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 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 apologise for that in advance. I'll try to be as brief and direct as possible.
Mr President, were you physically intimate with Monica Lewinsky? Was this contact with Ms Lewinsky - Mr President, did it involve any sexual contact in any way, shape or form?
A 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 characterisation.
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 17, 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; that's what I believe it means today.
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 If I can summarise 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 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 counsellor 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 28. 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 Ms Lewinsky? After this relationship, this intimate, inappropriate, intimate relationship between you and Ms 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 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's 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 counselled 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 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 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 19, just three 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 three weeks.
Q Now, on the morning of the 6th, Monica Lewinsky came to the north-west 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 [Clinton's secretary] 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 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.
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. 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 criminalise 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 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 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 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 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.
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. 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.
Q Did you ever tell Ms Lewinsky, or promise to her that you would do your best to get her back into the White House after the 1996 presidential elections?
A What I told Ms Lewinsky was that I would, I would do what I could to see, if she had a good record at the Pentagon, and she assured me she was doing a good job and working hard, that I would do my best to see that the fact that she had been sent away from the Legislative Affairs section did not keep her from getting a job in the White House, and that is, in fact, what I tried to do. I had a conversation with Ms Scott about it, and I tried to do that. But I did not tell her I would order someone to hire her, and I never did, and I wouldn't do that. It wouldn't be right.
Q When you received the book, this gift from Monica, the "Presidents of the United States", this book that you liked and you talked with Monica about, did it come with a note? Do you remember the note that it came with, Mr President?
A No, sir, I don't.
Q Do you agree with me that the statement, "I was never alone with her", is incorrect? You were alone with Monica Lewinsky, weren't you?
A Well, again, it depends on how you define alone. Yes, we were alone from time to time, even during 1997, even when there was absolutely no improper contact occurring. Yes, that is accurate. But, there were also a lot of times when, even though no one could see us, the doors were open to the halls, on both ends of the halls, people could hear. The Navy stewards could come in and out at will, if they were around. Other things could be happening. So, there were a lot of times when we were alone, but I never really thought we were.
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, you already know the answer to. Not if, but you know whether. 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.
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, 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.
Q Were you sending some kind of a signal to her by wearing a tie she had given you on the day that she appeared in front of the grand jury?
A No, sir. I don't believe she gave me this tie. And if I was sending a signal, I'm about to send a terrible signal, and maybe you ought to invite her to talk again. I don't, I don't want to make light about this. I don't believe she gave me this tie. I don't remember giving, her giving me this tie. And I had absolutely no thought of this in my mind when I wore it. If she did, I, I, I, I don't remember it, and this is the very first I've ever hearing of it.
Q So, you sat back and relied on this legalistic distinction between your personal, which you are in control of, and the White House which, by the way, you are also in control of; is that not correct?
A Mr Bennett, 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 five and a half years have been devoted to my job. Now, during that five and a half 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.
Q Just for the record, the invitation to the grand jury was contingent upon us not videotaping, and we had to videotape because we have an absent grand juror.
A Well, yes. Do you want to answer that?
Q Thank you, Mr President. [end of final tape]Reuse content