President’s Video: ‘Inappropriate, Intimate Contact’

These are excerpts from President Clinton’s testimony before the grand jury on Aug. 17, 1998. The questions are from prosecutors. Some readers may find parts of this testimony offensive.

Question: Mr. President, were you physically intimate with Monica Lewinsky?

Answer: Mr. Bittman, I think maybe I can save the--you and the grand jurors a lot of time if I read a statement which I think will make it clear what the nature of my relationship with Miss Lewinsky was, how it related to the testimony I gave, what I was trying to do in that testimony, and I think it will perhaps make it possible for you to ask even more relevant questions, from your point of view. And with your permission, I’d like to read that statement. . . .

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Q: Absolutely. Please, Mr. President.

A: (Reading from statement.) When I was alone with Ms. Lewinsky on certain occasions in early 1996, and once in early 1997, I engaged in conduct that was wrong. These encounters did not consist of sexual intercourse. They did not constitute sexual relations as I understood that term to be defined, at my January 17th, 1998 deposition, but they did involve inappropriate, intimate contact. These inappropriate encounters ended at my insistence in early 1997. I also had occasional telephone conversations with Miss Lewinsky that included inappropriate sexual banter.

I regret that what began as a friendship came to include this conduct, and I take full responsibility for my actions. While I will provide the grand jury whatever other information I can, because of privacy considerations affecting my family, myself, and others, and in an effort to preserve the dignity of the office I hold, this is all I will say about the specifics of these particular matters.

I will try to answer to the best of my ability other questions, including questions about my relationship with Miss Lewinsky, questions about my understanding of the term “sexual relations” as I understood it to be defined at my Jan. 17th, 1998 deposition, and questions concerning alleged subornation of perjury, obstruction of justice, and intimidation of witnesses. . . .

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Q: Was this contact with Ms. Lewinsky, Mr. President--did it involve any sexual contact in any way, shape or form?

A: Mr. Bittman, I said in the statement I would like to stay to the terms of the statement. I think it’s clear what inappropriately intimate is. I have said what it did not include. It did not include sexual intercourse, and I do not believe it included conduct which falls within the definition I was given in the [Paula Corbin] Jones deposition. And I would like to stay with that characterization.

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Q: Let’s, then, move to the definition that was provided to you during your deposition. . . .

A: Yes. I can tell you what my understanding of the definition is if you want me to do it.

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Q: Sure.

A: My understanding of this definition is that it covers contact by the person being deposed with the enumerated areas “if the contact is done with an intent to arouse or gratify.” That’s my understanding of the definition.

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Q: What did you believe the definition to include and exclude? What kinds of activity?

A: I felt the definition included any activity by the person being deposed where the person was the actor and came in contact with those parts of the bodies with the purpose of intent for gratification and excluded any other activity. For example, kissing’s not covered by that, I don’t think.

Defining Sex

A: . . . And I believe that is the definition that ordinary Americans would give it. If you said, “Jane and Harry had a sexual relationship,” and you’re not talking about people being gone into a lawsuit and being given definitions and then a great effort to trick them in some way, but you’re just talking about people in ordinary conversation, I’ll bet the grand jurors, if they were talking about two people they know and said, “They had a sexual relationship,” they meant they were “sleeping” together; they meant they were “having intercourse” together. . . .

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Q: So your definition of sexual relationship is intercourse only; is that correct?

A: No, not necessarily intercourse only, but it would include intercourse. I believe that the common understanding of the term, if you say two people are having a sexual relationship, most people believe that includes intercourse. So if that’s what Ms. Lewinsky thought, then this is a truthful affidavit. I don’t know what was in her mind, but if that’s what she thought, the affidavit is true. . . .

Well, I ask, Mr. President, because your attorney, using the very document, Grand Jury Exhibit 4, WJC-4, represented to Judge Wright that his understanding of the meaning of that affidavit, which you’ve indicated you thought Ms. Lewinsky thought was just intercourse, he says to Judge Wright that it meant absolutely no sex of any kind, in any manner, shape or form.

A: Well, let me say this. I didn’t have any discussion, obviously, at this moment with Mr. Bennett. I’m not even sure I paid much attention to what he was saying. I was--I was ready to get on with my testimony here, and they were having these constant discussions all through the deposition. But that statement, in the present tense, at least, is not inaccurate, if that’s what Mr. Bennett meant. That is, at the time the he said that and for some time before that, that would be a completely accurate statement.

