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MONICA LEWINSKY'S GRAND JURY TESTIMONY

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OFFICE OF THE INDEPENDENT COUNSEL

DEPOSITION OF Wednesday, August 26, 1998
MONICA S. LEWINSKY : Washington, D. C.

Deposition of

MONICA S. LEWINSKY

before the Independent Counsel, held in the Conference Room of the
Office of the Independent Counsel, Suite 490-North, 1001
Pennsylvania Avenue, N. W., Washington, D. C. 20004, beginning
at 12:35 p.m., when were present:

For the Independent Counsel:

KARIN IMMERGUT, ESQUIRE
Associate Independent Counsel

MARY ANNE WIRTH, ESQUIRE
Associate Independent Counsel
Court Reporter: Elizabeth A. Eastman

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PROCEEDINGS

MS. IMMERGUT. We are on the record. Ms. Lewinsky, could you please state and spell your full name for the record?

MS. LEWINSKY: Monica Samille Lewinsky, M-O-N-I-C-A S-A-M-I-L-L-E, L-E-W-I-N-S-K-Y.

MS. IMMERGUT: For the record. I am Karin Immergut from the Office of Independent Counsel. Seated with me is Mary Anne Wirth, also from the Office of the Independent Counsel.

WHEREUPON,

MONICA S. LEWINSKY

having been called for examination by the Office of the Independent counsel, and having been first duly sworn by the notary, was examined and testified as follows:

EXAMINATION BY COUNSEL FOR THE INDEPENDENT COUNSEL BY MS. IMMERGUT:

QUESTION: Before we begin the deposition, I do want to advise you of certain rights that you have in connection with this deposition. You have already, I know, testified twice before the grand jury, and essentially the same rights do apply.

First, you have a right to have an attorney present outside of the room. Do you have an attorney present?

A Yes, I do.

QUESTION: Who is that attorney?

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A Plato Cacheris.

QUESTION: You have the right to consult with Mr. Cacheris any time during the testimony, and I simply ask that you just request a break when you need to consult with him. Do you understand that you have that right?

A Yes, I do.

QUESTION: You also generally as a witness in a deposition, or before a grand jury, have a Fifth Amendment right not to incriminate yourself. Obviously, that now is modified pursuant to the agreement that you have with the Office of the Independent Counsel.

Do you understand that?

A Yes.

QUESTION: Nave you seen the agreement that you have, giving you immunity for your cooperation in this case?

A Yes, I have.

QUESTION: That also is a grand jury exhibit in this case, is it not?

A Yes, it is.

QUESTION: Do you have any questions about what your rights are not to incriminate yourself as part of that agreement?

A No, I don't.

QUESTION: In addition, as always, you are required to tell the truth during this procedure and are subject to the penalties of perjury if you do not tell the complete truth.

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Do you understand that?

A Yes, I do.

QUESTION: Any other questions that you have before we proceed?

A No.

QUESTION: First I just want to ask you a general question. know you have testified in two other proceedings about various aspects of your relationship with the President. Can you characterize whether or not your relationship was one that started with sex and then evolved into a friendship, or the other way around?

A It started with a physical attraction, which led to a sexual relationship, and then the emotional and friendship aspects of that relationship developed after the beginning of our sexual relationship.

QUESTION: I would like to place before you whet I will mark as Deposition exhibit No. 1.

(Deposition Exhibit No. 1 was

marked for identification.)

BY MS. IMMERGUT:

QUESTION: This is also a chart that was previously marked as Grand Jury Exhibit ML #7. You can see the Xerox copy of that sticker on this exhibit, and I will place that before you, and ask if you recognize what that exhibit is?
A Yes, I do.

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QUESTION: What do you recognize it to be?

A A chart that I helped develop with the Office of Independent Counsel to describe and enumerate the - - my relationship with the President, the contacts between the President and myself.

QUESTION: As you've testified before, did you provide the information that is on this chart?

A Yes, I did.

QUESTION: And is it accurate to the best of your recollection of the events?

A Yes, it is.

QUESTION: What I would like to do is go through the events that are written in bold, which deal with the private encounters you had with the President that involved, for the most part, some sort of physical intimacy that we have listed as physical intimacy, including oral sex. I did want to get into some more detail about each incident.

Basically, with respect to each incident, I would like you to describe the circumstances leading up to the actual visit, who initiated it, how it was set up, and then I would like to ask you some details about the sexual encounters themselves that occurred during each of those
visits . .
So; why don't we start with the very first one,

which is the second encounter that you had on November 15th,

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1995 that you've already testified some about. If you can, could you just tell us how that visit was set up, and then what occurred during the visit?

A The President came back to Mr. Panetta's office and I was the only person in the office at the time, and believe it was maybe around, I think. 10 p.m. or so, and asked me, or told me that if I wanted to meet him back in Mr. Stephanopoulos' office in about 5-10 minutes, that I could. And I told him I was interested to do that.

QUESTION: At that time, did you understand what it was he wanted to meet with you about?

A I had an idea. I, I, I had assumed that since we bad been intimate in our previous encounter that evening, that we would again be intimate.

QUESTION: And just to clarify for the record, the intimacy that you had earlier that night was just kissing, is that correct?
A Yes.

QUESTION: So, did you, in fact, go meet with the President?
A Yes, I did.

QUESTION: And could you describe where you went to meet him?

A I met him back in Mr. Stephanopoulos' office and he invited me into the back study again, and we were in the hallway. And we were -- I don't remember exactly how it started. But I know that we were talking a bit and kissing.

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I remember -- I know that he - - I believe I unbuttoned my jacket end he touched my, my breasts with my bra on, and then either -- I don't remember if I unhooked my bra or he lifted my bra up, but he -- this is embarrassing.

QUESTION: Then touched your breasts with his hands?

A Yes, he did.

QUESTION: Did he touch your breasts with his mouth?

A Yes, he did.

QUESTION: Did he touch your genital area at all that day?

A Yes. We moved -- I believe he took a phone call in his office, and so we moved from the hallway into the back office, and the lights were of f. And at that point, he, he put his bend down my pants end stimulated me manually in the genital area.

QUESTION: And did he bring you to orgasm?

A Yes, he did.

QUESTION: Back to the touching of your breasts for a minute, was that then through clothing or actually directly onto your skin?

A Me touched my breasts through clothing, being my bra, and then also without my bra on.

QUESTION: On that occasion, did you perform oral sex on the President?

A Yes.

QUESTION: Who actually initiated your performing oral sex?

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8
A I did.

QUESTION: Was the President wearing pants?

A Yes, he was.

QUESTION: Who unzipped his pants?

A I believe I went to go unbutton his pants and I had trouble. So, he did that. So, but --

QUESTION: So, you started it?

A If I remember correctly.

QUESTION: And he helped complete opening his pants?

A yes.

QUESTION: Did the President at that time do anything to stop you from doing that?

A No. I think he asked me if I was sure I wanted to do that.

QUESTION: Did you have any other discussion with him while the sexual encounter was occurring, about the sex or what you were doing?

A No. Actually, I don't think he asked me if I were sure I wanted to do that, because he was on the telephone. So -- I'm sorry.

Could you repeat what you just asked me?

QUESTION: Did the President have any discussion with you about sex, or you with him, while the sexual encounter was occurring?

A Not at this time. He was on the telephone for the

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second half when we were in the office.

QUESTION: So, he was on the telephone while you were performing oral sex?

A He was on the telephone while he was - -

QUESTION: Touching you?

A Touching me, and was also on the telephone when I was performing oral sex.

QUESTION: For any part of this sexual encounter, was he then of f the telephone?

A Yes, I believe towards the end of my performing oral sex.

QUESTION: Did he say anything about the oral sex or anything about the sex at all when he got off the phone, that you can remember?

A He stopped me before he came, and I told him that I wanted to, to complete that. And he said that, that he needed to wait until he trusted me more. And then I think he
Q _____________
A Yes.
Q Did he ejaculate in your presence that time at all?
A No.
Q How did you depart from the office, or how did you

end that visit?

