is not credible that the President forgot the subject of their conversations during his civil deposition. His statements "seems like that's what Betty said" and "I didn't know that" were more than mere omissions; they were affirmative misstatements.

The President's motive for making false and misleading statements about this subject in his civil deposition was straightforward. If the President admitted that he had talked with Vernon Jordan both about Monica Lewinsky's involvement in the Jones case and about her job, questions would inevitably arise about whether Ms. Lewinsky's testimony and her future job were connected. Such an admission by the President in his civil deposition likely would have prompted Ms. Jones's attorneys to inquire further into the subject. And such an admission in his deposition would have triggered public scrutiny when the deposition became public.

At the time of his deposition, moreover, the President was aware of the potential problems in admitting any possible link between those two subjects. A criminal investigation and substantial public attention had focused in 1997 on job assistance and payments made to Webster Hubbell in 1994. The jobs and money paid to Mr. Hubbell by friends and contributors to the President had raised serious questions about whether such assistance was designed to influence Mr. Hubbell's testimony about Madison-related matters.⁽³⁹³⁾ Some of Mr. Hubbell's jobs, moreover, had been arranged by Vernon Jordan, which was likely a further deterrent to the President raising both Ms. Lewinsky's job and her affidavit in connection with Vernon Jordan.

IX. There is substantial and credible information that President Clinton endeavored to obstruct justice by attempting to influence the testimony of Betty Currie.

In a meeting with Betty Currie on the day after his deposition and in a separate conversation a few days later, President Clinton made statements to her that he knew were false. The contents of the statements and the context in which they were made indicate that President Clinton was attempting to influence the testimony that Ms. Currie might have been required to give in the Jones case or in a grand jury investigation.⁽³⁹⁴⁾

A. Evidence

1. Saturday, January 17, 1998, Deposition

President Clinton's deposition in Jones v. Clinton occurred on Saturday, January 17, 1998. In that deposition, the President testified that he could not recall being alone with Monica Lewinsky and that he had not had sexual relations, a sexual affair, or a sexual relationship with her. During his testimony, the President referred several times to Betty Currie and to her relationship with Ms. Lewinsky. He stated, for example, that the last time he had seen Ms. Lewinsky was when she had come to the White House to see Ms. Currie;⁽³⁹⁵⁾ that Ms. Currie was present when the President had made a joking reference about the Jones case to Ms. Lewinsky;⁽³⁹⁶⁾ that Ms. Currie was his source of information about Vernon Jordan's assistance to Ms. Lewinsky;⁽³⁹⁷⁾ and that Ms. Currie had helped set up the meetings between Ms. Lewinsky and Mr. Jordan regarding her move to New York.⁽³⁹⁸⁾

At the deposition, Judge Wright imposed a protective order that prevented the parties from discussing their testimony with anyone else. "Before he leaves, I want to remind him, as the witness in this matter, . . . that this case is subject to a Protective Order regarding all discovery, . . . [A]ll parties present, including . . . the witness are not to say anything whatsoever about the questions they were asked, the substance of the deposition, . . ., any details . . . ."⁽³⁹⁹⁾

2. Sunday, January 18, 1998, Meeting with Ms. Currie

Because the President referred so often to Ms. Currie, it was foreseeable that she might become a witness in the Jones matter, particularly if specific allegations of the President's relationship with Ms. Lewinsky came to light.⁽⁴⁰⁰⁾ Indeed, according to Ms. Currie, President Clinton at some point may have told her that she might be asked about Monica Lewinsky.⁽⁴⁰¹⁾

Shortly after 7:00 p.m. on Saturday, January 17, 1998, two and a half hours after he returned from the deposition, President Clinton called Ms. Currie at home⁽⁴⁰²⁾ and asked her to come to the White House the next day.⁽⁴⁰³⁾ Ms. Currie testified that "[i]t's rare for [President Clinton] to ask me to come in on Sunday."⁽⁴⁰⁴⁾

At about 5:00 p.m. on Sunday, January 18, Ms. Currie went to meet with President Clinton at the White House. She told the grand jury:

He said that he had had his deposition yesterday, and they had asked several questions about Monica Lewinsky. And I was a little shocked by that or -- (shrugging). And he said -- I don't know if he said -- I think he may have said, "There are several things you may want to know," or "There are things -- " He asked me some questions.⁽⁴⁰⁵⁾

According to Ms. Currie, the President then said to her in succession:⁽⁴⁰⁶⁾

"You were always there when she was there, right? We were never really alone."⁽⁴⁰⁷⁾

"You could see and hear everything."⁽⁴⁰⁸⁾

"Monica came on to me, and I never touched her, right?"⁽⁴⁰⁹⁾

"She wanted to have sex with me, and I can't do that."⁽⁴¹⁰⁾

Ms. Currie indicated that these remarks were "more like statements than questions."⁽⁴¹¹⁾ Ms. Currie concluded that the President wanted her to agree with him.⁽⁴¹²⁾ She based that conclusion on the way he made most of the statements and on his demeanor.⁽⁴¹³⁾ Ms. Currie also said that she felt the President made these remarks to see her reaction.⁽⁴¹⁴⁾

Ms. Currie said that she indicated her agreement with each of the President's statements,⁽⁴¹⁵⁾ although she knew that the President and Ms. Lewinsky had in fact been alone in the Oval Office and in the President's study.⁽⁴¹⁶⁾ Ms. Currie also knew that she could not or did not in fact hear or see the President and Ms. Lewinsky while they were alone.⁽⁴¹⁷⁾

In the context of this conversation, President Clinton appeared to be "concerned," according to Ms. Currie.⁽⁴¹⁸⁾

334. Podesta 2/5/98 GJ at 31-33, 35, 40-41.

335. Richardson 4/30/98 Depo. at 28.

336. Lewinsky 7/31/98 Int. at 12. Ms. Lewinsky said that she spoke to President Clinton about the phone call on October 23, during which she suggested to the President that she was interested in some job other than at the United Nations. Id. According to Ms. Lewinsky, the President replied that he just wanted her to have some options. Id.

Ms. Lewinsky said that she spoke to the President again on October 30 about the interview, in which she expressed anxiety about meeting with the Ambassador. Ms. Lewinsky said that the President told her to call Betty Currie after the interview so he would know how the interview went. Id. at 13.

337. Lewinsky 7/31/98 Int. at 14.

338. Lewinsky 8/26/98 Depo. at 67; Lewinsky 7/31/98 Int. at 14.

339. >Lewinsky 7/31/98 Int. at 14.

340. Id. at 15. Ms. Lewinsky related this incident to her friend, Catherine Allday Davis, in a near-contemporaneous email. 1037-DC-00000017. See also Catherine Davis 3/17/98 GJ at 124.

341. Lewinsky 7/31/98 Int. at 14-15.

342. V004-DC-00000135 (Akin Gump phone records); Jordan 5/5/98 GJ at 52-55.

343. Lewinsky 8/6/98 GJ at 26-27 and GJ Exhibit ML-7. Ms. Lewinsky stated that just before Thanksgiving, 1997, she called Betty Currie and asked her to contact Vernon Jordan and prod him along in the job search. Lewinsky 8/4/98 Int. at 8. It was Ms. Lewinsky's understanding that Jordan was helping her at the request of the President and Ms. Currie. Id.

344. See Clinton 8/17/98 GJ at 84-85. Under the federal witness tampering statutes, it is a crime to corruptly persuade a witness to alter his testimony. See 18 U.S.C. §§ 1503, 1512.

345. 1178-DC-00000026 (WAVES records).

346. Lewinsky 8/4/98 Int. at 2.

347. Jordan 3/3/98 GJ at 48-49.

348. Id. at 65.

349. 921-DC-000000459-66.

350. Lewinsky 8/6/98 GJ at 121-23.

351. Id. at 121; Lewinsky 8/1/98 Int. at 6, 10.

352. Lewinsky 8/6/98 GJ at 127-28.

353. Id. at 138-41; Lewinsky 2/1/98 Statement at 6; cf. Jordan 3/3/98 GJ at 182-90 (recalls discussion of job search only).