Jones Lawyers’ Strategy

A: And it’s obvious, and I think by your questions you have betrayed that the Jones lawyers’ strategy in this case had nothing to do with uncovering or proving sexual harassment.

By the time this discovery started, they knew they had a bad case on the law, and they knew what our evidence was. They knew they had a lousy case on the facts. And so their strategy, since they were being funded by my political opponents, was to have this dragnet of discovery. They wanted to cover everybody, and they convinced the judge, because she gave them strict orders not to leak, that they should be treated like other plaintiffs in other civil cases and how could they ever know whether there had been any sexual harassment, unless they first knew whether there had been any sex.

And so with that broad mandate limited by time and employment in the federal or state government, they proceeded to cross the country and try to turn up whatever they could; not because they thought it would help their case. By the time they did this discovery, they knew what this deal was in their case, and they knew what was going to happen. And Judge Wright subsequently threw it out. . . .

What they wanted to do, and what they did do, and what they had done by the time I showed up here was to find any negative information they could on me, whether it was true or not, get it in a deposition, and then leak it, even though it was illegal to do so. It happened repeatedly. The judge gave them orders. One of the reasons she was sitting in that deposition was because she was trying to make sure that it didn’t get out of hand. But that was their strategy, and they did a good job of it, and they got away with it. I’ve been subject to quite a lot of illegal leaking. And they had a very determined, deliberate strategy, because their real goal was to hurt me. When they knew they couldn’t win the lawsuit, they thought, well, maybe we can pummel him. Maybe they thought I’d settle. Maybe they just thought they would get some political advantage out of it. But that’s what was going on here.

Now, I’m trying to be honest with you and it hurts me. And I’m trying to tell you the truth about what happened between Ms. Lewinsky and me. But that does not change the fact that the real reason they were zeroing in on anybody was to try to get any person in there, no matter how uninvolved with Paula Jones, no matter how uninvolved with sexual harassment, so they could hurt me politically. That’s what was going on, because by then--by this time, this thing had been going on a long time. They knew what our evidence was, they knew what the law was in the Circuit in which we were bringing this case, and so they just thought they would take a wrecking ball to me and see if they could do some damage. . . .

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Q: And it was your responsibility to answer those questions truthfully, Mr. President.

A: It was. But it was not my responsibility, in the face of their repeated illegal leaking, it was not my responsibility to volunteer a lot of information.

Keeping Affair Private

Q: Did anyone, as far as you knew, know about your embarrassing, inappropriate, intimate relations that you had with Miss Lewinsky?

A: At that time, I was unaware that she had told anyone else about it, but if--if I had known that, I would--it would not have surprised me.

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Q: Had you told anyone?

A: Absolutely not.

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Q: Had you tried, in fact, not to let anyone else know about this relationship?

A: Well, of course.

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Q: What did you do?

A: Well, I never said anything about it, for one thing, and I did what people do when they do the wrong thing. I tried to do it where nobody else was looking.

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Q: Mr. President, if your intent was, as you have earlier testified, you didn’t want anyone to know about this relationship you had with Ms. Lewinsky, why would you feel comfortable giving her gifts in the middle of discovery in the Paula Jones case?

A: Well, sir, for one thing, there was no existing improper relationship at that time. I had, for nearly a year, done my best to be a friend to Ms. Lewinsky, to be a counselor to her, to give her good advice, and to help her. She had, for her part, most of the time, accepted the changed circumstances. She talked to me a lot about her life, her job ambitions, and she continued to give me gifts. And I felt that it was the right thing to do to give her gifts back. I have always given a lot of people gifts; I have always been given gifts. I do not think there is anything improper about a man giving a woman a gift, or a woman giving a man a gift that necessarily connotes an improper relationship. So it didn’t bother me. I wasn’t--you know, this was Dec. 28th. I was--I gave her some gifts. I--I wasn’t worried about it; I thought it was an all right thing to do.

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Q: What about notes and letters? Cards, letters and notes from Miss Lewinsky? After this relationship, this intimate, inappropriate, intimate relationship between you and Miss Lewinsky ended, she continued to send you numerous intimate notes and cards, is that right?

A: Well, they were--some of them were somewhat intimate. I’d say most of them--most of the notes and cards were affectionate, all right, but she had clearly accepted the fact that there could be no contact between us that was in anyway inappropriate. Now, she--she sent cards sometimes that were just funny, even a little bit off color, but they were funny. She liked to send me cards, and I got a lot of those cards. I--several, anyway; I don’t know “a lot.” I got a few.