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10

A I believe we spoke for awhile and I know at some point in that conversation I - - oh, that might have been Friday. Hmm. I really don't remember how it ended.

QUESTION: Can you estimate at all how long the sexual part of your encounter with him lasted?
A Maybe 20 minutes?
Q How long - -
A I'm not a very good estimator of times. .
Q How long did the entire encounter last, if you can

recall?
A The second one of that evening?
Q Yes.
A Maybe half an hour or 40 minutes?
Q So, the entire encounter did not involve simply the

sexual part of it?

A No, it didn't.

QUESTION: Did you have talking beforehand or was most of the talking afterwards?

A It was before and after.

QUESTION: If I can direct your attention again back to Deposition Exhibit No. 1, the chart, the next date where you do have two encounters with the President is November 17th, 1995. Although you've described it somewhat for the grand jury, if you could now just describe in detail -- again, I'll direct your attention to that second contact where there was

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physical intimacy, including oral sex listed -- how that contact came about and what occurred during the contact?

A Yes. I had brought the President pizza, as he had asked. And when I brought it into him at the Oval Office, then he took me into the, to the back office and said that I could leave through that way. I believe we were talking for a little bit and he then, he got a phone call and he took the phone call in his bathroom.

Oh, it might have been before the phone call that

-- I don't, I don't remember who, who unbuttoned my jacket or anything like that, But we were kissing and he was fondling my breasts with his hands and with his mouth.

QUESTION: Was that through clothing or not through clothing?

A It was both.

QUESTION: Okay. So, was there a point that your bra is removed?

A Yes.

QUESTION: But you don't remember who actually removed it?

A No. I think, I think he -- rather than necessarily removing my bra, sometimes he would just expose my breasts.

QUESTION: By lifting the bra over your breasts?

A Yes, or sometimes lifting my breasts out of the bra. Oh, God.

QUESTION: So, on that occasion though, you do recall that he touched you not just through your bra, but also directly on

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the skin?

A Yes.

A
QUESTION: Was there any discussion about sex while you were in this encounter with him?

A I don't remember the specifics of it, but I know there was another discussion, I think, about him not letting me make him come, and then I had to get back to -- I'm sorry.

Could you repeat the question?

QUESTION: Was there any discussion during the November 17th encounter about sex during the encounter?

A I don't know exactly what you mean. I mean, do you mean either about --

QUESTION: Talking - -

A I mean, saying things, or --

QUESTION: Well, either about what he wanted or what you wanted, or anything like that, in terms of sex?

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A No. I mean, I think that there were always things being said, but not necessarily in a conversational form. Does that make sense?

QUESTION: Okay. And when you say there were always things being said, do you mean kind of chatting while you were having sex, or things that felt good? I don't mean that. mean -A Okay.

QUESTION: -- trying either implicitly giving you direction about what he wanted, or why he wouldn't ejaculate, anything like that?

A I believe that why he wouldn't ejaculate was, was discussed again.

QUESTION: Okay. You mentioned that the President unzipped his pants. Did you understand that to be a signal of what he wanted in terms of sex?

A Yes.

QUESTION: Did he ever say anything while that was happening about what he wanted or no?

A No. He was on the telephone.

QUESTION: Okay. And that was on the second time also?

A Yes.

QUESTION: Was he on the telephone the whole time that you performed oral sex on him on the l7th of November?

A I donut remember.

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QUESTION: Do you remember how you finished that meeting up with him that day, how you left?

A Yes. I know I needed to get back to my office, and he -- I think I told him that he should come down and have pizza with us, he should bring his pizza down, and that everyone was down there. And at some point I believe in that meeting he told me that, or he reiterated because he might have said it on the 15th as well, that I could come see him on the weekends when, when there weren't a lot of people around .

QUESTION: With respect again to the ejaculation, that he wouldn't actually ejaculate during oral sex, were you aware, or did he ejaculate anywhere in your presence on that occasion?

A No.

QUESTION: The next date listed on the chart is December 31st, 1995, a Sunday. Could you describe how that meeting was set up and what occurred when you got to the meeting?

A Yes. I had been having a conversation with Hal and had just told him that I smoked my first cigar the night before in honor of my brother's birthday. And Nel asked me if I wanted -- or offered that he could get me one of the President's cigars from his sort of stash of cigars. I said, that would be great.

And we went through the Roosevelt Room to the

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entrance into the back study which - - the door that leads into the dining room. And just as we approached the door, the door swung open and the President was standing right there, and he had something he was going to take to Mr. Panetta. So, he asked, he asked Nel to take this -- I think it was a picture actually -- a picture down to Mr. Panetta, and he invited me in,

So, I went into the office and he asked me what I was doing there. And -- well, first he told me he had been looking for me. And then he told me -- he asked me what I was doing there, and I told him that Nel was going to get me a cigar. So, he said that he would give me a cigar. So, he did give me a cigar.

And then we were talking for a little bit and I had

-- do you want me to just be --

QUESTION: If you could do a narrative, that's fine. A Well, he had -- I had thought that he had forgotten

my name before, because I had seen him in the hall a few times and he kept calling me "Kiddo", So, so, I sort of reiterated my - - I said my name again to him. You know, I said, you know, it's Monica Lewinsky, President Kiddo, you know. And he said, I know your name.

And he told me that he had tried to call me and that -- he said, but you're not in the book; I even spelled your last name right. So, it was, it was really funny. It

1295
16
was cute.

And then we were, we were kissing and he lifted my sweater and exposed my breasts and was fondling them with his hands end with his mouth. And then I believe I was fondling him over his pants in his genital area, and I think again I tried to unbutton his pants and I couldn't. So, he did it.

QUESTION: And again, just to be clear, when you mentioned he raised your sweater and fondled your breasts, were your breasts outside of your bra at that time?

A Yes.

A
Q

QUESTION: Did you have any discussion with him again about why he wasn't ejaculating, anything like that?

A Yes, I think so. It might have been at that time

-- the two excuses he always used were, one, that he didn't know me well enough or he didn't trust me yet. So that it sort of seemed to be some bizarre issue for him.

QUESTION: On that occasion, did he ever ejaculate in your.

1297

presence, even though not - - at any time later?

A After he told me to stop and then, and then wished me Happy New Year and kissed me goodbye, he went into the

QUESTION: Okay. Do you know how long that sexual encounter, or the sexual aspect of that encounter lasted, not including the other discussion with him?

A Maybe 10 minutes. Not, not very long. We would always spend quite a bit of time kissing. So.

QUESTION: And kissing and talking end just --

A Uh-huh.

QUESTION: - - being affectionate?
A Yes.

QUESTION: The next one is on page 2, and that would be January 7th of '96. Could you describe how that meeting was set up and what happened when you got there?

A Yes. The President called me -- this is the first time he called me at home -- that afternoon, and it was the first day of the blizzard. And I asked him what he was doing and he said he was going to be going into the office soon . said, oh, do you want some company. And he said, oh, that would be great. So, he said he was going into the office in about 45 minutes, and I told him that I should probably be in my office around that time, and he said he would call me in

1298

my office. I gave him my office number.

Then once I was in my office, he called me end we made en arrangement that I would pass - - he would have the door to his office open, and I would pass by the office with' some papers and then he would, he would sort of stop me and invite me in. So, that was exactly what happened.

I passed by and that was actually when I saw Lew Fox who was on duty outside the Oval Office, and stopped end . spoke with Lew for a few minutes, end then the President came out and said, oh, hey, Monica, you know, what are you doing here, come on in, sort of.

And so we spoke for about 10 minutes in the office. We sat on the sofas. Then we went into the back study and we were intimate in the bathroom.

QUESTION: And when you say you were intimate in the bathroom, what did you do?

