One Thing. Federal White Collar Defense.

Excerpts From The Grand Jury Questioning Of President William Jefferson Clinton

What Is Truth?

For the Independent Counsel: Kenneth W. Starr, Independent Counsel; Jackie M. Bennett Jr., Robert J. Bittman and Solomon L. Wisenberg, deputy independent counsels; Michael W. Emmick, Mary Anne Wirth, and Bernard J. Apperson, associate independent counsels,

For the President: David E. Kendall and Nicole Seligman, of Williams & Connolly; Charles F.C. Ruff, counsel to the president.

MR. APPERSON: Mr. Wisenberg, the grand jury is in session. There is a quorum. There are no unauthorized persons in the grand jury room and they are prepared to receive the testimony of the President.

MR. WISENBERG: Thank you, Mr. Apperson. If we could proceed with the oath, please?

WHEREUPON, William Jefferson Clinton, having been called for examination by the Independent Counsel, and having been first duly sworn, was examined and testified as follows:

Examination By The Independent Counsel


Q: Good afternoon, Mr. President.

PRESIDENT CLINTON: Good afternoon.

Q: Could you please state your full name for the record, sir?

PRESIDENT CLINTON: William Jefferson Clinton.

Q: My name is Sol Wisenberg and I’m a Deputy Independent Counsel with the Office of Independent Counsel. With me today are some other attorneys from the Office of Independent Counsel.

At the courtroom are the ladies and gentlemen of the grand jury prepared to receive your testimony as you give it. Do you understand, sir?


Q: This proceeding is subject to Rule 6(e) of the Federal Rules of Criminal Procedure as modified by Judge Johnson’s order. You are appearing voluntarily today as a part of an agreement worked out between your attorney, the Office of the Independent Counsel, and with the approval of Judge Johnson.

Is that correct, sir?

PRESIDENT CLINTON: That is correct.

MR. KENDALL: Mr. Wisenberg, excuse me. You referred to Judge Johnson’s order. I’m not familiar with that order. Have we been served that, or not?

MR. WISENBERG: No. My understanding is that that is an order that the Judge is going to sign today. She didn’t have the name of a WHCA person. And basically my understanding is that it will cover all of the attorneys here today and the technical people in the room, so that they will be authorized persons permitted to hear grand jury testimony that they otherwise wouldn’t be authorize to hear.

MR. KENDALL: Thank you.


Q: The grand jury, Mr. President, has been empaneled by the United States District Court for the District of Columbia. Do you understand that, sir?


Q: And, among other things, is currently investigating under the authority of the Court of Appeals upon application by the Attorney General, whether Monica Lewinsky or others obstructed justice, intimidated witnesses, or committed other crimes related to the case of Jones v. Clinton.

Do you understand that, sir?


Q: And today, you will be receiving questions not only from attorneys on the OIC staff, but from some of the grand jurors, too. Do you understand that?


Q: I’m going to talk briefly about your rights and responsibilities as a grand jury witness. Normally, grand jury witnesses, while not allowed to have attorneys in the grand jury room with them, can stop and consult with their attorneys. Under our arrangement today, your attorneys are here and present for consultation and you can break to consult with them as necessary, but it won’t count against our total time.

Do you understand that, sir?

PRESIDENT CLINTON: I do understand that.

Q: You have a privilege against self-incrimination. If a truthful answer to any question would tend to incriminate you, you can invoke the privilege and that invocation will not be used against you. Do you understand that?


Q: And if you don’t invoke it, however, any answer that you do give can and will be used against you. Do you understand that, sir?


Q: Mr. President, you understand that your testimony here today is under oath?


Q: And do you understand that because you have sworn to tell the truth, the whole truth, and nothing but the truth, that if you were to lie or intentionally mislead the grand jury, you could be prosecuted for perjury and/or obstruction of justice?

PRESIDENT CLINTON: I believe that’s correct.

Q: Is there anything that you – I’ve stated to you regarding your rights and responsibilities that you would like me to clarify or that you don’t understand?


Q: Mr. President, I would like to read for you a portion of Federal Rule of Evidence 603, which discusses the important function the oath has in our judicial system. It says that the purpose of the oath is one, “calculated to awaken the witness’ conscience and impress the witness’ mind with the duty” to tell the truth.