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Q: She professed her love to you in these cards, after the end of the relationship, didn’t she?

A: Well . . .

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Q: She said she loved you.

A: Sir, the truth is that most of the time, even when she was expressing her feelings for me in affectionate terms, I believe that she had accepted, understood, my decision to stop this inappropriate contact. She knew from the very beginning of our relationship that I was apprehensive about it. And I think that in a way she felt a little freer to be affectionate because she knew that nothing else was going to happen. I can’t explain entirely what was in her mind. But most of these messages were not what you’d call over the top. They weren’t things that if you read them, you would say, “Oh, my goodness, these people are having some sort of sexual affair.”

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Q: My question was: Did she, or did she not, profess her love to you in these cards and letters that she sent to you after the relationship ended?

A: Most of them were signed, “Love”--you know, “Love, Monica.” I don’t know that I would--I don’t believe that in most of these cards and letters, she professed her love, but she might well have. But you know, love can mean different things too, Mr. Bittman. There are a lot of women with whom I have never had any inappropriate conduct, who are friends of mine, who will say from time to time, “I love you.” And I know that they don’t mean anything wrong by that. . . .

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Q: Do you ever remember telling her, Mr. President, that she should not write some of the things that she does in these cards and letters that she sends to you because it reveals--it disclosed this relationship that you had and that she shouldn’t do it?

A: I remember telling her she should be careful what she wrote because a lot of it was clearly inappropriate and would be embarrassing if somebody else read it. . . .

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Q: Embarrassing in that it was revealing of the intimate relationship that you and she had; is that right?

A: I do not know when I said this, so I don’t know whether we did have any sort of inappropriate relationship at the time I said that to her. I don’t remember. But it’s obvious that if she wrote things that she should not have written down and someone else read it, that it would be embarrassing.

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Q: She certainly sent you something like that after the relationship began, didn’t she? And so, therefore, there was, at the time she sent it, something inappropriate going on?

A: Well, my recollection is that she--that maybe because of changed circumstances in her own life, in 1997, after there was no more inappropriate contact, that she sent me more things in the mail, and that there was sort of a disconnect sometimes between what she was saying and the plain facts of our relationship. And I don’t know what caused that, but it may have been dissatisfaction with the rest of her life; I don’t know. You know, she had from the time I first met her talked to me about the rest of her personal life, and it may be that there was some reason for that. It may be that when I did the right thing and made it stick, that in a way she felt a need to cling more closely or try to get closer to me even though she knew nothing improper was happening or was going to happen. I don’t know the answer to that.

Meeting With Currie

Q: Let me ask you about the meeting you had with Betty Currie at the White House on Sunday, Jan. 18, this year; the day after your deposition. First of all, . . . you never allowed her, did you, to watch whatever--whatever intimate activity you did with Miss Lewinsky, did you?

A: No, sir, not to my knowledge.

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Q: And as far as you know, she couldn’t hear anything, either, is that right?

A: In--there were a couple of times when Monica was there when I asked Betty to be places where she could hear because Monica was upset and I--this was after there was--all the inappropriate contact had been terminated, but . . .

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Q: I’m talking about the times when you actually had the intimate contact.

She was--I believe that--well first of all, on that one occasion in 1997, I do not know whether Betty was in the White House after the radio address in the Oval Office complex. I believe she probably was, but I am not sure. But I am certain that someone was there. Always someone was there. In 1996, I think most of the times that Ms. Lewinsky was there, there may not have been anybody around except maybe coming in and out, but not permanently. So I--that’s correct--I never--I didn’t try to involve Betty in that in any way.

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Q: Well, not only did you not try to involve her, you specifically tried to exclude her and everyone else, isn’t that right?

A: Well, yes, I’ve never--I think it’s almost humorous, sir; I’d have to be an exhibitionist not to have tried to exclude everyone else.

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Q: So if Ms. Currie testified that you approached her on the 18th, where you spoke with her and you said you were always there when she was there, she wasn’t, was she; that is, Mrs. Currie?

A: She was always there in the White House, and I was concerned--let me back for a second.

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Q: What about the radio address, Mr. President?

A: Let me back up a second, Mr. Bittman.

I knew about the radio address. I was sick after it was over.