A We kissed and he, he fondled my breasts and exposed

- - or I think pulled them out of my bra and fondled them with his hands and with his mouth, and --

QUESTION: Did he touch your genitals on that occasion?

A No. He wanted to and was talking about performing oral sex on me,

QUESTION: Okay. On that date, did you gratify him in some

1299

way other than performing oral sex?

A Yes,

-A

QUESTION: Did you have any discussion about sex during the encounter that you had with him?

A No,

QUESTION: How long was your encounter with him?

A Hmm. Maybe about half an hour? I, I'm -- it's really hard for me to estimate the time.

QUESTION: And that would be the sexual aspect of it though that - -

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A Correct.

QUESTION: -- we're talking about. Did he ejaculate at any point in your presence after you performed oral sex on him?

A That day?

QUESTION: Yes.

A Ho,

MS. IMMERGUT: Did you have a question?

BY MS. WIRTH:

QUESTION: I have a question, actually going back to November 15th, if you don't mind.

A Okay.

QUESTION: When you were talking about the President having contact with your genitals, you said, I think, that he put his hands in your pants. When he touched your genitals, was that through your underwear or directly?
A I didn't have my underwear on at that point.
Q Okay. So, it was directly then?
A Yes.
Q Okay.
BY MS. IMMERGUT:
Q The next encounter listed is January 21st of '96,

also on page 2 of the exhibit. Could you describe how that encounter occurred and what happened during the encounter?

A Yes. I was -- actually, I'm looking at this right now and I think it might have been a Saturday -- no, it was a

1301

Sunday. I'm sorry. Never mind. I think it might have been a Saturday, but it, it says here Sunday. I just noticed that .

I was - - I had been in my office doing work. and I was leaving, leaving for the day. And as I was walking through the Residence hall to go through the West Wing to the Old Executive Office Building, I heard his voice behind me. And either he called my name or I just heard his voice and turned around, and he had just come off of the elevator and, I guess, was going back to his office.

So, we were, we were -- we stopped, and we spoke as we continued to walk through the outdoor corridor by the Rose Garden. And when we got to the point where he turns left to then go into the Oval Office, he told me that I could go out this way with him, that I could leave through the, that I could leave through the Oval Office. So, we walked down the pathway together and then went into the Oval Office from there .

QUESTION: And could you describe your encounter once you got into the Oval Office?

A Yes. We had, we had already had phone sex for the first time the week prior, and I was feeling a little bit insecure about whether he had liked it or didn't like it, and I just -- I felt in general that I didn't know -- from having spoken to him on the phone, you know, prior to having phone

1302

sex and from having had these encounters with him, I didn't know if this was sort of developing into some kind of a longer term relationship then what I thought it initially might have been, that maybe he had some regular girlfriend who was furloughed or something during the furlough.

And at that point, I, you know, I said to him, you know, I asked him why he doesn't ask me any questions about myself, and doesn't he, you know, is this just about sex, you know, because if it is, then I just want to know that; or do you have some interest in trying to get to know me as a person. And so he kind of laughed at the manner in which I was asking him and talking to him.

And we, we went into the back study and he was. he was waiting for a friend of his to come to the office, and he was talking about that he has a lot of -- that he doesn't get a lot of time to himself end he really cherishes the private times that he has with his friends, and he cherishes the time that he had with me, which seemed a little bit odd to me at that time.

But he, he was upset that day about the first soldier in Bosnia had been -- I believe it was that day --that it was the first soldier in Bosnia had been killed just recently, and he was very upset and moved. And so I was trying to comfort him.

QUESTION: When you say you thought it was odd that he said he

1303

cherished the time with you, why was that, why did you think it was odd at that point?

A Because I didn't feel, I didn't feel like he really knew me. We had spent time talking, but it didn't seem --and, you know, he had asked some questions and I offered a lot of information about myself, But he didn't seem to ask probing questions, when you're trying to get to know someone. So, it seemed a little bit odd to me that he would sort of cherish this time, when he, you know, when I felt like he didn't really even know me yet.

QUESTION: And at that point, sex was sort of the more dominant part of the relationship?

A Yes.

QUESTION: Rather than as it became - -

A There was always a lot of joking that went on between us. And so we, you know, I mean, it was fun. When we were together, it was fun. We would laugh and it would --we were very compatible sexually. And I've always felt that he was sort of my sexual soulmate. and that I just felt very connected to him when it came to those kinds of things.

QUESTION: So, on the January 21st date --

A Right.

QUESTION: -- how did it turn into your conversation end then go into actually having a sexual encounter?

A I was in the middle of saying something and he just

1304

started kissing me. And, so, it was funny. It was, it was very funny.

QUESTION: And what room were you physically in at that time? A We were in the hallway. And we were kissing and - -

oh. I had -- because I was leaving, I was having a bad hair day, and this was actually the first time that I had the infamous beret on. And so I just said something to him about feeling stupid. Here I was standing here in this dumb hat, and he said that it wasn't a dumb hat, that I looked cute and he liked it.

And so then he was kissing me, or we were kissing each other, I guess, and I think again he, he fondled my breasts with his hands and his mouth.

QUESTION: Through clothing or not through clothing?

A I think it was always through clothing, and then eventually it, it would be direct contact. So, it wouldn't just be this immediate jump to being, you know, to contact. It was -- there was sort of foreplay to the foreplay, if that makes sense.

QUESTION: Do you remember whether he removed any of your clothing on that occasion?

A I think he -- I remember him lifting my top. So --and he, he sort of exposing my breasts.

QUESTION: Did he stimulate your genitals on that occasion?

A No.

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QUESTION: Did you perform oral sex on him or any kind of sex on him?

A Yes, I did.

QUESTION: Could you describe how that came about?

A Yes. He unzipped his pants and sort of exposed himself and that -- end then I performed oral sex.

QUESTION: Let me ask, on all of these occasions when you've described just the pants unzipping and exposing, is it fair to say that he still kept his pants on?
A Yes,
Q It was just the zipper that --
A Yes.
Q - - was undone?
A Right. And actually at one point during this

encounter, I think someone came into the, to the Oval Office and he, you know, zipped up real quickly and went out and came back in, and I -- this is probably too much information. I just -- sorry.

QUESTION: And what happened?

A I just remember laughing because he had walked out there and he was visibly aroused, and I just thought it was funny. I mean, it wouldn't, it wouldn't necessarily be visible to anyone who just walked in because they wouldn't be looking at that, but it was just funny to me, So,

And then his - - then someone - - I think at that

1306

point someone came in to let him know that his friend had arrived. And so he asked me which way I wanted to leave, and I said I was going to go, I was going to leave through Betty's office. And we went into -- we went from the back study through the Oval into Betty's office area, and he took me into Nancy Hernreich's office and kissed me goodbye,

And then I went to go leave from, from Betty's office, from the door into the hallway, to the West Wing hallway, but it was locked. So, I went back in to tell him. He was still in Nancy's office, I went back into Nancy's office to tell him the door was locked, and he was manually stimulating himself .

QUESTION: Did he cause himself to ejaculate at that point, or did you see that?
A No.
Q But that was in Nancy Hernreich's office?
A Yes.
Q And what did you do when you saw that?
A I smiled,
Q Okay.
A And I think we kissed again.
Q On that occasion, you mentioned that he did not

touch your genitals at all. Was there any discussion about that?

A No.

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QUESTION: Then did you leave from Nancy Hernreich's office eventually?

A I think I left through the - - I left through the door in Betty's office that goes out into the Rose Garden.

QUESTION: On this particular entry on January 21st, it lists that the entire encounter was approximately 30 to 40 minutes. Do you recall what portion of that would have been the sexual encounter part of it, versus just talking?
A Maybe 15 minutes?
Q You just can't really estimate?
A Exactly.
Q Let's go now to February 4th of 1996, the next bold

date where there was a private encounter. Could you describe how that encounter came about and what happened?

