Excerpt from President Clinton s deposition on January 17, 1998, in the civil action brought against him by Paula Jones. James Fisher led the questioning for Jones. The President was defended by Bob Bennett. Judge Wright personally presided over the deposition. Q. Now, do you know a woman named Monica Lewinsky? A. I do. Q. How do you know her? A. She worked in the White House for a while, first as an intern, and then in the legislative affairs office. Q.... Do you recall when you met her for the first time? A. It would be sometime, I'd think, in later 1995. Q. She began to work in the White House office of legislative affairs around December of 1995, correct? A. I have no idea. Q. Do you know how she obtained that job? Q. Did you ever talk to anyone about finding a job for Monica Lewinsky? A. When she got the job in the legislative affairs office? No. Q.... Did you ever talk to anyone about the possibility of her obtaining a job in the White House? A. She came there as an intern, and, as several of them have, she applied for some job there apparently and got the job. I was not involved in her moving from being an intern to being a full-time employee. I had no involvement in that whatever. Q. And you never talked to anyone about that? A. No, I did not. Q. In April of 1996 she was offered and she accepted a job as assistant to the assistant secretary for public affairs at the U.S. Department of Defense; is that correct? A. I don't know when she went over there. 1
Q.... And worked at the Pentagon, correct? A. Well, she worked for the Department of Defense. I think that's where all their officers are in Washington. Q. Is it true that when she worked at the White House she met with you several times? A. I don't know about several times. There was a period when the Republican Congress shut the government down that the whole White House was being run by interns, and she was assigned to work back in the chief of staff's office, and we were all working there, and so I saw her on two or three occasions then. And then when she worked at the White House, I think there was one or two other times when she brought some documents to me. Q. Well, you also saw here at a number of social functions at the White House, didn't you? A. Could you be specific? I'm not sure. I mean when we had like big staff things, like in the summertime, if I had a birthday party and the whole White House staff came, then she must have been there. If we had a Christmas party and the whole White House staff was invited, she must have been there. I don't remember any specific social occasions at the White House, but people who work there when they're invited to these things normally come. It's a they work long hours, it's hard work, and it's one of the nice things about being able to work there, so I assume she was there, but I don't have any specific recollection of any social events. Q.... At any time were you and Monica Lewinsky alone together in the Oval Office? A. I don't recall, but as I said, when she worked at the legislative affairs office, they always had somebody there on the weekends. I typically worked some on the weekends. Sometimes they'd bring me things on the weekends. She it seems to me she brought things to me once or twice on the weekends. In that case, whatever time she would be in there, drop it off, exchange a few words and go, she was there. I don't have any specific recollections of what the issues were, what was going on, but when the Congress is there, we're working all the time, and typically I would do some work on one of the days of the weekends in the afternoon. Q. So I understand, your testimony is that it was possible, then, that you were alone with her, but you have no specific recollection of that ever happening? A. Yes, that's correct. It's possible that she... brought something to me and that at the time she brought it to me, she was the only person there. That's possible. Q.... Do you recall ever walking with Ms. Lewinsky down the hallway from the Oval Office to your private kitchen there in the White House? 2
Mr. Bennett: Your Honor, excuse me, I need some guidance from the Court at this point. I'm going to object to the innuendo. I'm afraid, as I say, that this will leak. I don't question the predicates here. I question the good faith of counsel, the innuendo in the question. Counsel is fully aware that Ms. Jane Doe 6 has filed, has an affidavit which they are in possession of saying that there is absolutely no sex of any kind in any manner, shape or form, with President Clinton, and yet listening to the innuendo in the questions Judge Wright: No, just a minute, let me make my ruling. I do not know whether counsel is basing this question on any affidavit, but I will direct Mr. Bennett not to comment on other evidence that might be pertinent and could be arguably coaching the witness at this juncture. Now, I, Mr. Fisher is an officer of this court, and I have to assume that he has a good faith basis for asking the question. If in fact he has no good faith basis for asking this question, he could later be sanctioned.... I'm going to permit the question.... [During Clinton s August 1998 Grand Jury testimony, the Independent Counsel will revisit Clinton s silence during the foregoing exchange.] A. Well, let me try to describe the facts first, because you keep talking about this private kitchen. The private kitchen is staffed by two naval aides. They have total, unrestricted access to my dining room, to that hallway, to coming into the Oval Office. The people who are in the outer office of the Oval Office can also enter at any time. After I went through a presidential campaign in which the far right tried to convince the American people I had committed murder, run drugs, slept in my mother's bed with four prostitutes, and done numerous other things, I had a high level of paranoia. There are no curtains on the Oval Office, there are no curtains on my private office, there are no curtains or blinds that can close the windows in my private dining room. The naval aides come and go at will. There is a peephole on the office that George Stephanopoulos first and then Rahm Emanuel occupied that looks back down that corridor. I have done everything I could to avoid the kind of questions you are asking me here today, so to talk about this kitchen as if it is a private kitchen, it's a little cubbyhole, and these guys keep the door open. They come and go at will. Now, to go back to your question, my recollection is that, that at some point during the government shutdown, when Ms. Lewinsky was still an intern but was working the chief staff's office because all the employees had to go home, that she was back there with a pizza that she brought to me and to others. I do not believe she was there alone, however. I don't think she was. And my recollection is that on a couple of occasions after that she was there but my secretary Betty Currie was there with her. She and Betty are friends. That's my recollection. And I have no other recollection of that. Q. While I appreciate all of that information, for the record I'm going to object. It's nonresponsive as to the entire answer up to the point where the deponent said, Now back to your question. At any time were you and Monica Lewinsky alone in the 3