Could you please tell the grand jury what that oath means to you for today’s testimony?

PRESIDENT CLINTON: I have sworn an oath to tell the grand jury the truth, and that’s what I intend to do.

Q: You understand that it requires you to give the whole truth, that is, a complete answer to each question, sir?

PRESIDENT CLINTON: I will answer each question as accurately and fully as I can.

Q: Now, you took the same oath to tell the truth, the whole truth, and nothing but the truth on January 17th, 1998 in a deposition in the Paula Jones litigation; is that correct, sir?

PRESIDENT CLINTON: I did take an oath then.

Q: Did the oath you took on that occasion mean the same to you then as it does today?

PRESIDENT CLINTON: I believed then that I had to answer the questions truthfully, that is correct.

Q: I’m sorry. I didn’t hear you, sir.

PRESIDENT CLINTON: I believed that I had to answer the questions truthfully. That’s correct.

Q: And it meant the same to you then as it does today?

PRESIDENT CLINTON: Well, no one read me a definition then and we didn’t go through this exercise then. I swore an oath to tell the truth, and I believed I was bound to be truthful and I tried to be.

Q: At the Paula Jones deposition, you were represented by Mr. Robert Bennett, your counsel, is that correct?

PRESIDENT CLINTON: That is correct.

Q: He was authorized by you to be your representative there, your attorney, is that correct?

PRESIDENT CLINTON: That is correct.

Q: Your counsel, Mr. Bennett, indicated at page 5 of the deposition, lines 10 through 12, and I’m quoting, “the President intends to give full and complete answers as Ms. Jones is entitled to have.”

My question to you is, do you agree with your counsel that a plaintiff in a sexual harassment case is, to use his words, entitled to have the truth?

PRESIDENT CLINTON: I believe that I was bound to give truthful answers, yes, sir.

Q: But the question is, sir, do you agree with your counsel that a plaintiff in a sexual harassment case is entitled to have the truth?

PRESIDENT CLINTON: I believe when a witness is under oath in a civil case, or otherwise under oath, the witness should do everything possible to answer the questions truthfully.

MR. WISENBERG: I’m going to turn over questioning now to Mr. Bittman of our office, Mr. President.


The Meaning Of “Is”


Q: Mr. President, I want to, before I go into a new subject area, briefly go over something you were talking about with Mr. Bittman. The statement of your attorney, Mr. Bennett, at Paula Jones deposition, “Counsel is fully aware” – it’s page 54, line 5 – “Counsel is fully aware that Ms. Lewinsky has filed, has an affidavit which they are in possession of saying that there is absolutely no sex of any kind in any manner, shape or form, with President Clinton”. That statement is made by your attorney in front Judge Susan Webber Wright, correct?

PRESIDENT CLINTON: That’s correct.

Q: That statement is a completely false statement.

Whether or not Mr. Bennett knew of your relationship with Ms. Lewinsky, the statement that there was “no sex of any kind in any manner, shape or form, with President Clinton,” was an utterly false statement. Is that correct?

PRESIDENT CLINTON: It depends on what the meaning of the word “is” is. If the – if he – if “is” means is and never has been that is not – that is one thing. If it means there is none, that was a completely true statement. But, as I have testified, and I’d like to testify again, this is – it is somewhat unusual for a client to be asked about his lawyer’s statements, instead of the other way around. I was not paying a great deal of attention to this exchange. I was focusing on my own testimony. And if you go back and look at the sequence of this, you will see that the Jones lawyers decided that this was going to be the Lewinsky deposition, not the Jones deposition. And, given the facts of their case, I can understand why they made that decision. But that is not how I prepared for it. That is not how I was thinking about it. And I am not sure, Mr. Wisenberg, as I sit here today, that I sat there and followed all these interchanges between the lawyers. I’m quite sure that I didn’t follow all the interchanges between the lawyers all that carefully. And I don’t really believe, therefore, that I can say Mr. Bennett’s testimony or statement is testimony and is imputable to me. I didn’t – I don’t know that I was even paying that much attention to it.

Q: You told us you were very well prepared for the deposition.

PRESIDENT CLINTON: No. I said I was very well prepared to talk about Paula Jones and to talk about Kathleen Willey, because she had made a related charge. She was the only person that I think I was asked about who had anything to do with anything that would remotely approximate sexual harassment. The rest of this looked to me like it was more of a way to harass me.

