Presidential crisis: `I think you go too far in trying to criminalise my private life'

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The Independent Online
This is the edited text of President Bill Clinton's testimony on 17 August to the grand jury investigating his relationship with Monica Lewinsky

Q Mr President, would you raise your right hand, please? Do you solemnly swear that the testimony you're about to give in this matter will be the truth, the whole truth and nothing but the truth, so help you God?

A I do.

Q Good afternoon, Mr President.

A Good afternoon.

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

A William Jefferson Clinton.

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

A I do.

Q My name is Robert Bittman. I'm an attorney with the Office of Independent Counsel.

Mr President, we are first going to turn to some of the details of your relationship with Monica Lewinsky that follow on your deposition that you provided in the Paula Jones case as was referenced on January 17, 1998.

The questions are uncomfortable and I apologize for that in advance. I'll try to be as brief and direct as possible.

Mr President, were you physically intimate with Monica Lewinsky?

A 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 Ms. 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.

A And with your permission, I'd like to read that statement.

Q Absolutely. Please, Mr President.

A 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 Ms. 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 Ms. Lewinsky, questions about my understanding of the term of sexual relations, as I understood it to be defined at my January 17th, 1998, deposition, and questions concerning alleged subordination of perjury, obstruction of justice and intimidation of witnesses.

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

A I said in this 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 did not believe that it included conduct which falls within the definition I was given in the Jones deposition. And I would like to stay with that characterization.

Q Did you understand the definition to be limited to sexual activity?

A Yes, I understood the definition to be limited to physical contact with those areas of the body with the specific intent to arouse or gratify. That's what I understood it to be.

Q What specific acts did the definition include, as you understood the definition on January 17th, 1998?

A Any contact with the areas that are mentioned, sir. If you contacted those parts of the body with an intent to arouse or gratify, that is covered.

Q So if I can be clear, Mr President, is it - was it your understanding back in January that definition, now marked as Grand Jury Exhibit 2, only included consensual sexual activity?

A My understanding - let me go back and say, my understanding - I'll tell you what it did include. My understanding was, when I was giving it to you, was that what was covered in those first two lines was any direct contact by the person being deposed with those parts of another person's body if the contact was done with an intent to arouse or gratify. That's what I believed it meant. That's what I believed it meant then [audio gap]; that's what I believe it means today.

Q Did you talk with Ms. Lewinsky about what she meant to write in her affidavit?

A I didn't talk to her about her definition. I did not know what was in this affidavit before it was filled out, specifically. I did not know what words was used - were used specifically before it was filled out or what meaning she gave to them.

But I'm just telling you that it's certainly true what she says here, that we didn't have - there was no employment or benefit in exchange. There was nothing having anything to do with sexual harassment.

Q And if she defined sexual relationship in the way I think most Americans do, meaning intercourse, then she told the truth.

A And that depends on what was in her mind. I don't know what is her mind. You'll have to ask her that.

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 - 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.

Q What else would sexual relationship include besides intercourse?

A Well, that - I think - let me answer what I said before. I think most people when they use that term include sexual relationships and what other - whatever other sexual contact is involved in a particular relationship. But they think it includes intercourse as well.

Q Judge Wright had ruled that the attorneys in the Jones case were permitted to ask you certain questions.

A She certainly did, and they asked them, and I did my best to answer them. I'm just trying to tell you what my state of mind was.

Q Was it 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.

Q Let me ask you, Mr President, you indicate in your statement that you were alone with Ms. Lewinsky. Is that right?

A Yes, sir.

Q How many times were you alone with Ms. Lewinsky?

A Let me begin with the correct answer - I don't know for sure. But if you would like me to give an educated guess, I will do that. But I do not know for sure. And I will tell you what I think based on what I remember. But I can't be held to a specific time because I don't have records of all of them.

Q How many times do you think?

A Well, there are two different periods here. There is the period when she worked in the White House until April of `96. And then there's the period when she came back to visit me from February `97 until late December `97.

Q So, if I can summarize your testimony, approximately five times you saw her before she left the White House, and approximately nine times after she left the employment of the White House.