hallway between the Oval Office and this kitchen area? A. I don't believe so, unless we were walking back to the back dining room with the pizzas. I just, I don't remember. I don't believe we were alone in the hallway, no. Q. Are there doors at both ends of the hallway? A. There are, and they're always open. Q. At any time have you and Monica Lewinsky ever been alone together in any room in the White House? A. I think I testified to that earlier. I think that there is a, it is I have no specific recollection, but it seems to me that she was on duty on a couple of occasions working for the legislative affairs office and brought me some things to sign, something on the weekend. That's I have a general memory of that. Q. Do you remember anything that was said in any of those meetings? You know, we just have conversation, I don't remember. Q.... Have you ever met with Monica Lewinsky in the White House between the hours of midnight and six a.m.? A. I certainly don't think so. Q. Have you ever met A. Now, let me just say, when she was working there, there may have been a time when we were all we were up working late. There are lots of, on any given night, when the Congress is in session, there are always several people around until late in the night, but I don't have any memory of that. I just can't say that there could have been a time when that occurred, I just but I don't remember it. Q. Certainly if it happened, nothing remarkable would have occurred? A. No, nothing remarkable. I don't remember it. Q.... When was the last time you spoke with Monica Lewinsky? A. I'm trying to remember. Probably sometime before Christmas. She came by to see Betty sometime before Christmas. And she was there talking to her, and I stuck my head out, said hello to her. Q. Stuck your head out of the Oval Office? 4
A. Uh-huh, Betty said she was coming by and talked to her, and I said hello to her. Q. Was that shortly before Christmas or A. I'm sorry, I don't remember. Been sometime in December, I think, and I believe that may not be the last time. I think she came to one of the Christmas parties. *** Q. Well, have you ever given any gifts to Monica Lewinsky? A. I don't recall. Do you know what they were? Q. A hat pin? A. I don't, I don't remember. But I certainly, I could have. Q. A book about Walt Whitman? A. I give let me just say, I give people a lot of gifts, and when people are around I give a lot of things I have at the White House away, so I could have given her a gift, but I don't remember a specific gift. Q. Do you remember giving her a gold brooch? Q. Do you remember giving her an item that had been purchased from The Black Dog store at Martha's Vineyard? A. I do remember that, because when I went on vacation, Betty asked me if I was going to bring some stuff back from The Black Dog, and she said Monica loved, liked that stuff and would like to have a piece of it, and I did a lot of Christmas shopping from The Black Dog, and I bought a lot of things for a lot of people, and I gave Betty a couple of the pieces, and she gave I think something to Monica and something to some of the other girls who worked in the office. I remember that because Betty mentioned it to me. Q. What in particular was given to Monica? A. I don't remember. I got a whole bag full of things that I bought at The Black Dog. I went there, they gave me some things, and I went and purchased a lot at their store, and when I came back I gave a, a big block of it to Betty, and I don't know what she did with it all or who got what. Q. But while you were in the store you did pick out something for Monica, correct? 5
A. While I was in the store first of all, The Black Dog sent me a selection of things. Then I went to the store and I bought some other things, t-shirts, sweatshirts, shirts. Then when I got back home, I took out a thing or two that I wanted to keep, and I took out a thing or two I wanted to give to some other people, and I gave the rest of it to Betty and she distributed it. That's what I remember doing. Q. Has Monica Lewinsky ever given you any gifts? A. Once or twice. I think she's given me a book or two. Q. Did she give you a silver cigar box? Q. Did she give you a tie? A. Yes, she had given me a tie before. I believe that's right.... Q.... Did you have an extramarital sexual affair with Monica Lewinsky? Q. If she told someone that she had a sexual affair with you beginning in November of 1995, would that be a lie? A. It's certainly not the truth. It would not be the truth. Q. I think I used the term sexual affair. So the record is completely clear, have you ever had sexual relations with Monica Lewinsky, as that term is defined in Deposition Exhibit 1, as modified by the Court? [At the beginning of the deposition, the court had accepted part (1) of the Jones team s definition of sexual relations, and excluded parts (2) and (3), leaving the following definition of the phrase: For the purposes of this deposition, a person engages in sexual relations when the person knowingly engages in or causes contact with the genitalia, anus, groin, breast, inner thigh, or buttocks of any person with an intent to arouse or gratify the sexual desire of any person.] MR. BENNETT: I object because I don't know that he can remember. JUDGE WRIGHT: Well, it's real short. He can I will permit the question and you may show the witness definition number one. A. I have never had sexual relations with Monica Lewinsky. I've never had an affair with her. 6