Q: You are the President of the United States and your attorney tells a United States District Court Judge that there is no sex of any kind, in any way, shape or form, whatsoever. And you feel no obligation to do anything about that at that deposition, Mr. President?

PRESIDENT CLINTON: I have told you, Mr. Wisenberg, I will tell you for a third time. I am not even sure that when Mr. Bennett made that statement that I was concentrating on the exact words he used. Now, if someone had asked me on that day, are you having any kind of sexual relations with Ms. Lewinsky, that is, asked me a question in the present tense, I would have said no. And it would have been completely true.

Q: Was Mr. Bennett aware of this tense-based distinction you are making now –


MR. KENDALL: I’m going to object to any questions about communications with private counsel.

MR. WISENBERG: Well, the witness has already testified, I think, that Mr. Bennett didn’t know about the inappropriate relationship with Ms. Lewinsky. I guess –

PRESIDENT CLINTON: Well, you’ll have to ask him that, you know. He was not a sworn witness and I was not paying that close attention to what he was saying, I’ve told you that repeatedly. I was – I don’t – I never even focused on that until I read it in this transcript in preparation for this testimony. When I was in there, I didn’t think about my lawyers. I was, frankly, thinking about myself and my testimony and trying to answer the questions.


Q: I just want to make sure I understand, Mr. President. Do you mean today that because you were not engaging in sexual activity with Ms. Lewinsky during the deposition that the statement of Mr. Bennett might be literally true?

PRESIDENT CLINTON: No, sir. I mean that at the time of the deposition, it had been – that was well beyond any point of improper contact between me and Ms. Lewinsky. So that anyone generally speaking in the present tense, saying there is not an improper relationship, would be telling the truth if that person said there was not, in the present tense; the present tense encompassing many months. That’s what I meant by that. Not that I was – I wasn’t trying to give you a cute answer, that I was obviously not involved in anything improper during a deposition. I was trying to tell you that generally speaking in the present tense, if someone said that, that would be true. But I don’t know what Mr. Bennett had in his mind. I don’t know. I didn’t pay any attention to this colloquy that went on. I was waiting for my instructions as a witness to go forward I was worried about my own testimony.


Vernon Jordan

Q: I want to go back to some questions about Mr. Jordan and we are going to touch a little bit on the December 19th meeting and some others. Mr. Jordan is a long-time friend of yours, is that correct, Mr. President?

PRESIDENT CLINTON: Yes, sir. We’ve been friends probably 20 years, maybe more.

Q: You said you consider him to be a truthful person, correct?


Q: If Mr. Jordan has told us that he visited you in the Residence on the night of the 19th, after a White House holiday dinner, to discuss Monica Lewinsky and her subpoena with you, do you have any reason to doubt it?

PRESIDENT CLINTON: No. I’ve never known him to say anything that wasn’t true. And his memory, of these events, I think, would be better than mine because I had a lot of other things going on.

Q: We have WAVE records that will show that, but in the interest of time I’m not going to – since you don’t dispute that, I’m not going to show them right now. And, in fact, that was the very day Monica Lewinsky was subpoenaed, wasn’t it, the night that he came to see you?

PRESIDENT CLINTON: I don’t have an independent memory of that, but you would probably know that. I mean, I’m sure there is a record of when she got her subpoena.

Q: If Mr. Jordan has told us that he spoke with you over the phone within about an hour of Monica receiving her subpoena, and later visited you that very day, the night at the White House, to discuss it, again you’d have no reason doubt him, is that correct?

PRESIDENT CLINTON: I’ve already – I believe I’ve already testified about that here today, that I had lots of conversations with Vernon. I’m sure that I had lots of conversations with him that included comments about this. And if he has a specific memory of when I had some conversation on a certain day, would be inclined to trust his memory over mine, because under the present circumstances my head’s probably more cluttered than his, and my schedule is probably busier. He’s probably got better records.

Q: And when Mr. Jordan met with you at the Residence that night, sir, he asked you if you’d been involved in a sexual relationship with Monica Lewinsky, didn’t he?

PRESIDENT CLINTON: I do not remember exactly what the nature of the conversation was. I do remember that I told him that there was no sexual relationship between me and Monica Lewinsky, which was true. And that – then all I remember for the rest is that he said he had referred her to a lawyer, and I believe it was Mr. Carter, and I don’t believe I’ve ever met Mr. Carter. I don’t think I know him.