A Yes, I was in my office on Sunday and the President called me in the office and - - from the Residence, and told me that he was going to be going into the office later, And I think I asked him if I could come see him. And he said that would be fine, and then that he -- oh, I think he was, he said he was going to go into the office in an hour and a half or so,

So, then he called me - - it was actually maybe two or three hours later, because I remember I thought he forgot, maybe he had forgotten to call me and that - - so. And when he called from the Residence to say he was on his way, I told

1308

him that -- I asked him if we could sort of bump into the hallway, bump into each other in the hallway on purpose this time, because when it happened accidentally, that seemed to work really well and I felt more comfortable doing that. So, that's what we did. We both said, okay, I'm going to leave now .

And indeed we bumped into each other in the hall

and went through the Rose Garden into the Oval Office, And I

think we went right into the back office. The -- when we got

there .

QUESTION: When you say the back office, you mean the study?

A Yes. And -- let's see,

You know, I need to take a break.

QUESTION: Okay. Let's take a break.

(Whereupon, the deposition was recessed from 1:10 p.m. until 1:15 p.m.)
BY MS. IMMERGUT:
Q Ms. Lewinsky, you are still under oath.
A Yes.
Q We are still on February 4th, 1996. You've

described going into the office and starting to kiss the President. What happened then?

A We were in the back office and we were kissing, and I was -- I had a dress on that buttoned all the way, all the way up and down.

1309

QUESTION: To the neck?

A Correct. It was long and down to the, to my ankles, or whatever. And he unbuttoned my dress and he unhooked my bra, and sort of took the dress off of my shoulders and took the bra off of my, off of my -- I'm not explaining this right. So that he moved the bra so that my bra was kind of hanging on one shoulder and so was off. And he just was, he was looking at me and touching me and telling me how beautiful I was.
Q And did he touch your breasts with his hands?
A Yes.
Q Did he also touch them with his mouth?
A Yes.
Q And at that point, that is directly on your skin,

is that right?
A Yes.
Q Did he touch your genitals?
A Yes, he did.
Q Did he bring you to orgasm on that date?
A Yes, he did.

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-A

A
Q

QUESTION: And again, just with respect to bringing you to an orgasm, did he touch you directly on your skin on your genitals, or was it through underwear?

A First it was through underwear and then it was directly touching my genitals,

QUESTION: Did he take your underwear off, or did you take your underwear off?

A Hmm.

QUESTION: Or did they stay on?

A I think that -- I believe that he touched me first with my underwear on, and then placed his bend under my underwear. And I think at some point I, I removed them.

QUESTION: Okay. Did you also perform oral sex on him at that

1311

time?

A Yes, I did.

QUESTION: How did it come about? Was that something that you decided to do, or did the President either, through his actions or words, indicate to you that he wanted that?

A I don't really remember. I mean, it was a mutual

-- I think in all of these instances, it wasn't, you know --I know sometimes it's sort of hard to answer these questions as more directed, But it was - - I mean, it was the course of being intimate, I mean, it was the course of having this kind of a relationship, that you - - sometimes he initiated it, sometimes I initiated it. It wasn't, you know, it wasn't

-- it didn't necessarily go through my mind, okay, now it's time to perform oral sex.

I mean, it was, it was the passion of the moment, That was, I mean, just sort of in the course of things that happened, you know. I always felt that we sort of just, we both really went to a, to a whole other place together sexually.

QUESTION: Is it fair to say you were both trying to please each other by doing different things?

A Yes. Yes.

QUESTION: Is it also fair to say that you were not the sole aggressor in this sexual --

A That's very fair to say.

1312

QUESTION: - - encounter?

A I was not.

QUESTION: Again, I'm just asking you every time in case you remember, do you remember how long the sexual aspect of that encounter lasted?

A I really, I really don't.

QUESTION: Okay. I just note, to direct your attention that the time that you provided us previously is approximately one and a half hours for the whole visit.

A Right, We spent a long time in the Oval Office talking after, maybe 45 minutes to an hour just talking.

QUESTION: And that - -

A I think he was maybe heeding my, my advice from. from the 21st, about trying to get to know me, and so he did.

QUESTION: And is it fair to say that's sort of when the friendship really starts to develop, around that time period?

A It does, That certainly helped. I think he, he was just very sweet, and he -- when I got up to leave, he kissed my arm and told me he'd call me, end then I said, yeah, well, what's my phone number. And so he recited both my home number end my office number off the top of his head. So, I told him, you know, that he got an A.

And he called me in my office later that afternoon to tell me how much he enjoyed talking to me. So -- and then again called Wednesday night to tell me again how much he had

1313

enjoyed talking to me,

So. it - - I think that certainly was a turning point in the relationship, where it kind of went from a --obviously there's, there's some personal and intimate aspects of a sexual relationship that develop just in talking or laughing or getting to the point where you, where you kiss someone on every encounter, But for me, I think that spending the time talking to him was certainly when I, when I got to know him as a person and started to realize that he wasn't necessarily the person I thought he was at that point,

QUESTION: Let's move on to the next date, which is March 31st, 1996, the next encounter where there is physically intimate contact. Why don't you tell us how that date was set up and what happened?

A I had spoken -- well, just to back up real quickly. The President had ended things on the, I think it was the 19th of February. But then he had called me later - - I think it was late February or early March at some point - -indicating to me he wanted to sort of see me again: possibly for some intimate moments.

And it wasn't until the 31st of March that we really were together again physically. But he had called, I think two times, two times prior during that work week, leading up to the 31st. And it was on the Friday night which is, looking at the chart, which was the 29th, that I, I asked

1314

him if I could see him on Sunday. And he said, he'd, you know, he'd see what he could do.

And then on Sunday, he called me in my office and

-- let's see. I believe -- oh. I believe that I brought him papers that day. That I think I asked him to tell the guard outside that he was expecting some papers, expecting someone from Leg Affairs, And then when I got to the door, I told them that I was supposed to bring papers to the President,
Q And that was part of a ruse to - -
A Yes.
Q --get into see him?
A Exactly.
Q Just to back up for a second, you mentioned that

you had had some phone calls with him between February 19th, '96 when he tried to cut off the relationship --
A Yes.
Q - - or the sexual part of the relationship - -
A Correct.
Q -- and the 31st, in which he had suggested that he

wanted to perhaps renew the intimacy. What led you to believe that?

A I saw him on my way out one evening. It was late. And he was on his way home from, I think it was the Israeli Embassy and Evelyn Lieberman was with him. So, I certainly made a point of not having any eye contact or anything with

1315

him, And he called me later that evening and said he had, he had -- after he left and went upstairs, he went back to his office and had called me in my office, hoping that I could come have a visit with him, but I had already gone home.

And so then I offered, I said, well, I could come back. And he said, no, I'm upstairs already. So,

QUESTION: Back now to March 31st --

A Yes.

QUESTION: -- of '96. So, what happens then? How actually is that then finally set up?

A He had called me in my office and then I brought papers there, or fake papers.

QUESTION: Do you then go into the Oval Office?

A Yes, I do.

QUESTION: And what happens?

A We went into the back study and we were in the, the hallway area, And it had sort of become actually a ritual sort of at this point, that we always kind of started out our meetings, that he was leaning against the closed door of the bathroom and I would rub his back, because he has a bad back, So, I used to always rub his back, and sometimes he'd rub my back. But I usually concentrated on his lower back because it was always bothering him.

And, you know, and then I'd usually move around and sort of just lovingly touch his chest and --

1316

QUESTION: Was there any removal of clothing?

A Yes, there was. We kissed and, and he had not been feeling well, I guess, the past couple of days. So, really, most of -- he focused on me pretty exclusively. I guess, in a sexual manner on me that day, and kissed me, and kissed my breasts, and he, he fondled my genitals with his hands,

QUESTION: Through clothing or not through clothing?

A Not through clothing.

QUESTION: Did you have your underwear removed? Or how did your clothes get off?

A (No response.)