354. V002-DC-000000052 (President Clinton's Supplemental Responses to Plaintiff's Second Set of Interrogatories).

355. Lewinsky 8/6/98 GJ at 149.

356. Lewinsky 8/6/98 GJ at 151-52; Lewinsky 7/27/98 Int. at 7. This was the same meeting where the President and Ms. Lewinsky discussed their concerns over the Lewinsky subpoena and its demand for the production of gifts.

357. Sutphen 5/27/98 Depo. at 39; Lewinsky 7/27/98 Int. at 5.

358. Lewinsky 8/6/98 GJ at 191-98, 205-06.

359. Jordan 5/5/98 GJ at 223-25.

360. Id. at 232; Lewinsky 8/6/98 GJ at 209.

361. Lewinsky 8/6/98 GJ at 208-10.

362. Jordan 5/28/98 GJ at 39 (emphasis added).

363. Ms. Jones's attorney named the "other women" he planned to call at trial:

Mr. Fisher: They would include . . . Monica Lewinsky

Judge Wright: Can you tell me who she is?

Mr. Fisher: Yes, your Honor.

Judge Wright: I never heard of her.

Mr. Fisher: She's the young woman who worked in the White House for a period of time and was later transferred to a job in the Pentagon.

1414-DC-00001327-28.

364. 1414-DC-00001334-46.

365. Lewinsky 8/6/98 GJ at 214.

366. Bowles 4/2/98 GJ at 78-79.

367. Hilley 5/19/98 GJ at 74; Hilley 5/26/98 GJ at 11.

368. 830-DC-0000007.

369. 921-DC-00000775-78; 1292-DC-000000661-86.

370. The arrangement may not be explicitly spelled out. In this case, for example, there is no evidence that Ms. Lewinsky received an explicit proposal where someone said, "I'll give you a job if you lie under oath."

371. In a recorded conversation, Ms. Lewinsky discussed the job assistance various individuals, including Vernon Jordan, gave Webster Hubbell, and she expressed her concern that someone could similarly consider the assistance she was provided as improper in some manner: "I think somebody could construe, okay? Somebody could construe or say, 'Well, they gave her a job to shut her up. They made her happy.'" T2 at 11.

372. Clinton 1/17/98 Depo. at 68-69 (emphasis added).

373. Id. at 72 (emphasis added). See also id. at 73 ("[m]y understanding was . . . that she was going to move to New York and that she was looking for some advice [from Jordan] about what she should do when she got there").

374. Jordan 3/5/98 GJ at 26.

375. Jordan 3/5/98 GJ at 29.

376. 833-DC-0017890 (Pentagon phone records). See also Jordan 3/3/98 GJ at 92-93 (testifying that Ms. Lewinsky called him up and she was "very upset" about "being served with a subpoena in the Paula Jones case").

377. Jordan 5/5/98 GJ at 142-43.

378. Id. at 133-34. Mr. Jordan had told Ms. Lewinsky to come see him at 5:00 p.m. Lewinsky 8/6/98 GJ at 129. See also Jordan 5/5/98 GJ at 144 (relating why he wanted to tell the President about Ms. Lewinsky's subpoena).

379. 1178-DC-00000014 (White House phone records); Jordan 5/5/98 GJ at 145.

380. Jordan 5/5/98 GJ at 145-47.

381. Jordan 3/3/98 GJ at 167-69. White House records indicate that Mr. Jordan was scheduled to arrive at 8:00 p.m., and actually arrived at 8:15 p.m. See 1178-DC-00000026 (WAVES record). Mr. Jordan testified, however, that he is certain that he did not arrive at the White House until after 10 p.m. Jordan 5/5/98 GJ at 164.

382. Jordan 3/3/98 GJ at 169.

383. Id. at 172.

384. Jordan 5/5/98 GJ at 221-22.

385. Jordan 3/5/98 GJ at 24-25, 33; Jordan 5/5/98 GJ at 223-26; V004-DC-00000159 (Akin Gump phone records).

386. The affidavit is dated January 7, 1998, so the conversation informing the President that it had been signed could not have occurred any earlier than this date.