Q: Mr. President, if Mr. Jordan has told us that he had a very disturbing conversation with Ms. Lewinsky that day, then went over to visit you at the White House, and that before he asked you the question about a sexual relationship, related that disturbing conversation to you, the conversation being that Ms. Lewinsky had a fixation on you and thought that perhaps the First Lady would leave you at the end of – that you would leave the First Lady at the end of your term and come be with Ms. Lewinsky, do you have any reason to doubt him that it was on that night that that conversation happened?

PRESIDENT CLINTON: All I can tell you, sir, is I, I certainly don’t remember him saying that. Now, he could have said that because, as you know, a great many things happened in the ensuing two or three days. And I could have just forgotten it. But I don’t remember him ever saying that.

Q: At any time?

PRESIDENT CLINTON: No, I don’t remember him saying that. What I remember was that he said that Monica came to see him, that she was upset that she was going to have to testify, that he had referred her to a lawyer.

Q: In fact, she was very distraught about the subpoena, according to Mr. Jordan, wasn’t she?

PRESIDENT CLINTON: Well, he said she was upset about it. I don’t remember – I don’t remember any, at any time when he said this, this other thing you just quoted me. I’m sorry. I just don’t remember that.

Q: That is something that one would be likely to remember, don’t you think, Mr. President?

PRESIDENT CLINTON: I think I would, and I’d be happy to share it with you if I did. I only had one encounter with Ms. Lewinsky, I seem to remember, which was somewhat maybe reminiscent of that. But not that, if you will, obsessive, if that’s the way you want to use that word.

Q: Do you recall him at all telling you that he was concerned about her fascination with you, even if you don’t remember the specific conversation about you leaving the First Lady?

PRESIDENT CLINTON: I recall him saying he thought that she was upset with – somewhat fixated on me, that she acknowledged that she was not having a sexual relationship with me, and that she did not want to be drug into the Jones lawsuit. That’s what I recall. And I recall his getting, saying that he had recommended a lawyer to her and she had gone to see the lawyer. That’s what I recall.

I don’t remember the other thing you mentioned. I just – I might well remember it if he had said it. Maybe he said it and I’ve forgotten it, but I don’t – I can’t tell you that I remember that.

Q: Mr. President, you swore under oath in the Jones case that you didn’t think anyone other than your lawyers had ever told you that Monica Lewinsky had been subpoenaed. Page 68, line 22 [sic] through page 69, line 3. Here’s the testimony, sir.

Question – we’ve gone over it a little bit before: “Did anyone other than your attorneys ever tell you that Monica Lewinsky had been served with a subpoena in this case?” Answer, “I don’t think so.” Now, this deposition was taken just three and a half weeks after, by your own testimony, Vernon Jordan made a trip at night to the White House to tell you, among other things, that Monica Lewinsky had been subpoenaed and was upset about it. Why did you give that testimony under oath in the Jones case, sir?

PRESIDENT CLINTON: Well, Mr. Wisenberg, I think you have to – again, you have to put this in the context of the flow of questions, and I’ve already testified to this once today, I will testify to it again. My answer to the next question, I think, is a way of finishing my answer to the question and the answer you’ve said here. I was trying to remember who the first person, other than Mr. Bennett – I don’t think Mr. Bennett – who the first person told me that, who told me Paula Jones had, I mean, excuse me, Monica Lewinsky had a subpoena. And I thought that Bruce Lindsey was the first person. And that’s how I was trying to remember that. Keep in mind, sort of like today, these questions are being kind of put at me rapid-fire. But, unlike today, I hadn’t had the opportunity to prepare at this level of detail. I didn’t – I was trying to keep a lot of things in my head that I had remembered with regard to the Paula Jones case and the Kathleen Willey matter, because I knew I would be asked about them. And I gave the best answers I could. Several of my answers are somewhat jumbled. But this is an honest attempt here – if you read both these answers, it’s obvious they were both answers to that question you quoted, to remember the first person, who was not Mr. Bennett, who told me. And I don’t believe Vernon was the first person who told me. I believe Bruce Lindsey was.