And I was pleased at that time it had been nearly a year since any inappropriate contact had occurred with Ms. Lewinsky. I promised myself it wasn’t going to happen again. The facts are complicated about what did happen and how it happened, but, nonetheless, I am responsible for it. On that night, she didn’t.

I was more concerned about the times after that when Ms. Lewinsky was upset, and I wanted to establish at least that I had not--because these questions were--some of them were off the wall; some of them were way out of line, I thought. I think Ms. Currie would also testify that I explicitly told her, once I realized that you were involved in the Jones case--you, the Office of Independent Counsel--and that she might have to be called as a witness, that she should just go in there and tell the truth, tell what she knew, and be perfectly truthful. So I was not trying to get Betty Currie to say something that was untruthful. I was trying to get as much information as quickly as I could.

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Q: What information were you trying to get from her when you said, “I was never alone with her, right.”

A: I don’t remember exactly what I did say with her. That’s what you say I said.

What Does ‘Is’ Mean?

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 the Paula Jones deposition, “Counsel is fully aware . . . that Ms. Lewinsky has filed--has an affidavit, which they were in possession of, saying that there is absolutely no sex of any kind, any manner, shape or form with President Clinton.” That statement is made by your attorney in front of Judge Susan Webber Wright; correct?

A: That’s correct.

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Q: That statement is a completely false statement, whether or not Mr. Bennett knew your relationship with Ms. Lewinsky, the statement that there is no sex of any kind, in any manner, shape or form with President Clinton was an utterly false statement; is that correct?

A: It depends upon what the meaning of the word “is” is. If “is” means is and never has been, that’s 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 events, 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 am 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 that’s imputable to me. I don’t know that I was even paying that much attention to it.

Jordan Conversation

Q: Mr. President, 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 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 the--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 that it was on that night that that conversation happened?

A: I--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.

. . . Again, I say, sir, just from the tone of your voice and the way you’re 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. . . .

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. . . .

I think what they were trying to do to her and all these other people, who knew nothing about sexual harassment, was outrageous--just so they could hurt me politically. . . .

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Q: Well, you’re not telling our grand jurors that if you think the case was a political case or a set-up, Mr. President, that that would give you the right to commit perjury?

A: No, sir.

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Q: . . . or not to tell the whole truth?

A: 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 that 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 . . .

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Q: The question . . .

A: 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--you’re the first person who’s ever suggested to me that I should have been doing their lawyer’s 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 [Linda] 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 come out? 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. . . .

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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?

A: 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 and illegally leaking these deposition, you should be a good lawyer for them. And if they don’t have enough sense to write--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 minefield of this deposition without violating the law, and I believe I did.

Embarrassment and Pain

A: I’ve been pretty tough, so let me say something sympathetic.

All of you are intelligent people. You’ve worked hard on this, you’ve worked for a long time, you’ve gotten all the facts, you’ve seen a lot of evidence that I haven’t seen.

And it’s an embarrassing and personally painful thing, the truth about my relationship with Ms. Lewinsky. So the natural assumption is that while all this was going on, I must have been focused on nothing but this, therefore, I must remember everything about it in the sequence and form in which it occurred. All I can tell you is, I was concerned about it, I was glad she saw a lawyer, I was glad she was doing an affidavit. But there were a lot of other things going on, and I don’t necessarily remember it all. And I don’t know if I can convince you of that, but I tried to be honest with you about my mind set about this deposition, and I’m just trying to explain that I don’t have the memory that you assume that I should about some of these things.

Questions From Jurors

Q: Mr. President, these next series of questions are from the grand jurors. And let me tell you that the grand jurors want you to be more specific about the inappropriate conduct.

The first question was--one of the grand jurors has said that: You referred to what you did with Ms. Lewinsky as inappropriate contact. What do you mean by that?

A: I mean just what I said. But I’d like to ask the grand jury, because I think I have been quite specific, and I think I’ve been willing to answer some specific questions that I haven’t been asked yet, but I do not want to discuss something that is intensely painful to me. This has been tough enough already on me and on my family, although I take responsibility for it. I have no one to blame but myself.

What I meant was, and what they can infer that I meant was that I did things that were--when I was alone with her that were inappropriate and wrong, but that they did not include any activity that was within the definition of “sexual relations” that I was given by Judge Wright in the deposition. I said that I did not do those things that were in that--within that definition, and I testified truthfully to that. And that’s all I can say about it.

Now, you know, if there’s any doubt on the part of the grand jurors about whether I believe some kind of activity falls within that definition or outside that definition, I’d be happy to try to answer that.