A I don't - there were several times in `97. I told you that I've looked at my calendar and I can tell you what I think the outer limits are. I would think that would sound about right.

Q And you also gave her Christmas gifts - is that not correct, Mr President?

A Yes, that is correct. They were Christmas gifts and they were going- away gifts. She was moving to New York, taking a new job, starting a new life and I gave her some gifts.

Q Did anyone, as far as you knew, know about your embarrassing, inappropriate, intimate relationship that you had with Ms. 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.

Q Had you told anyone?

A Absolutely not.

Q Did you tell her in the conversation about her being subpoenaed - she was upset about it. You acknowledged that. I'm sorry, you have to respond for the record, yes or no. Do you agree that she was upset about being subpoenaed?

A Oh, yes, sir, she was upset. She - well, she - we -she didn't - we didn't talk about the subpoena. But she was upset. She said, "I don't want to testify. I know nothing about this. I certainly know nothing about sexual harassment. Why do they want me to testify?"

Q Well, did she tell you, Mr President, that the subpoena specifically called for a hat pin that you had produced, or that you had given her?

A I don't remember that. I remember, sir - I've told you what I remember. It doesn't mean that my memory is accurate. A lot of things have happened in the last several months. A lot of things were happening then.

But my memory is she asked me a general question about gifts. And my memory is she asked me in the hypothetical. So it's possible that I had a conversation with her before she got a subpoena. Or it's possible she didn't want to tell me that was part of the subpoena. I don't know.

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 Miss 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 Miss Lewinsky, to be a counselor to her, to give her good advice and to help her.

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 December 28th. I was - I gave her some gifts. I wasn't worried about it. I thought it was an all right thing to do.

Q What about notes and letters? Cards, letters and notes to 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 any way inappropriate.

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.

Q Specifically, Mr President, do you remember a card she sent you after she saw the movie "Titanic" in which she said that she reminisced or dreamed about that the romantic feelings that occurred in the movie and how that reminded her of you two. Do you remember that?

A No, sir. But she could have said it. Just because I don't remember doesn't mean it wasn't there.

Q When you testified in the Paula Jones case - this was only 2 weeks after you had given her these six gifts - you were asked at page 75 of the deposition, lines 2 through 5: "Well, have you ever given any gifts to Monica Lewinsky?"

And you answered: "I don't recall." And you are correct when you point out that you actually asked them to [off-mike] - do you know that they were?

A Yes, I think what I meant there is I don't recall what they were, not that I don't recall whether I had given them.

And then, if you see, they did give me the specifics, and I gave them quite a good explanation here. I remember very clearly what the facts were about the black dog. And I said that I could have given her a hat pin and a Walt Whitman book, but I did not remember giving her a gold broach, which was true. They didn't ask me about the Christmas gifts. It was obvious to me by this point in the definition - in this deposition that they had - these people had access to a lot of information from somewhere. And I presume it came from Linda Tripp.

Q Let me ask you about the meeting you had with Betty Currie at the White House on Sunday, January 18, this year, the day after your deposition. First of all, you didn't - Mrs. Currie, your secretary of six or seven years, you never allowed her, did you, to watch whatever - whatever intimate activity you did with Ms. Lewinsky, did you?

A No, sir, not to my knowledge.

Q And as far as you know, she couldn't hear anything either? Is that right?

A 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...

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.

Q If Ms. Currie testified to that - that she says you told her, "I was never alone with her, right?"

A Well, I was never alone with her...

Q Did you not say that, Mr President?

A Mr Bittman, just a minute. "I was never alone with her, right?" might be a question. And what I might have meant by that is, "In the Oval Office complex."


Q Mr President,The statement of your attorney, Mr Bennett, at the Paula Jones deposition that there was absolutely no sex of any kind in any manner, shape or form with President Clinton. That statement was made by your attorney in front of Judge Susan Webber Wright.

A That's correct.

Q Your - 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?

A It depends upon what the meaning of the word is means. 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 - I'd like to testify again - this is - it 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.

Q You're the president of the United States, and your attorney counseled the United States District Court judge that there's no sex of any kind or any way, shape or form whatsoever. And you feel no obligation to do anything about that at that deposition, Mr President?