QUESTION: Or were they simply pulled out of the way?

A I think I -- I think that they were just sort of --

oh.

QUESTION: Pulled out of the way?

A Yeah,

QUESTION: Okay. So, he touched you. And with your breasts, was that through clothing, through your brassiere, or did he move your breasts out of the way of the brassiere?

A It was, it was both. I mean, it was always both. He -- there was never a time when he just touched my breasts through - -

QUESTION: The bra?

A -- the bra, right.

1317

-A Yes,

QUESTION: Whose idea was that?

A On -- when I met with him on January 7th, after we had been intimate and we were talking in the Oval Office, he was chewing on a cigar. And then he had the cigar in his hand and he was kind of looking at the cigar in a, sort of a naughty way. And so I, I looked at the cigar and I looked at him and I said, we can do that, too, some time.

And I don't, I don't really remember how it got

started, but.

QUESTION: Was it part of the sexual encounter that he did that?

A Yes, it was.

QUESTION: Did you understand it to be arousing?

A It was.

QUESTION: Okay. What happened to the cigar afterwards?

QUESTION: How did you leave that encounter? So, you didn't perform oral sex on him at all that time?

A No.

QUESTION: How--

A Actually, looking also -- I should mention that, looking at the chart, that I didn't bring papers that day. I brought this tie to him in a folder. So, sometimes I brought

1318

papers and this day it was I had a tie, and there probably were some papers in the folder as well.

QUESTION: And that's the Hugo Boss tie that's listed under the gift category for that date?

A Correct.

QUESTION: The next encounter is April 7th, 1996. Could you describe how that encounter was set up?

A The President had called me at home sort of in the early evening, and this was - - it was Easter Sunday and it was the first, it was the Sunday after I had found out I was to be transferred to the Pentagon. And he called -- it also had been the week that Ron Brown had passed away.

So, I asked him how he was doing and we talked about that for a little bit. And then I told him that Monday was my last day, and that I had been transferred. And I was crying and he wanted to know what happened, and I asked him if I could come see him, And he said, that's fine, but just tell me what happened first. So, I explained to him what had happened, and then he told me to come on over. So, I did.

And this is when I had this little encounter trying to get into the office with John Muskett, just that he said

-- I brought papers with me from home in a folder. And so John had said something about wanting to check with Evelyn if it was okay for me to go in. And I don't remember exactly what ended up happening, but I managed to get him to not ask

1319

Evelyn and I got in.

And the President and I were in the back office. He was actually on the phone when I came in. And then when he got of f the phone, we went into the back office and we talked again about what had happened, in terms of my transfer .

And that was when he, he looked me in the eye and he promised me -- well, first he said that he couldn't believe that they were taking me away from him because he trusted me so much, and he was convinced that it had something to do with him, why I was being transferred. And then he looked me in the eye and he said, I promise you, if I win in November, I'll have you back like that (snapping fingers] .

QUESTION: Did he say anything like, if you do a good job at the Pentagon he'll bring you back?

A No,

QUESTION: So, what else happened at that meeting?

A I, I donut remember how it exactly cams about, but I know that, that, I remember kissing him and we were physically intimate .

QUESTION: In terms of the physical intimacy that day, did the President touch your genitals on that date?

A I don't think so.

QUESTION: What about your breasts?

1320
40
A Yes.
Q With his mouth or with his hands, or both?
A With both.
Q And again, I'm assuming, unless you correct me now,

that it's both through clothing and directly on the skin? A Yes.

QUESTION: With respect to oral sex, do you just remember how that occurred, whether his pants came off, whether somebody unzipped them?

A I think he unzipped them and -- because it was sort of this running joke that I could never unbutton his pants, that I just had trouble with it. So, I was -- you know, there were times that I tried and we'd laugh and then he'd, he'd do it.

But we were -- I, I performed oral sex in the, in the back office.

QUESTION: And at that time, did he ejaculate?

A No, he did not.

QUESTION: Was there any discussion with him about the ejaculation at that time that you can remember?

A No,

QUESTION: On that date, I think you've already testified that there was a phone call during your sexual encounter with him, is that right?

A Yes, there was.

1321

QUESTION: Did you perform oral sex while he was on the telephone?

A Yes. It was, it was -- I think I'll just say, because for -- there are a lot of people that could interpret that as being sort of a, that being done in a servicing sort of manner, and it was more done in kind of an exciting sort of -- I don't want to say erotic, but in a way that there was kind of this titillating like a secret, in a sense, in the same way sometimes that an affair is, that, you know, when you are doing this and obviously there is kind of the irony that the person on the other line has no idea what's going

on.

So, I just wanted to clarify that.

QUESTION: Okay. Although on that occasion, I believe you previously mentioned that that was the first time that you felt a little funny about it?

A I, I did. I did. I, I, I, I was, I was pretty emotionally devastated at that point, and the prospect of going to the Pentagon was very upsetting to me, And there were moments when I felt a little uncomfortable, and moments when I didn't.

QUESTION: Although you mentioned that there were other times that he was on the phone, that you didn't think sort of anything bad about it - -

A Right.

1322

42
Q - - and on this occasion, you felt more like - -
A I just--
Q -- you were servicing - -
A Exactly.
Q -- on some level, And did you tell Linda Tripp

about that, do you remember?

A Probably,

QUESTION: How did that encounter end, if you remember? And actually you've already testified a little bit about this, So, just if you could quickly summarize how you finished the encounter end what happened?

A We were in the back office and I heard Mr. Ickes call, say, Mr. President, from the Oval Office. And we both were startled and looked at each other, and he jetted into the Oval and I --

QUESTION: Were you performing oral sex at the time?

A I think so, but I'm not a hundred percent sure. And so then I, I left,

QUESTION: On that occasion also, when the President went to get the phone call, had you started performing oral sex on him before he went to take the phone call?

A Yes, I believe that we were -- I think that that was it. I know that we were, we were intimate in the hallway, end then it was a phone call that prompted us to go into the office. And that when we were in the office, that,

- 1323

that he, he removed, he sort of removed his pants.

QUESTION: How did you know that you were supposed to kind of accompany him to take the phone call? Did he - -

A I don't remember.

QUESTION: - - invite you to come in, in any way, or gesture for you to come along?

A I don't really remember,

QUESTION: So, you think you actually didn't begin the oral sex until he was on the phone already?

A It's --

QUESTION: Or is it not that clear?

A It's not that clear.

QUESTION: But you remember him unzipping his pants at some point?

A At some point, yes.

QUESTION: Before the oral sex?

A Yes.

QUESTION: Okay.

A I hope so.

QUESTION: At that point, and I didn't really ask you this for the other encounters, but in terms of putting your stuff back on or collecting yourself, is there any sort of general way that that happened? Did the President help you, or how did you get dressed again?

A Well, neither of us ever really took -- completely

1324

took off any piece of our clothing, I think specifically because of the possibility of encounters, like what happened that day. But there had, earlier in that day on the 7th, when I - - not earlier in the day, but earlier in the encounter with the President - - when he had been kissing my breasts, someone had come in, I think to tell him he had the phone call, or something like that.

Or someone had come in at some point and he stepped out of the of f ice, and I had put my bra and my sweater back

on. And he came in and sort of made a remark about me having done that. And --

QUESTION: Do you remember the remark?

A I think he smirked and he sort of said, you know, damn, you put your top back on, or something like that, Or, why did you do that, something like that. But he was smirking and joking with me.

But then when he went into the Oval, when Mr. Ickes came in, I put myself together and hurried out the back way through the dining room.

QUESTION: The next encounter, There's luckily a big gap there, The next one is February 29th. How was this encounter set up, and then what happened?

A Betty called me at work to tell me, or to invite me to the radio address for that evening. And so I went.