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Q: Well, I have a question regarding your definition then, and my question is: Is oral sex performed on you within that definition, as you understood the definition in the Jones--

A: As I understood it, it was not; no.

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Q: The grand jurors would like to know upon what basis, what legal basis you’re declining to answer more specific questions about this. . . .

A: I am not trying to evade my legal obligations or my willingness to help the grand jury achieve their legal obligations. As I understand it, you want to examine whether you believe I told the truth in my deposition, whether I asked Ms. Lewinsky not to tell the truth, and whether I did anything else with evidence or in any other way--amounted to an obstruction of justice or a subornation of perjury. And I am prepared to answer all questions that the grand jury needs to draw that conclusion.

Now, respectfully, I believe the grand jurors can I ask me if I believe just like that grand juror did--could ask me, “Do you believe that this conduct falls within that definition?” And if it does, then you are free to conclude that my testimony is that I didn’t do that. And I believe that you can achieve that without requiring me to say and do things that I don’t think are necessary and that I think, frankly, go too far in trying to criminalize my private life.

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Q: If a person touched another person--if you touched another person on the breast, would that be in your view, and was it within your view, when you took the deposition, within the definition of “sexual relations”?

A: If the person being deposed, in this case, me, directly touched the breast of another person with the purpose to arouse or gratify, under that definition, that would be included.

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Q: Only directly, sir, or would it be directly or through clothing?

A: Well, I would--I think the common sense definition would be directly. That’s how I would infer what it means.

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Q: If the person being deposed kissed the breast of another person, would that be in the definition of sexual relations as you understood it when you were under oath in the Jones case?

A: Yes, that would constitute contact. I think that would, if it were direct contact, I believe it would. I--maybe I should read it again, just to make sure. (Reviews document.) And if this basically says that if there was any direct contact with an intent to arouse or gratify, if that was the intent of the contact, then that would fall within the definition. That’s correct.

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Q: So, touching, in your view, then and now--the person being deposed touching or kissing the breast of another person would fall within the definition?

A: That’s correct, sir.

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Q: And you testified that you didn’t have sexual relations with Monica Lewinsky in the Jones deposition, under that definition, correct?

A: That’s correct, sir.

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Q: If the person being deposed touched the genitalia of another person, would that be in--with the intent to arouse the sexual desire--arouse or gratify, as defined in definition one, would that be, under your understanding then and now, sexual relations?

A: Yes, sir.

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Q: Yes, it would?

A: Yes, it would. If you had a direct contact with any of these places in the body, if you had direct contact with intent to arouse or gratify, that would fall within the definition.

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Q: So you didn’t do any of those three things with Monica Lewinsky.

A: You are free to infer that my testimony is that I did not have sexual relations as I understood this term to be defined.

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Q: Including touching her breast, kissing her breast or touching her genitalia.

A: That’s correct. . . .

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Q: As you understood the definition then and as you understood it now, would it include sticking an object into the genitalia of another person in order to arouse or gratify the sexual desire of any person? Would it constitute, in other words, contact with the genitalia if an object . . .

A: I don’t know the answer to that. I suppose you could argue that since section two, paragraph two, was eliminated, and paragraph two actually dealt with the object issue, that perhaps whoever wrote this didn’t intend for paragraph one to cover an object and basically meant direct contact. So, if I were asked--I’ve not been asked this question before, but I guess that’s the way I would read it.

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Q: That it would not be covered, that activity would not be covered.

A: That’s right. . . .

This is an unusual question, but it’s a slippery slope. I have tried to deal with some very delicate areas here in the one case, and I have given you a very forthright answer about what I thought that was not within here. All I can tell you is whatever I thought was covered--and I thought about this carefully.

And let me just point out that this was uncomfortable for me. I had to acknowledge because of this definition, that under this definition I had actually had sexual relations once with Gennifer Flowers, a person who had spread all kinds of ridiculous and dishonest, exaggerated stories about me for money. And I knew when I did that, it would be leaked--it was--and I was embarrassed, but I did it.

So I tried to read this carefully. I can tell you what I thought it covered, and I can tell you that I do not believe I did anything that I thought was covered by this.

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Q: As I understand your testimony, Mr. President, touching somebody’s breasts with the intent to arouse or gratify sexual desire in any person is covered, kissing the breast is covered, touching the genitalia is covered, correct? . . .

A: I believe it is, yes, sir.

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Q: Oral sex in your view, is not covered, correct?