387. Jordan 5/5/98 GJ at 224-26.

388. Jordan 3/5/98 GJ at 25. Cf. Jordan 5/5/98 GJ at 225-26 (When President was told Ms. Lewinsky signed affidavit, "[t]here was no elation. There was no celebration.").

389. Jordan 3/5/98 GJ at 26 (emphasis added).

390. Id. at 125.

391. Clinton 8/17/98 GJ at 73-75.

392. Id. at 75-77.

393. That matter is still under criminal investigation by this Office.

394. Under the federal witness tampering and obstruction of justice statutes, it is a crime to attempt to corruptly persuade another person with intent to influence the person's testimony in an official proceeding. See 18 U.S.C. §§ 1503, 1512.

395. Clinton 1/17/98 Depo. at 68.

396. Id. at 70-71.

397. Id. at 72-73, 79.

398. Id. at 80-82.

399. Id. at 212-213.

400. Jones v. Clinton, Order of Judge Susan Webber Wright, January 29, 1998, at 2.

401. Currie 1/24/98 Int. at 8 ("CURRIE advised CLINTON may have mentioned that CURRIE might be asked about LEWINSKY"); Currie 5/6/98 GJ at 118 (Q: "Didn't the President talk to you about Monica's name coming up in those cases [Whitewater or Jones v. Clinton]?" BC: "I have a vague recollection of him saying that her name may come up. Either he told me, somebody told me, but I don't know how it would come up.").

402. Currie 5/7/98 GJ at 80-81; GJ Exhibit BC 3-10, 1248-DC-00000307 (Presidential Call Log, Jan. 17, 1998). The White House call log indicates that the President called Ms. Currie at 7:02 p.m., they talked at 7:13 p.m., and the call ended at 7:14 p.m.

The President returned to the White House from the deposition at 4:26 p.m. 1248-DC-00000288 (Kearney's logs).

403. Currie 1/27/98 GJ at 65-66. The President confirmed that he called Betty Currie shortly after his deposition, and that he asked her to come in on Sunday, her day off. Clinton 8/17/98 GJ at 148-49.

The next day at 1:11 p.m., the President again called Ms. Currie at home. Currie 5/7/98 GJ at 85. GJ Exhibit BC 3-11, 1248-DC-00000311 (Presidential Call Log, Jan. 18, 1998). Ms. Currie could not recall the content of the second call, stating: "He may have called me on Sunday at 1:00 after church to see what time I can actually come in. I don't know. That's the best I can recollect." Id. at 89.

404. Currie 5/7/98 GJ at 91. See also Clinton 8/17/98 GJ at 149 (acknowledging that Ms. Currie normally would not be in the White House on Sunday).

405. Currie 1/27/98 GJ at 70.

406. Currie 1/24/98 Int. at 6.

407. Currie 1/27/98 GJ at 71, 73-74. At different points in the grand jury testimony, there are minor variations in the wording used or agreed to by Ms. Currie in recounting the President's statements. Compare id. at 71 ("You were always there when Monica was there." (Currie statement)) with id. at 74 (Q: "'You were always there when she was there, right?' Is that the way you remember the President stating it to you?" BC: "That's how I remember him stating it to me.").

408. Id. at 72.

409. Id. at 72. See also Currie 1/24/98 Int. at 6.

410. Ms. Currie interpreted this last comment as simply a statement, not necessarily one for which the President was seeking her agreement. Currie 1/27/98 GJ at 72-73.

411. Currie 1/27/98 GJ at 71 (Q: "Okay. And then you told us that the President began to ask you a series of questions that were more like statements than questions." BC: "Right.").

412. Id. at 72-76.

413. Id.

414. Currie 1/24/98 Int. at 7.

415. Id. at 6.

416. Currie 1/27/98 GJ at 32-34.

417. Id. at 82-83.

418. Id. at 76.