QUESTION: Did she say anything about that you would see the

1325

President on that date, or --

A Yes, I mean, she, she had indicated to me the President wanted me to come to this radio address, So that

-- and I knew that he had -- we had spoken earlier that month and the month before, and the month before that, and I knew he had a Christmas gift for me which he had yet to give me, So, it sort of seemed, it was understandable,

I went to the radio address, And then -- it was a very small group, maybe 10 people, six, 10 people, It was quite small. And after -- or when I went to go take my picture with him, he told me to go see Betty or go wait with Betty because he had something to give me, So, I went into Betty's office and was waiting there with her, There were some other people there, staff members. And I think I've gone through the whole - -

QUESTION: And you've actually testified in some detail about this before.

A Right.

QUESTION: So, actually, why don't we just go to the sexual encounter - -

A Okay.

QUESTION: - - and how the actual sexual part started?

A Once we were alone in the back office, he started to say something to me and I was pestering him to kiss me, because I hadn't -- we hadn't been alone in almost a year and

1326

-- well, I guess not a year, but it had been a long time since we had been alone. And so he, you know, he jokingly told me to, you know, just wait a sec. he wanted to give me my presents.

So, he gave me my hatpin and he sort of hurriedly put the Leaves Of Grass in my purse and he said, here, just take this with me. And then I said, what is it. I took the book out and so we, we were looking at it, end I was just, I thought it was pretty incredible, It was just a beautiful, beautiful book, and it meant a lot to me.

And then we went back over by the bathroom in the hallway, and we kissed. We were kissing and he unbuttoned my dress and fondled my breasts with my bra on, and then took them out of my bra end was kissing them and touching them with his hands end with his mouth,

And I continued to perform oral sex and then he pushed me sway, kind of as he always did before he came, and then I stood up end I said, you know, I really, I care about you so much; I really, I don't understand why you won't let

1327

me, you know, make you Come; it's important to me; I mean, it just doesn't feel complete, it doesn't seem right.

And so he -- we hugged. And, you know, he said he didn't want to get addicted to me, and he didn't want me to get addicted to him. And we were just sort of looking at each other end then, you know, he sort of, he looked at me, he said, okay. And so then I finished.

-Q

Q
A -

QUESTION: Did he touch your genitals at all during that occasion, do you remember?

A I think through my tights, but not direct genital.

QUESTION: Now did the meeting then end, or the encounter?

A We, well, we kissed after --

QUESTION: The ejaculation?

A Yes. And then I think Betty knocked on the door. So, I think - no, no, no: no, no, that's not right, because I fixed my lipstick. So, I think we sort of -- I think he said, oh, you've got to put yourself back together again. And so then I went end I got my lipstick and I put my lipstick back on, and then Betty knocked on the door.

QUESTION: The dress that you were wearing on this occasion, is that the blue dress from the Gap?

1328

A Unfortunately, yes.

QUESTION: And I think we've already gone into detail about the dress on that. The next encounter is March 29th, 1997. Would you tell us how that encounter was set up?

A It was, it was set up through my conversations with Betty.

QUESTION: Did you contact Betty?

A Yes. I contacted Betty and Betty -- my understanding was Betty spoke with the President, end then Betty got in touch with me and told me to come that afternoon, I did, I was waiting for the President in the back study and then he hobbled in because he was on crutches, And we were, we were in the back office. Actually, it was sort of an overcast day. It had been raining earlier. So, it was just sort of dark and overcast.

And we were, he was -- I think he had put his crutches down and he was kind of leaning on me, So, I was holding him, you know, I mean, sort of romantically but at the same time literally holding him. And - -

QUESTION: This is in the back study?

A Uh-huh. yes. And I was -- this was another one of those occasions when I was babbling on about something, and he just kissed me, kind of to shut me up, I think. And so we were kissing and then we sort of - - we turned around and he was leaning against -- he has a little, it's like a little

1329

table that I think has this stereo. I don't know if the stereo was always there. I know it was there later. But he was leaning against this little table a little bit just, I think, kind of for support.

And he unbuttoned my blouse end just sort of touched me over, Over my bra, And I don't think he took, I don't think he exposed my breasts that day. And we were, we were just kissing a lot.

And then he -- oh, he went to go put his hand down my pants, and then I unzipped them because it was easier. And I didn't have any panties on. And so he manually stimulated me.

QUESTION: Did he bring you to orgasm?

A Yes, four times.

-A
QUESTION: How did you end the contact with him on that

1330

occasion?

A End the sexual contact? Or --

QUESTION: The sexual contact?

A He - - oh, well, this was also the day that before, before I performed oral sex on him, I wanted him to touch my genitals with his genitals. And so we sort of had tried to do that, but because he's really tall and he couldn't bend because of his knee, it didn't really work.

QUESTION: And I think you've previously testified your genitals grazed each other - -
A Exactly.
Q - - on that occasion?
A I mean, just barely,
Q And when they grazed each other, neither of you had

clothes covering your genitals, is that right? A Correct,

QUESTION: How did you end the encounter completely that time, in terms of ending the meeting?

A Oh, we moved into the dining room and we were talking for a long time. I had brought some presents for him. So. we talked for awhile. And then Betty came back and the three of us were talking.

QUESTION: Let's move on to the next one, which is August 16th, 1997.

A I -- this was sort of his, his birthday, his

1331

birthday encounter. And so after -- I had set up in his back office, I had brought an apple square and put a candle and had put his birthday presents out. And after he came back in and I sang happy birthday and he got his presents, I asked him if we could, if we could share a birthday kiss in honor of our birthdays, because mine had been just a few weeks before, So, he said that that was okay and we could kind of bend the rules that day.

And so we, we, we kissed, And then I was touching him in his genital area through his shorts, and then I, I went to, to --

QUESTION: Perform oral sex?

A Yes, and he wouldn't let me.

QUESTION: Did he touch you on your genitals on that date?

A No.

QUESTION: Any other physical contact that is referred to as physical intimacy on that date?

A Not that I remember.

QUESTION: How did you end that encounter with him? Any discussion about sex during that encounter, or not having sex?

A No, just he got upset when I, you know, when be stopped me and he said, I'm trying to not do this and I'm trying to be good. And he, he got visibly upset. And so I, I hugged him and I told him I was sorry and not to be upset,

1332

and I was a little shocked, actually. I didn't -- he just seemed to get so emotionally upset about it. It seemed a little bit strange to me,

QUESTION: And he hadn't done that before?

A He had been emotionally visibly upset with me before, but not --

QUESTION: With regard to --

A Correct.

QUESTION: - - stopping you from having sex with him?

A Exactly.

QUESTION: Or having sexual contact with him? Is that correct?

A Yes.

QUESTION: And is that, other than any brief kiss, the last physically intimate contact that you've had with him?

A Well, our Christmas kiss was -- I mean, it was passionate. So.

QUESTION: Okay. It was --

A I don't call it a brief kiss.

QUESTION: That was a physically intimate kiss. Any other contact that would fall within the sexual relations definition --

A No.

QUESTION: -- that we've previously seen?

A I think we, you know, we would, we would joke with

1333

each other sexually. And so sometimes, you know, I might hit him on the butt, or he might hit me on the butt, but it wasn't -- not under the definition.

QUESTION: So, it wouldn't be a real intent to arouse, or not the physical touching that is described --

A No.

QUESTION: -- in the definition?

A No.

QUESTION: All right. Let's move on to another topic.

A Yea,

QUESTION: Thank you for your patience. I know that those are not easy questions to get to.

A It's just hard thinking my dad might see this.

QUESTION: Why don't we move to another emotional topic, July

4th, just briefly. Is now a good time to - -A Sure.

QUESTION: -- talk about that? Why don't you tell us -- I know that you've brought up in your grand jury testimony that July 4th of 1997 was an emotional day for you in connection with your relationship with the President,

A Yes.

QUESTION: Could you just briefly tell us what you meant by that and just a little bit about your meeting with him on that date?

A Our meeting had started out in, as a, in a fight.