Q: Let me read the question, because I want to talk about the first person issue. The question on line 25 of page 68 is, “Did anyone other than your attorneys ever tell you that Monica Lewinsky had been served with a subpoena in this case?” Answer, “I don’t think so.” You would agree with me, sir, that the question doesn’t say, the question doesn’t say anything about who was the first person. It just says, did anyone tell you. Isn’t that correct?

PRESIDENT CLINTON: That’s right. And I said Bruce Lindsey, because I was trying to struggle with who – where I had heard this. And they were free to ask a follow-up question, and they didn’t.

Q: Mr. President, three and a half weeks before, Mr. Jordan had made a special trip to the White House to tell you Ms. Lewinsky had been subpoenaed; she was distraught; she had a fixation over you. And you couldn’t remember that, three and a half weeks later?

PRESIDENT CLINTON: Mr. Wisenberg, if – they had access to all this information from their conversations with Linda Tripp, if that was the basis of it. They were free to ask me more questions. They may have been trying to trick me.

Now, they knew more about the details of my relationship with Monica Lewinsky. I’m not sure everything they knew was true, because I don’t know. I’ve not heard these tapes or anything. But they knew a lot more than I did. And instead of trying to trick me, what they should have done is to ask me specific questions, and I invited them on more than one occasion to ask follow-up questions.

This is the third or fourth time that you seem to be complaining that I did not do all their work for them. That just sitting here answering these questions to the best of my memory, with limited preparation, was not enough. That I should have actually been doing all their work for them. Now, they’d been up all night with Linda Tripp, who had betrayed her friend, Monica Lewinsky, stabbed her in the back and given them all this information. They could have helped more. If they wanted to ask me follow-up questions, they could. They didn’t. I’m sorry. I did the best I could.

Q: Can you tell the grand jury what is tricky about the question, “Did anyone other than your attorneys ever tell you” –

PRESIDENT CLINTON: No, there’s nothing – I’m just telling – I have explained. I will now explain for the third time, sir. I was being asked a number of questions here. I was struggling to remember then. There were lots of things that had gone on during this time period that had nothing to do with Monica Lewinsky.


“I Am Not Going To Answer Your Trick Questions”

Q: You’ve told us that you understand your obligation then, as it is now, is to tell the whole truth, sir. Do you recall that?

PRESIDENT CLINTON: I took the oath here.

Q: If Vernon Jordan –

PRESIDENT CLINTON: You even read me a definition of the oath.

Q: If Vernon Jordan has told us that you have an extraordinary memory, one of the greatest memories he’s ever seen in a politician, would that be something you would care to dispute?

PRESIDENT CLINTON: No, I do have a good memory. At least, I have had a good memory in my life.

Q: Do you understand that if you answered, “I don’t think so”, to the question, has anyone other than your attorneys told you that Monica Lewinsky has been served with a subpoena in this case, that if you answered, “I don’t think so”, but you really knew Vernon Jordan had been telling you all about it, you understand that that would be a false statement, presumably perjurious?

PRESIDENT CLINTON: Mr. Wisenberg, I have testified about this three times. Now, I will do it the fourth time. I am not going to answer your trick questions.

I – people don’t always hear the same questions in the same way. They don’t always answer them in the same way. I was so concerned about the question they asked me that the next question I was asked, I went back to the previous question, trying to give an honest answer about the first time I heard about the Lewinsky subpoena. I – look. I could have had no reasonable expectation that anyone would ever know that, that – or not, excuse me, not know if this thing – that I would talk to Vernon Jordan about nearly everything. I was not interested in – if the implication of your question is that somehow I didn’t want anybody to know I had ever talked to Vernon Jordan about this, that’s just not so. It’s also – if I could say one thing about my memory. I have been blessed and advantaged in my life with a~ good memory. Now, I have been shocked, and so have members of my family and friends of mine, at how many things that I have forgotten in the last six years, I think because of the pressure and the pace and the volume of events in the President’s life, compounded by the pressure of your four-year inquiry, and all the other things that have happened, I’m amazed there are lots of times when I literally can’t remember last week. If you ask me, did you talk to Vernon – when was the last time you talked to Vernon Jordan, what time of day was it, when did you see him, what did you say, my answer was the last – you know, if you answered [sic] me, when was the last time you saw a friend of yours in California, if you asked me a lot of questions like that, my memory is not what it was when I here, because my life is so crowded.