A: If performed on the deponent.

Who Was Told?

Q: Do you recall denying any sexual relationship with Monica Lewinsky to the following people: Harry Thomason, Erskine Bowles, Harold Ickes, Mr. Podesta, Mr. Blumenthal, Mr. Jordan, Ms. Betty Currie? Do you recall denying any sexual relationship with Monica Lewinsky to those individuals?

A: I recall telling a number of those people that I didn’t have--either I didn’t have an affair with Monica Lewinsky or didn’t have sex with her. And I believe, sir, that--well, you’ll have to ask them what they thought--but I was using those terms in the normal way people use them. You’ll have to ask them what they thought I was saying.

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Q: If they testified that you denied sexual relations or a relationship with Monica Lewinsky, or if they’ve told us that you denied that, do you have any reason to doubt--in the days after the story broke--do you have any reason to doubt them?

A: No, the--let me say this: It’s no secret to anybody that I hoped that this relationship would never become public. It’s a matter of fact that it had been many, many months since there had been anything improper about it in terms of improper contact. I would . . .

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Q: Did you deny it to them or not, Mr. President?

A: Let me finish. So what--I did not want to mislead my friends, but I wanted to find language where I could say that. I also, frankly, did not want to turn any of them into witnesses because--and sure enough, they all became witnesses. And so . . .

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Q: Well you knew they might be witnesses, didn’t you?

A: And so I said to them things that were true about this relationship, that I used--in the language I used; I said, “There’s nothing going on between us.” That was true. I said, “I have not had sex with her”--as I define it. That was true.

And did I hope that I would never have to be here on this day giving this testimony? Of course. But I also didn’t want to do anything to complicate this matter further. So I said things that were true. They may have been misleading, and if they were, I have to take responsibility for it, and I’m sorry.

*

Q: They may have been misleading, sir. And you knew, though, after January 21st, when the Post article broke and said that Judge Starr was looking into this, you knew that they might be witnesses, you knew that they might be called into a grand jury, didn’t you?

A: I think I was quite careful what I said after that. I may have said something to all these people to that effect, but I--I also--whenever anybody asked me any details, I said, “Look, I don’t want you to be a witness or I turn you into a witness or give you information that could get you in trouble.” I just wouldn’t talk. I by and large didn’t talk to people about this. . . .

*

Q: Yet all of these people--let’s leave out Mrs. Currie for a minute--Vernon Jordan, Sid Blumenthal, John Podesta, Harold Ickes, Erskine Bowles, Harry Thomason--after the story broke, after Judge Starr’s involvement was known on January 21st, have said that you denied a sexual relationship with them. Are you denying that?

A: No.

*

Q: And you’ve told us . . .

A: I am just telling you what I meant by it. I told you what I meant by it when they started this deposition.

*

Q: You’ve told us now that you were being careful but that it might have been misleading, is that correct?

A: It might have been. Since we have seen this four-year, $40-million investigation come down to parsing the definition of “sex,” I think it might have been. I don’t think at the time that I thought that’s what this was going to be about.

In fact--and if you remember the headlines at the time . . . all the headlines were and all the people who talked about this, including a lot who had been quite sympathetic to your operation, said, “Well, this is not really a story about sex,” or, “This is a story about subornation of perjury and these talking points and all this other stuff.”

So what I was trying to do was to give them something that would be true even if misleading, in the context of this deposition, and keep them out of trouble and deal with what I thought was the almost ludicrous suggestion that I had urged someone to lie or try to suborn perjury in other ways.

Did Monica Lie?

Q: . . . If Monica Lewinsky says that while you were in the Oval Office area you touched her breast, would she be lying? . . .

A: That is not my recollection. My recollection is that I did not have sexual relations with Ms. Lewinsky, and I am staying on my former statement about that. My statement is that I did not have sexual relations as defined by that.

*

Q: If she says that you kissed her breast, would she be lying?

A: I am going to revert to my former statement.

*

Q: OK. If Monica Lewinsky says that while you were in the Oval Office area, you touched her genitalia, would she be lying? . . .

A: Then I will revert to my statement on that.

*

Q: If Monica Lewinsky says that you used a cigar as a sexual aid with her in the Oval Office area, would she be lying? Yes, no, or won’t answer?

A: I will revert to my former statement.

*

Q: If Monica Lewinsky says that you had phone sex with her, would she be lying?

A: Well, that is, at least in general terms, I think, is covered by my statement. I addressed that in my statement, and that--I don’t believe it . . .