1334

We -- and early on in this fight, I started crying, and then he -- we were in the back office and he came over and was hugging me and told me not to cry, to stop crying, and was very -- he was very sweet, and was very gentle.

And then we -- I -- there was a gardener outside. So, when I noticed the gardener, I pointed it out and we moved to the, into the hallway by the bathroom. And much of the discussion that day was he spent a lot of time talking to me, you know, about the kind of person he thought I was, and

-- I'm a little bit modest. So, it's sort of -- it's hard for me to get into all the things he said, But, there just --
Q Did he say wonderful things about you?
A He did.
Q Like what kinds of things?
A Just that he thought I was smart and beautiful, and,

that -- you know, but that a lot of it, it centered around my needing to learn to, to sort of squelch a bit of the fire in my belly. And that, you know, he said that people like us who, you know, have a tendency to get really angry and that there are a lot of other people that, that, that don't understand that and don't know how to handle that,

And he just - - he spent a lot of time talking to me. He was very, very -- he was the most affectionate with me he'd ever been. There wasn't a second when he wouldn't be

1335

touching me. whether it was holding my hand or stroking my arm or. you know, he'd kiss my neck at one point. It was just - - or he'd, you know, put his hands, he was running his hands through my hair and touching my face, And my bra strap kept falling down my shoulder, So, he kept pushing my bra strap up.

It was just very -- it was intense. It was just really emotionally intense,

And at one point, we, we had been talking about --I made some remarks to him about his relationship with Mrs. Clinton, And he, he remarked a little bit later than that that he wished he had more time for me, And so I said, well. maybe you will have more time in three years. And I was actually sort of thinking just when he wasn't President, he was going to have more time on his hands, And he said, well, I don't know, I might be alone in three years.

And then I said something about, you know, us sort of being together, I think I kind of said, oh, I think we'd be a good team, or something like that. And he, you know, he jokingly said, well, what are we going to do when I'm 75 and I have to pee 25 times a day. And I, you know, I told him That we'd deal with that. And it was -- there was just this incredible connection .

And I, I left that day sort of emotionally stunned, because I felt -- I was shocked. But I thought, I mean, he

1336

was - - I just knew he was in love with me, and from the way he acted that day, and that's not, it's not something that I would, that I would think easily. It's not a conclusion that I would come to easily at all. And it just -- with the kind of person I am.

And I knew I was in love with him, you know, a year before, and I thought he cared about me, But just the way he looked at me and touched me, and the things he said, it just

-- it was so obvious to me. And it was shocking. So, it was a bizarre day.

QUESTION: Anything else about the 4th?

A Not that I don't think I've gone over before.

QUESTION: Okay. We'll switch to a completely different topic. You previously testified that on December 17th --

A You know, I need a --

QUESTION: Do you want a break?

A I'd like just a break.

QUESTION: Sure, absolutely.

(Whereupon, the deposition was recessed from 1:57 p.m. until 2:07 p.m.)

BY MS. IMMERGUT:

QUESTION: Ma. Lewinsky, you are still under oath.

A Yes.

QUESTION: We are going to cover some other areas, hopefully quickly. You previously testified that on December 17th,

1337

during your phone call with the President -- and that's in

1997 --

A Yes.

QUESTION: -- when you were discussing various things, including that your name had appeared on the witness list, that the President told you that if you were ever subpoenaed that you should contact Betty?

A That's correct.

QUESTION: Did he ever tell you at that time that you should get a lawyer?

A I don't believe so. No,

QUESTION: When you say "I don't believe so", are you quite certain of that?

A I'm, I'm 99.9 percent certain.

QUESTION: What would you have done if he had told you that you should get a lawyer?

A I would have started to think about how I was going to get a lawyer and who I should get, and I didn't do that, So, that's what leads me to believe that he didn't say that.

QUESTION: Okay, Were you ever under the impression from anything that the President said that you should turn over all the gifts that he had given you to the Paula Jones attorneys?

A No.

QUESTION: Did you ever talk to the President about turning

1338

gifts over to the Jones lawyers before you were ever subpoenaed?

A No.

QUESTION: Did you actually ever talk to him about the fact that gifts could be subpoenaed prior to them actually being subpoenaed?

A No.

QUESTION: So, is it fair to say that the only time you talked about the gifts from the President, in connection with the subpoena, was on December 28th?

A That's correct.

QUESTION: Directing your attention to January 5th of 1998, when you had a telephone call with the President, you previously testified that you had some discussion about a book that you had purchased for him?

A Correct.

QUESTION: That was the book that you gave to Betty Currie on approximately January 4th to give to the President? Is that right?

A Yes,

QUESTION: What was the name of that book again? It was the book on the Presidents.

A It was a book about the Presidents of the United States .

QUESTION: Do you remember when you purchased that book?

1339

A I believe it was that weekend, the weekend prior to the 5th,

QUESTION: Did you ever talk to him, during your meeting of December 28th, 1997, about the fact that you were going to give him that book?
A No.
Q Now do you know that you didn't?
A Because I hadn't purchased the book yet.
Q Had you even thought about purchasing that

particular book?

A No. It was bought on the spur of the moment.

QUESTION: Do you remember where you bought it?

A At a little bookstore in Georgetown, an antique book store.

QUESTION: I'm going to switch topics again. Do you believe that if you hadn't had a sexual relationship with the President that you would have kept your job at the White House?

A Yes,

QUESTION: Do you believe that, your difficulty or inability to return to employment at the White House was because of your sexual relationship with him?

A Yes. Or the issues that, or the problems that people perceived that really were based in truth because I had a relationship with the President. But, however, some of

1340

the people who worked there chose to, to see some of my behavior. Does that make sense?

QUESTION: What do you mean by that?

A I think that -- I've always felt that some of the, some of the staffers there, particularly Evelyn Lieberman and those who worked with her to move me out of the White House, instead - - looked at my behavior only, instead of looking at the President's behavior, and instead of necessarily thinking that I had a relationship with the President. : were just looking at it thinking I was trying to have a relationship with the President when I already was having a relationship
with him, They turned a blind eye to his actions.

QUESTION: During 199?, did you feel that the President owed you something with respect to a job?
A I did, because he, he had promised me on April 7th

of '96 that he would bring me back when, if he won in November. And I had - - when he first told me that, I had had some hope and I didn't, I didn't even know if I was going to hear from him again after I left. And then when he continued to call me frequently during the campaign period, it led me to believe he would bring me back.

And then after we had a - - it was after a period when he didn't call me and I wasn't sure about things, what was happening -- I'm sorry. I'm not being clear.

Because he had sort of led me to believe that he

1341

was going to bring me back and was constantly reassuring that, I, I believe that he did owe that to me. Versus him having said, I'm really sorry -- let's just say in April of '96 -- I'm really sorry that this happened, there's not, you know, there's nothing I can do, and left it at that, Then I wouldn't have felt that he owed me anything.

QUESTION: What about the fact that you had gone quietly and not revealed your relationship? Did that have anything to do with your feeling that you were entitled to something?

A It did later on. I, I would have gone quietly anyway, because that - - it was never, ever, ever my intention for this relationship to ever become public. And -- but I had felt that after having left quietly, after having been sort of maybe strung along throughout the campaign and then even way into 1997, that I had felt -- and him promising me that he'd bring me back and constantly enumerating the different steps he was trying to take to do that -- that, yes, I did feel at that point he, he certainly owed me.

QUESTION: Is that part of your letter of July 3rd to the President in 1997, where you described it previously as threatening to disclose the relationship, at least to your parents, was that part of your feeling that --

A It was never really a, a, maybe a -- it was never really a threat, because I never really was going to do that. While I had disclosed a portion of the relationship to my

1342

mom, I never had any intention of telling my dad. There's no way of that.

And what I really was trying to do was trying to, in a circuitous manner, remind him that I had been a good girl, and that I hadn't, you know, disclosed this information, and that really, you know, he'd promised me he was going to do something. And I had told my parents, I had told my dad that I was coming back after the election.