A I had 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, someone had asked me on that day, are you having any kind of sexual relations with Ms. Lewinsky - that is ask me a question in the present tense - I would have said no. And it would have been completely true.

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

A Yes, sir. We've been friends probably 20 years, maybe more.

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, would you have any reason to doubt it?

A 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 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 - night at the White House to discuss it, again, you'd have no reason to doubt him, is that correct?

A Well, I believe I've already testified about that here today. That I had a lots of conversations with Vernon. I am 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, I 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's 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 had been involved in a sexual relationship with Monica Lewinsky, didn't he?

A I do not remember exactly what the nature of the conversation was. I do remember that I told him - excuse me - 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 most 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 In fact, she was very distraught about the subpoena, according to Mr Jordan, wasn't she?

A Well, he said she was upset about it. I remember that - I don't remember any - at any time when he said 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?

A 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?

A I recall him saying he thought that she was upset with - somewhat fixated on me. But 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.

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. Here's the testimony, sir: "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 the case?" Answer: "I don't think so."

Now this deposition was taken just three 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?

A 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.

Several of my answers are somewhat jumbled. But this is an honest attempt here - if you read both these answers, it's obvious they're 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 Mr President, 3.5 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 3.5 weeks later?

A 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 - I invited them on more than one occasion to ask follow-up questions.

Now, they had 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.

Q Can you tell the grand jury what is tricky about the question? Did anyone other than your attorneys ever tell you...

A No, there is nothing. I'm just telling you. I have explained, and I will now explain for the third time, sir.

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

A I took the oath here.

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

A No. I do have a good memory. At least I have had a good memory in my life. 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 a president's life, compounded by the pressure of your four-year inquiry, and all the other things that have happened.

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

A No.

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, you didn't reveal that to the court.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 she had been talking with Vernon Jordan about the case, about the affidavit from the lawyer, the subpoena?

A 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?"

Q Are you saying, sir, that you forgot when you were asked this question that Vernon Jordan had come on December 19th, just 3 weeks before, and said that he'd met that day, the day that Monica got the subpoena?

A It's quite - this is 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 3 weeks.

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 was. I felt very strongly that Ms. Lewinsky and everybody else that didn't know anything about Paula Jones and anything about sexual harassment, that she and others were themselves being harassed for political purposes in the hope of getting damaging information that the Jones' lawyers could unlawfully leak.

Now, I believed then, I believe today that she could execute an affidavit which, under reasonable circumstances - with fair-minded, nonpolitically oriented people - would result in her being relieved of the burden to be put through the kind of testimony that thanks to Linda Tripp's work with you and with the Jones' lawyers she would have been put through.

Q Well, you're not telling our grand jurors that you think the case was a political case for a setup, Mr President, that that would give you the right to commit perjury...

A No, sir. 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 that this deposition and this discovery started, they knew - was a bogus suit on the law and a bogus suit on the facts.

Q I want to talk to you for a bit, Mr President, about the incident that happened at the northwest gate of the White House on December 5th. Sorry, December 6th, 1997. If you'll give me just a moment.

That was a - let me ask you first, in early 19 - in early December 1997, the Paula Jones case was pending, correct?

A Yes, sir.

Q The witness list came out on December 5th of 1997 with Monica Lewinsky's name on it. Mr President, when did you find out that Monica's name was on that witness list?

A I believe that I found out late in the afternoon on the 6th. That's what I believe.

I've tried to remember with great precision, and because I thought you would ask me about this day, I tried to remember the logical question, which is whether I knew it on the 6th, and if so, at what time. I don't - I had a meeting in the late afternoon on the 5th - on the 6th. Excuse me, on the 6th. And I believe that's when I learned about it.

Q Now, on the morning of the 6th, Monica Lewinsky came to the northwest gate and found out that you were being visited by Eleanor Mondale at the time and had an extremely angry reaction. You know that, sir, don't you?

A I have - I have - I know that Monica Lewinsky came to the gate on the 6th, and apparently directly called in and wanted to see me and couldn't, and was angry about it.