And now that – as I said, you have made this the most important issue in America. I mean you have made it the most important issue in America from your point of view. At the time this was occurring, even though I was concerned about it, and I hoped she didn’t have to testify, and I hoped this wouldn’t come out, I felt – I will say again – that she could honestly fill out an affidavit that, under reasonable circumstances, would relieve her of the burden of testifying. I am not trying to exclude the fact that I talked to Vernon here. I just – all I can tell you is I believe this answer reflects I was trying to remember the first person who told me who was not Mr. Bennett, and I believe it was Bruce Lindsey.

Q: As you yourself recalled, just recalled, Mr. President, Vernon Jordan not only discussed the subpoena with you that night, but discussed Frank Carter, the lawyer he had gotten for Ms. Lewinsky. And also Mr. Jordan discussed with you over the next few weeks, after the 19th of December, in addition to the job aspects of Ms. Lewinsky’s job, discussed with you her affidavit that she was preparing in the case. Is that correct, sir?

PRESIDENT CLINTON: I believe that he did notify us, I think, when she signed her affidavit, I have a memory of that. Or it seems like he said that she had signed her affidavit.

Q: If he’s told us that he notified you around January 7th, when she signed her affidavit, and that you generally understood that it would deny a sexual relationship, do you have any reason to doubt that?


Q: So, that’s the affidavit, the lawyer, and the subpoena. And yet when you were asked, sir, at the Jones deposition about Vernon Jordan, and specifically about whether or not he had discussed the lawsuit with you, didn’t reveal that to the Court.

I want to refer you to page 72, line 16, where this starts. It’s going to go down, it might go down somewhat.

Line 16. Question,. “Has it ever been reported to you that he …. and that’s referring to Mr. Jordan. At line 12 you were asked, “You know a man named Vernon Jordan?”, and you answer, “I know him well.” Going down to 16, “Has it ever been reported to you that he met with Monica Lewinsky and talked about this case?”

This is your answer, or a portion of it: “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.”

Why didn’t you tell the Court, when you were under oath and sworn to tell the truth, the whole truth, and nothing but the truth, that you had been talking with Vernon Jordan about the case, about the affidavit, the lawyer, the subpoena?

PRESIDENT CLINTON: Well, that’s not the question I was asked. I was not asked any question about – I was asked, “Has it ever been reported to you that he met with Monica Lewinsky and talked about this case.” I believe – I may be wrong about this – my impression was that at the time, I was focused on the meetings. I believe the meetings he had were meetings about her moving to New York and getting a job. I knew at some point that she had told him that she needed some help, because she had gotten a subpoena. I’m not sure I know whether she did that in a meeting or a phone call. And I was not, I was not focused on that.

I know that, I know Vernon helped her to get a lawyer, Mr. Carter. And I, I believe that he did it after she had called him, but I’m not sure. But I knew that the main source of their meetings was about her move to New York and her getting a job.

Q: Are you saying, sir, that you forgot when you were asked this question that Vernon Jordan had come on December 19th, just three and a half weeks before, and said that he had met that day, the day that Monica got the subpoena?

PRESIDENT CLINTON: It’s quite possible – it’s a sort of a jumbled answer. It’s quite possible that I had gotten mixed up between whether she had met with him or talked to him on the telephone in those three and a half weeks.

Again, I say, sir, just from the tone of your voice and the way you are asking questions here, it’s obvious that this is the most important thing in the world, and that everybody was focused on all the details at the time. But that’s not the way it worked. I was, I was doing my best to remember.

Now, keep in mind, I don’t know if this is true, but the news reports are that Linda Tripp talked to you, then went and talked to the Jones lawyers, and, you know, that she prepared them for this. Now, maybe – you seem to be criticizing me because they didn’t ask better questions and, as if you didn’t prepare them well enough to sort of set me up or something. I don’t know what’s going on here.

All I can tell you is I didn’t remember all the details of all this. I didn’t remember what – when Vernon talked to me about Monica Lewinsky, whether she talked to him on the telephone or had a meeting. I didn’t remember all those details. I was focused on the fact that Monica went to meet with Vernon after Betty helped him set it up, and had subsequent meetings to talk about her move to New York.