*

Q: Let me read it--let me define phone sex for purposes of my question. Phone sex occurs when a party to a phone conversation masturbates while the other party is talking in a sexually explicit manner. And the question is, if Monica Lewinsky says that you had phone sex with her, would she be lying?

A: I think that is covered by my statement.

Issue of Gifts

Q: I want to go back briefly to the December 28th conversation with Ms. Lewinsky. I believe you testified to the effect that she asked you, “What if they ask me about gifts you gave me?” My question to you is, after that statement by her, did you ever have a conversation with Betty Currie about gifts or picking something up from Monica Lewinsky?

A: I don’t believe I did, sir, no.

*

Q: You never told her anything to this effect, that “Monica has something to give you?”

A: No, sir. . . .

*

Q: And so you had no knowledge at the time that Betty Currie went and picked up--your secretary went and picked up from Monica Lewinsky, items that were called for by the Jones subpoena, and hid them under her bed? You had no knowledge that anything remotely like that was going to happen?

A: I did not. I did not know she had those items, I believe, until that was made public.

*

Q: And you agree with me that that would be a very wrong thing to do, to hide evidence in a civil case or any case? Isn’t that true?

A: Yes. I don’t know that Ms. Currie knew that that’s what she had at all. But . . .

*

Q: I am not that saying she did. I am just saying . . .

A: If Monica Lewinsky did that after they had been subpoenaed, and she knew what she was doing, she should not have done that.

*

Q: And if . . .

A: And indeed, I myself told her, “If they ask you for gifts, you have to give them what you have.” And I don’t understand if in fact she was worried about this, why she was so worried about it. It was no big deal.

Phone Call

Q: I want to talk about a December 17th phone conversation you had with Monica Lewinsky at approximately 2 a.m. Do you recall making that conversation and . . . telling her that she was on the witness list and that it broke your heart that she was on the witness list?

A: No, sir, I don’t. But it is quite possible that that happened because if you remember earlier in this meeting, you asked me some questions about what I had said to Monica about testimony and affidavits, and I was struggling to try to remember whether this happened in a meeting or a phone call. . . .

*

Q: And in that conversation or in any conversation in which you informed her she was on the witness list, did you tell her, “You know, you can always say that you were coming to see Betty or bringing me letters?” Did you tell her anything like that?

A: I don’t remember. She was coming to see Betty. I can tell this: I absolutely never asked her to lie. . . .

*

Q: You would agree with me, if you did say something like that to her, to urge her to say that to the Jones people, that that would be part of an effort to mislead the Jones people, no matter how evil they are and corrupt?

A: I didn’t say they were evil. I said that what they were doing here was wrong, and it was.

*

Q: Wouldn’t that be misleading?

A: Well, again, you’re trying to get me to characterize something that I don’t know if I said or not, without knowing whether the--whether the context is complete or not. So I would have to know what was the context, what were all the surrounding facts. I can tell you this: I never asked Ms. Lewinsky to lie. The first time she raised with me the possibility that she might be a witness or I told her--you suggested a possibility in this December 17th time frame--I told her she had to get a lawyer. And I never asked her to lie. . . .

*

Q: If Monica Lewinsky has stated in her affidavit that she didn’t have a sexual relationship with you is in fact a lie, I take it you disagree with that?

A: No. I told you before what I thought the issue was there. I think the issue is how do you define “sexual relationship.” And there was no definition imposed on her at the time she executed the affidavit. Therefore, she was free to give it any reasonable meaning. And I . . .

*

Q: And if she says she was lying under the common sense, ordinary meaning that you talked about earlier, Mr. President, that most Americans would have, if she says sexual relationship--”Saying I didn’t have one was a lie because I had oral sex with the president,” I take it you would disagree with that? . . .

A: Now we’re back to where we started and I have to invoke my statement. But let me just say one thing. I’ve read a lot--and obviously, I don’t know whether any of it’s accurate--about what she said and what is--what purports to be on these tapes. And this thing--and I’ve searched my own memory.

This reminds me to some extent of the hearings when Clarence Thomas and Anita Hill were both testifying under oath. Now, in some rational way, they could not have both been telling the truth since they had directly different accounts of a shared set of facts. Fortunately, or maybe you think unfortunately, there was no special prosecutor to try to go after one or the other of them, to take sides and try to prove one was a liar, and so Judge Thomas was able to go on and serve on the Supreme Court. But what I learned from that--I can tell you that I was a citizen out there just listening, and when I heard both of them testify, what I believed after it was over, I believed that they both thought they were telling the truth. This is--you’re dealing with in some ways the most mysterious area of human life. I’m doing the best I can to give you honest answers. . . .