A I know that.

Q And she expressed that anger to Betty Currie over the telephone, isn't that correct, sir?

A That - Betty told me that.

Q And she then later expressed her anger to you in one of her telephone conversations with Betty Currie, is that correct?

A You mean, did I talk to her on the phone?

Q Monica Lewinsky that day, before she came in to visit in the White House.

A Mr Wisenberg, I remember that she came in to visit that day. I remember that she was upset. I don't recall whether I talked to her on the phone before she came in to visit, but I may well have. I'm not denying that I did. I just don't recall that.

Q And Mrs. Currie and yourself were very irate that Ms. Lewinsky had overheard that you were in the Oval Office with a visitor on that day - isn't that correct, that you and Mrs. Currie were very irate about that?

A Well, I don't remember all that. What I remember is that she was very - Monica was very upset. She got upset from time to time. And - and I was, you know - I couldn't see her. I had -I was doing, as I remember - I had some other work to do that morning, and she had just sort of showed up and wanted to be let in and wanted to come in at a certain time. And she wanted everything to be that way. And we couldn't see her.

Q Now, I did arrange to see her later that day. And I was upset about her conduct.

A I'm not sure I knew or focused on, at that moment, exactly the question you asked. I remember I was - I thought her conduct was inappropriate that day.

Q I want to go back, and I want to take them one at a time.

A No. 1, did you find out at some point during that day that Monica had overheard from somebody in the Secret Service that you were meeting with Ms. Mondale and that Monica got very irate about that? I knew that at some point. I don't know whether I found out that, that day. I knew that they - I knew that somehow she knew that among - that - that Eleanor Mondale was in to see us that day. I knew that. I don't know that I knew how she knew that on that day. I don't remember that.

Q Pardon me. That leads into my second question, which is, weren't you irate at the Secret Service precisely because they had revealed this information to Ms. Lewinsky on that very day - so irate that you told several people - or at least one person - that somebody should be fired over this, on that very day?

A I don't remember whether it happened on that very day. But let me tell you that the uniformed Secret Service - if that is in fact what happened, and I - we'll stipulate that that is. But no one should be telling anybody, not anybody - not a member of my staff -who the president is meeting with. That's an inappropriate thing to do. So I would think that if that in fact is what I heard when I heard it, I would have thought that was a bad thing. I don't know that I said that. I don't remember what I said, and I don't remember to whom I said it.

Q You don't recall that you later gave orders to the effect that we're going to pretend this never happened...

A No, sir.

Q ... or something like that?

A No, sir. I don't recall that. First of all, I don't recall that I gave orders to fire anybody, if that was the implication of your first statement.

Q It wasn't an implication. Actually, the question was that you initially wanted somebody fired. You were so mad that you wanted somebody fired.

A I don't remember that, first of all. I remember thinking it was an inappropriate thing to do. And I remember - as I usually do when I'm mad, I - after a while, I wasn't so mad about it. And I'm quite aware that Ms. Lewinsky has a way of getting information out of people when she's either charming or determined. And it - I could have just said, well, I'm not so mad about it anymore. But I don't remember the whole sequence of events you're talking to me about now, except I do remember that somehow Monica found out Eleanor Mondale was there. And I learned either that day or later that one of the uniformed division personnel had told her. I thought then it was a mistake; I think now it was a mistake. I'm not sure it's a mistake someone should be terminated over. I think that, you know, you could just tell them not to do that anymore.

Q In fact, it would kind of be an overreaction to get irate or terminate somebody for revealing to a former White House staffer who visits where the president is, don't you think, sir?

A Well, it would depend upon the facts. I think, on the whole, people in the uniformed Secret Service who are working on the gate have no business telling anybody anything about the president's schedule, just as a general principle. I didn't mind anybody knowing that she was there, if that's what you're saying. I could care less about that. But I think that the schedule itself - these uniform people -you know, somebody shouldn't just be able to come up on the street, and because they know who the Secret Service agent is, he says who the president's with. I don't think that's proper.

Q I agree, Mr President.