Now, keep in mind at this time, at this time, until this date here when it’s obvious that something funny’s going on here and there’s some sort of a gotcha game at work in this deposition, until this date, I didn’t know that Ms. Lewinsky’s deposition [sic] wasn’t going to be sufficient for her to avoid testifying. I didn’t, you know –

MR. KENDALL: Excuse me, Mr. President, I think –

PRESIDENT CLINTON: So, all these details –

MR. KENDALL: – you mean her affidavit.


Q: You mean her affidavit?

PRESIDENT CLINTON: Excuse me. I’m sorry. Her affidavit. Thank you.

So, I don’t necessarily remember all the details of all these questions you’re asking me, because there was a lot of other things going on, and at the time they were going on, until all this came out, this was not the most important thing in my life. This was just another thing in my life.

Q: But Vernon Jordan met with you, sir, and he reported that he had met with Monica Lewinsky, and the discussion was about the lawsuit, and you didn’t inform, under oath, the Court of that in your deposition ?

A I gave the best answer I could, based on the best memory I had at the time they asked me the question. That’s the only answer I can give you, sir.


Walk Through The Minefield

Q: Well, you’re not telling our grand jurors that because you think the case was a political case or a setup, Mr. President, that that would give you the right to commit perjury or –


Q: – not to tell the full truth?

PRESIDENT CLINTON: No, sir. In the face of their, the Jones lawyers, the people that were questioning me, in the face of their illegal leaks, their constant, unrelenting illegal leaks in a lawsuit that I knew and, by the time this deposition and this discovery started, they knew was a bogus suit on the law and a bogus suit on the facts.

Q: The question is –

PRESIDENT CLINTON: In the face of that, I knew that in the face of their illegal activity, I still had to behave lawfully. But I wanted to be legal without being particularly helpful. I thought that was, that was what I was trying to do. And this is the first – you are the first persons who ever suggested to me that, that I should have been doing their lawyers’ work for them, when they were perfectly free to ask follow-up questions. On one or two occasions, Mr. Bennett invited them to ask follow-up questions.

It now appears to me they didn’t because they were afraid I would give them a truthful answer, and that there had been some communication between you and Ms. Tripp and them, and they were trying to set me up and trick me. And now you seem to be complaining that they didn’t do a good enough job. I did my best, sir, at this time. I did not know what I now know about this. A lot of other things were going on in my life. Did I want this to come cut? No. Was I embarrassed about it? Yes. Did I ask her to lie about it? No. Did I believe there could be a truthful affidavit? Absolutely.

Now, that’s all I know to say about this. I will continue to answer your questions as best I can.

Q: You’re not going back on your earlier statement that you understood you were sworn to tell the truth, the whole truth, and nothing but the truth to the folks at that deposition, are you, Mr. President?

PRESIDENT CLINTON: No, sir, but I think we might as well put this out on the table. You tried to get me to give a broader interpretation to my oath than just my obligation to tell the truth. In other words, you tried to say, even though these people are treating you in an illegal manner in illegally leaking these depositions, you should be a good lawyer for them. And if they don’t have enough sense to write – to ask a question, and even if Mr. Bennett invited them to ask follow-up questions, if they didn’t do it, you should have done all their work for them.

Now, so I will admit this, sir. My goal in this deposition was to be truthful, but not particularly helpful. I did not wish to do the work of the Jones lawyers. I deplored what they were doing. I deplored the innocent people they were tormenting and traumatizing. I deplored their illegal leaking. I deplored the fact that they knew, once they knew our evidence, that this was a bogus lawsuit, and that because of the funding they had from my political enemies, they were putting ahead. I deplored it.

But I was determined to walk through the mine field of this deposition without violating the law, and I believe I did.

Q: You are not saying, are you, Mr. President, in terms of doing the work for the Jones folks, the Jones lawyers, that you could, you could say, as part of your not helping them, “I don’t know” to a particular question, when you really knew, and that it was up to them – even if you really knew the answer, it was up to them to do the follow-up, that you kind of had a one free “I don’t know ….


Q: If I could finish up? I’ve been very patient, Mr. President, in letting you finish.

You didn’t think you had a free shot to say, “I don’t know”, or “I don’t recall”, but when you really did know and you did recall, and it was just up to them, even you weren’t telling the truth, to do a follow-up and to catch you?

PRESIDENT CLINTON: No, sir, I’m not saying that.

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