And, you know, those people both testified under oath, so if there had been a special prosecutor, one of them could have gone after Anita Hill, another could have gone after Clarence Thomas. I thank God there was no such thing then because I don’t believe that it was a proper thing. And I think they both thought they were telling the truth.

So maybe Ms. Lewinsky believes she’s telling the truth. And I’m glad she got her mother and herself out of trouble. I’m glad you gave her that sweeping immunity. I’m glad for the whole thing. I--it breaks my heart that she was ever involved in this.

The Dress

Q: Mr. President, if there is a semen stain belonging to you on a dress of Ms. Lewinsky’s, how would you explain that?

A: Well, Mr. Bittman, I, I don’t--first of all, when you asked me for a blood test, I gave you one promptly. You came over here and got it. That’s--we met that night and talked. So, that’s a question you already know the answer to. Not if, but you know whether. . . .

And the main thing I can tell you is that doesn’t affect the opening statement I made. The opening statement I made is that I had inappropriate intimate contact. I take full responsibility for it. It wasn’t her fault; it was mine. I do not believe that I violated the definition of sexual relations I was given by directly touching those parts of her body with the intent to arouse or gratify. And that’s all I have to say. I think, for the rest, you know, you know what the evidence is and it doesn’t affect that statement.

*

Q: Is it possible or impossible that your semen is on a dress belonging to Ms. Lewinsky?

A: I have nothing to add to my statement about it, sir. You, you know whether--you know what the facts are. There’s no point in a hypothetical.

*

Q: Don’t you know what the facts are also, Mr. President?

A: I have nothing to add to my statement, sir.

Request for Understanding

A: . . . I would say to the grand jury, put yourself in my position. This is not a typical grand jury testimony. I, I have to assume a report is going to Congress. There’s a videotape being made of this, allegedly because only one member of the grand jury is absent. This is highly unusual. And, in addition to that, I have sustained a breathtaking number of leaks of grand jury proceedings.

And, so, I think I am right to answer all the questions about perjury, but not to say things which will be forever in the historic annals of the United States because of this unprecedented videotape and may be leaked at any time. I just think it’s a mistake.

And, so, I’m doing my best to cooperate, with the grand jury and still protect myself, my family, and my office.

*

Q: Well, the grand jury would like to know, Mr. President, why it is that you think that oral sex performed on you does not fall within the definition of sexual relations as used in your deposition.

A: Because that is--if the deponent is the person who has oral sex performed on him, then the contact is with--not with anything on that list, but with the lips of another person. It seems to be self-evident that that’s what it is. And I thought it was curious.

Let me remind you, sir, I read this carefully. And I thought about it. I thought about what “contact” meant, thought about what “intent to arouse or gratify” meant. And I had to admit under this definition that I’d actually had sexual relations with Gennifer Flowers. Now, I would rather have taken a whipping than done that, after all the trouble I’d been through with Gennifer Flowers, and the money I knew that she had made for the story she told about this alleged 12-year affair, which we had done a great deal to disprove. So, I didn’t like any of this. But I had done my best to deal with it and the--that’s what I thought. And I think that’s what most people would think, reading that.

Question of Sex

Q: Would you have been prepared, if asked by the Jones lawyers, would you have been prepared to answer a question directly asked about oral sex performed on you by Monica Lewinsky?

A: If the judge had required me to answer it, of course, I would have answered it. And I would have answered it truthfully. . . .

And did I want, if I could, to avoid talking about Monica Lewinsky? Yes, I’d give anything in the world not to be here talking about it. I’d be giving--I’d give anything in the world not to have to admit what I’ve had to admit today. . . .

I haven’t said this all day long, but I would like to say it now.

Most of my time and energy in the last 5 1/2 years have been devoted to my job. Now, during that 5 1/2 years, I have also had to contend with things no previous president has ever had to contend with: a lawsuit that was dismissed for lack of legal merit, but that cost me a fortune and was designed to embarrass me; this independent counsel inquiry, which has gone on a very long time and cost a great deal of money, and about which serious questions have been raised; and a number of other things.

And, during this whole time, I have tried as best I could to keep my mind on the job the American people gave me. . . .