A But, on the other hand, I didn't - you know, I wanted to know what happened. I think we found out what happened. And then they were, I think, told not to let it happen again, and I think that's the way it should have been handled. I think it was handled in the appropriate way.

Q And you have no knowledge of the fact that Secret Service officers were told later in the day something to the effect of "This never happened; this event never happened; you have no knowledge of that"?

A Sir, I'm not sure anybody ever told that to me. I mean, I thought you were asking - let me just say my interpretation of this, of your previous question, was different than what you're asking now. What I remember was being upset that this matter would be discussed by anybody. It's incidental it happened to be Monica Lewinsky. And that whatever I said, I don't recall, but then thinking that the appropriate thing to do was to say, look, this is not an appropriate thing for you to be talking about, the president's schedule, and it shouldn't happen again. Now the question you seem to be asking me now - I just want to be sure I'm getting the right question - is whether I gave instructions in effect to pretend that Monica Lewinsky was never at the gate.

Q To the effect of...

A And if that is the question you're asking me, I don't believe I ever did that, sir. I certainly have no memory of doing that.

Q We'll take a break now....

Q Mr President, these next series of questions are from the grand jurors. And let me you 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 I - 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.

Q Well, I have a question regarding your definition. And my question is, is oral sex performed on you within that definition as you understood it?

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

Q The grand jurors would like to know upon what basis -what legal basis you're declining to answer more specific questions about this. I've mentioned to you that obviously you have privileges - privileges against self-incrimination. There's no general right not to answer questions. And so one of the questions from the grand jurors is what basis - what legal basis are you declining to answer these questions?

A I'm not trying to evade my legal obligations or my willingness to help the grand jury achieve their legal obligation. 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, that amounted to an obstruction of justice or a subornation of perjury. And I'm prepared to answer all questions that I - that the grand jury needs to draw that conclusion. Now respectfully, I believe the grand jurors can ask me if I believe - just like that grand juror did - could ask me, do you believe that this conduct falls within that definition. If it does, then you're 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.

Q If a person touched another person - you touched another person on the breasts, 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 breasts of another person, with the purpose to arouse or gratify, under that definition, that would be included.

Q Only directly, sir, or would it be directly or through clothes?

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

Q If the person being deposed kissed the breasts 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. This basically says 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.

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.

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.

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.

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.

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.

Q Including touching her breast, kissing her breast or touching her genitalia?

A That's correct.

Q Would you agree with me that the - insertion of an object into the genitalia of another person with the desire to gratify sexually would fit within the definition you used in the Jones case as sexual relations?

A There is nothing here about that, is there? I don't know that I ever thought about that one way or the other.

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 2, Paragraph 2 was eliminated, and Paragraph 2 actually dealt with the object issue, that perhaps whoever wrote this didn't intend for Paragraph 1 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.

Q If it - that it would not be covered, that activity would not be covered.

A That's right. If the activity you just mentioned would be covered in number two and number two was stricken, I think you can infer logically that Paragraph 1 was not intended to cover. But as I said, I've not been asked this before. I'm just doing the best I can here.

Q Well, if someone were to hold or a judge were to hold that you're incorrect, and that definition one does include the hypo I've given to you - because we're talking in hypos so that you don't - under your request here - if someone were to tell you or rule that you're wrong, that the insertion of an object into somebody else's genitalia with the intent to arouse or gratify the sexual desire of any person is within definition one...

A Mr Wisenberg, I have said all along that I would say what I thought it meant, and you could infer that I didn't. This is an unusual question, but it's a slippery slope. I - we can - I have tried to deal with some very delicate areas here, and in one case, I've given you a very forthright answer about what I thought 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, 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 ridiculous, 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.

Q As I understand your testimony, Mr President, touching somebody's breast with the intent to arouse, with the intent to arouse or gratify sexual desire of any person, is covered. Kissing the breast is covered. Touching the genitalia is covered, correct?

A I believe it is. Yes, sir.

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

A If performed on the deponent.

Q Is not covered, correct?

A That's my reading of this number one.