QUESTION: I'd like to focus now just very briefly on your dealings with Ambassador Richardson with regard to the U.N. job .

A Yes,

QUESTION: How many times did Ambassador Richardson call you directly, do you remember?

A Do you mean someone from his - - he never directly picked up the phone and dialed my phone number.
Q Let me ask a different question.
A Okay.
Q How many times did you speak to him personally?
A I believe twice.
Q And when I say personally, on the telephone?
A Yes.
Q How do you know that you actually spoke with him on

those occasions?

A Well, the first time I spoke with him I remember,

1343

63'

because I was shocked and I was, I was very nervous. And --QUESTION: Because the Ambassador was on the phone?

A Exactly. And the second, the second time I actually hadn't really remembered, I wasn't sure. And then through documentation I was shown, it, it led me to believe that I had, in fact, spoken to him on the phone.

QUESTION: But you are positive at least one time you did, in fact, speak to him personally?

A Yes.

QUESTION: Do you remember which occasion that was, or when that occurred?

A Yes, it was sometime in October.

QUESTION: Was that the October 23rd call? Does that sound right?

A Yes.

QUESTION: And that's prior to your actual interview with him?

A Correct.

QUESTION: I'd like to just ask you very briefly about your conversation with the President the night before your interview with Ambassador Richardson for the U.N. job. Could you describe who initiated that call and what the substance of the call was?

A I had -- well, I had requested through Betty that the President call me, because I was really nervous about my interview and meeting with Ambassador Richardson. I just, I

1344

didn't, I didn't want to make anyone look bad, I didn't want to sound like a fool, or -- so, the President called me and we talked about some of the different issues at the U.N., and he gave me some suggestions of things I could say. But I think he may have also done that the previous week, too.

QUESTION: Do you remember him giving you sort of a job pep talk on --
A Yes.
Q --the 30th?
A Yes.
Q Why would you describe it as a pep talk?
A Because I was nervous. So, he, he was trying to

kind of build my confidence and reassure me, you know, reassure me that I was an intelligent person, and that I had a lot to offer and that they would be happy to have me there.

QUESTION: At some point, did you tell the President that you got an offer from the U.N.?

A I believe so,

QUESTION: Did you tell Betty also that you had gotten an offer?

A Yes,

QUESTION: Do you remember any details about talking to Betty about it, or how you let her know?

A I, I remember calling Betty after the interview and telling her that it had gone much better than I had expected

1345

it would, and that I was really, that I was, that I was somewhat more interested after having met the Ambassador than I was prior to the interview. And other than that, I don't really,

QUESTION: What about details about your conversation with the President telling him that you had gotten the job?

A I vaguely remember it being in context, I think, of sort of trying to press him on getting in touch with Mr. Jordan .
Q In terms of getting other jobs - -
A Exactly.
Q - - you let him know this?
A Exactly.
Q That you had an offer from the U.N.?
A Right.
Q Do you remember when you got the U.N. offer?
A No.
Q Was it sometime, in relation to your interview with

the Ambassador - -
A It was sooner, rather than later.
Q So, sometime within a matter of a week or --
A I believe so.
Q - - some weeks?
A Somewhere within a couple, within the next two

weeks or so.

1346

QUESTION: And did they tell you that they would leave the job open until a certain time, for you to make the decision if you wanted it?

A Not at the point when I got the offer. I, I -- and actually I think, thinking now I'm a little bit more clearer that I did speak with the Ambassador, that he was the one who, who extended the offer to me, because I remember being nervous and not knowing what to say to him, because I didn't really want the job. And so I sort of just "yessed' him along and thanked him profusely, and told him I was excited about it.

And then I later spoke, I believe, with Mona Sutphen, and sort of relayed to her that I was interested in also trying to feel out the private sector. So, and I believe it was at that point that she said, well, let's keep in touch, We can -- this position, I think, had been open f or awhile. So.

QUESTION: Did she give you any timeframe at all about how long they would wait for you to make a decision?

A It was -- I think we talked about talking maybe in a few weeks, and then at some point we said, let's get in touch around the first of January. And I was under the impression that, you know, I believed that they would hold the position open for me, but that it didn't necessarily --

QUESTION: It's not a guarantee?

1347

A Exactly.

QUESTION: But they weren't rushing you to make an immediate decision?

A No.

QUESTION: So, you understand you basically had some leeway until January 1998 to make a decision?

A Correct.

QUESTION: January 16th, 1998, Ritz Carlton night. I really have just one question about it, which was, was there a time that you, in fact, during the course of the evening, that you, in fact, did leave the prosecutors and agents by yourself?

A Yes, when I was given, finally given permission to go call my mom, I wasn't comfortable using the phone in the room .
Q So, you went out by yourself to --
A Yes, I did,
Q Where did you go make a phone call?
A To Nordstrom's.
Q And--
A It was just one phone call, to my mother. And

there was also a time -- I think one of the prosecutors came with me, I think it was Stephen Bin --

QUESTION: Binhak?

A -- I think, came downstairs with me. I used -- I

1348

needed to return a phone call from a page. And then when I was with Mr. Emmick and Agent they let me go to the bathroom in Macy's by myself.

QUESTION: Were you in Macy's for some time by yourself?

A Well, it, it took awhile to find a bathroom. It was kind of far away. So,

QUESTION: So, they didn't follow you into the bathroom?

A They didn't follow me in. But then when I came

back, Agent had gone looking for me. So,

QUESTION: And just with respect to the phone call to call your mother, no one accompanied you for that, is that right?

A No,

QUESTION: And finally --

A I just, I do want to state that I did -- because I know this sort of goes to this issue of being, you know, kind of told, oh, you're free to leave whenever you want, that I didn't really -- I didn't feel at any point that I could leave whenever I wanted, that I could -- that I was afraid that if I had left the Mall, I would be arrested and put in jail. So, that was my impression.

QUESTION: One last question from me. Do you, for any reason now, want to hurt the President?

A No, I'm, I'm upset with him right now, but I, no, that's the last thing in the world I want to do.

MS. IMMERGUT: That's all I have,

1349

MS. WIRTH: I just have one question.

BY MS. WIRTH:

QUESTION: From your grand jury testimony last week, on August

20th, 1998, you were talking about your understanding of the

President's testimony. I'm just going to read a portion of

your testimony to you and ask you a question about that.

This is in response to a question from a juror.

You said, "I'm sorry. I'm sorry. It's -- from my understanding about what he testified to on Monday, not - -just from the press accounts, is that this was a -- that this was a service contract, that all I did was perform oral sex on him and that that's all that this relationship was, And it was a lot more than that to me and I thought it was a lot more than that."

And the answer continues a little bit more after that .

The question I have for you is that when you mentioned your understanding of what the President testified to on the previous Monday, from what did you derive your understanding of what the President's testimony was?

A From the press accounts I had read,

QUESTION: Okay. No one from this office divulged to you anything that the President said during his testimony, did they?

A Absolutely not,

1350

MR. WIRTH: Thank you.

MS. IMMERGUT: Nothing further. Do you have any questions?

THE WITNESS: No.

(Whereupon, at 2:24 p.m., the proceedings were concluded.)

CERTIFICATE OF COURT REPORTER - NOTARY PUBLIC

I, Elizabeth A. Eastman, the officer before whom the foregoing deposition was taken, do hereby certify that the witness whose testimony appears in the foregoing deposition was duly sworn by me; that the testimony of said witness was taken by me electronically and thereafter reduced to typewriting by me; that said deposition is a true record of the testimony given by said witness; that I am neither counsel for, related to, nor employed by any of the parties to the action in which this deposition was taken; and, further, that I am not a relative or employee of any attorney or counsel employed by the parties hereto, nor financially or otherwise interested in the outcome of the action.

NOTARY PUBLIC FOR THE
DISTRICT OF COLUMBIA
My Commission Expires: July 31, 2000

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