Q And you're declining to answer the hypothetical about insertion of an object. I need to inform you, Mr President - but we'll go on, at least for now - but I need to inform you that the grand jury will consider your not answering the questions more directly in their determination of whether or not they're going to issue another subpoena. Let me switch the topic and talk to you about John Podesta and some of the other aides you met with and spoke to after this story became public on January 21st, 1998, the day of The Washington Post story.

Do you recall meeting with him around January 23rd, 1998, Friday a.m. in your study, two days after The Washington Post story, and extremely explicitly telling him that you didn't have - engage in any kind of sex in any way, shape or form with Monica Lewinsky, including oral sex?

A I meet with John Podesta almost every day. I meet with a number of people. And the only thing I - what happened in the couple of days after what you did was revealed is a blizzard to me. The only thing I recall is that I met with certain people, and a few of them I said I didn't have sex with Monica Lewinsky, or I didn't have an affair with her or something like that. I had a very careful thing. I said - and I tried not to say anything else.. And I - it might be that John Podesta was one of them. But I do not remember the specific meeting about which you asked or the specific comments to which you referred.

Q You don't remember...

A Seven months ago, I'd have no way to remember, no.

Q You don't remember denying any kind of sex in any way, shape or form with him, including oral sex, correct?

A I remember that I issued a number of denials to people that I thought needed to hear them, but I tried to be careful and to be accurate in them. And I do not remember what I said to John Podesta.

Q Surely, if you told him that, that would be a falsehood, correct?

A Oh, I didn't say that, sir. I didn't say that at all. That is not covered by the definition, and I did not address it in my statement.

Q Well, let me ask you then. If you told him - perhaps he thought it was covered. I don't know. But if you told him, if you denied to him sex in any way, shape or form - kind of similar to what Mr Bennett did at the deposition, including oral sex - wouldn't that have been a falsehood?

A Now, Mr Wisenberg, I told you, in response to a grand jury's question - you asked me did I believe that oral sex performed on the person who was being deposed was covered by that definition. And I said: No. I don't believe it's covered by the definition. I said you were free to conclude that I did not do things that I believe were covered by the definition.. Look, I'm not trying to be evasive here. I'm trying to protect my privacy, my family's privacy, and I'm trying to stick to what the deposition was about. If the deposition wasn't about this and didn't cover it, then I don't believe that I should be required to go beyond my statement.

Q Mr President, it's not our intent to embarrass you, but since we have to look, among other things, at obstruction of justice, questions of obstruction of justice and perjury, the answer to some of these delicate and unfortunate questions are absolutely required. And that is the purpose that we have to ask them for.

A That's not...

Q Mr President, one of the - one of the nice things about - one of the normal things about an investigation and a grand jury investigation is if the grand jurors and the prosecutors get to ask the questions unless they're improper and unless there's a legal basis. As I understand from your answers, there's no legal basis for which you decline to answer these questions. And I'll ask you again to answer the question. I'm unaware of any legal basis for you not to. If you told John Podesta two days after the story broke something to this effect - that you didn't have any kind of sex in any way, shape or form, including oral sex, with Ms. Lewinsky. Were you telling him the truth?

A And let me say again, with respect, this is an indirect way to try to get me to testify to questions that have no bearing on whether I committed perjury. You apparently agree that it has no bearing on whether...

Q No, I don't. I don't agree.

A ... I committed perjury.

Q Mr President, I'm sorry, with respect, I don't agree with that. I'm not going to argue with you about it. I just am going to ask you again - in fact, direct you - to answer the question.

A I'm not going to answer that question because I believe it's a question about conduct that, whatever the answer to it is, would - does not bear on the perjury because oral sex performed on the deponent under this definition is not sexual relations. It is not covered by this definition.

Q The - you denied - the witness is not declining to tell me anything. Did you deny oral sex in any way, shape or form to John Podesta?

A I told you so before and I will say again - in the aftermath of this story breaking, and what was told about it, the next two days, the next three days are just a blur to me. I don't remember to whom I talked, when I talked to them or what I said.

Q So you're not declining to answer. You just don't remember.

A I honestly don't remember - no. I'm not saying that anybody who had a contrary memory is wrong. I do not remember..