VIII. There is substantial and credible information that the President lied
under oath in describing his conversations with Vernon Jordan about Ms.
Lewinsky. 
A. President's Testimony in the Jones Case
B. Evidence That Contradicts the President's Civil Deposition
C. Summary

IX. There is substantial and credible information that President Clinton
endeavored to obstruct justice by attempting to influence the testimony of
Betty Currie. 
A. Evidence
1. Saturday, January 17, 1998, Deposition
2. Sunday, January 18, 1998, Meeting with Ms. Currie
3. Conversation Between the President and Ms. Currie on Tuesday, January
20, 1998, or Wednesday, January 21, 1998. 
B. The President's Grand Jury Testimony
C. Summary

X. There is substantial and credible information that President Clinton
endeavored to obstruct justice during the federal grand jury investigation.
While refusing to testify for seven months, he simultaneously lied to
potential grand jury witnesses knowing that they would relay the falsehoods
to the grand jury. 
A. The Testimony of Current and Former Aides
1. John Podesta
2. Erskine Bowles
3. Sidney Blumenthal
4. Harold Ickes
B. The President's Grand Jury Testimony
C. Summary 

XI. There is substantial and credible information that President Clinton's
actions since January 17, 1998, regarding his relationship with Monica
Lewinsky have been inconsistent with the President's constitutional duty to
faithfully execute the laws. 
A. Beginning on January 21, 1998, the President misled the American people
and Congress regarding the truth of his relationship with Ms. Lewinsky.
B. The First Lady, the Cabinet, the President's staff, and the President's
associates relied on and publicly emphasized the President's denial. 
C. The President repeatedly and unlawfully invoked the Executive Privilege
to conceal evidence of his personal misconduct from the grand jury. 
D. The President refused six invitations to testify to the grand jury,
thereby delaying expeditious resolution of this matter, and then refused to
answer relevant questions before the grand jury when he testified in August
1998. 
E. The President misled the American people and the Congress in his public
statement on August 17, 1998, when he stated that his answers at his civil
deposition in January had been "legally accurate." 
F. Summary
End Page

Key Dates




November 1992 William Jefferson Clinton elected President of the United
States 

May 1994 Paula Jones files lawsuit against President Clinton 

July 1995 Monica S. Lewinsky begins White House internship 

November 15, 1995 President begins sexual relationship with Lewinsky 

April 5, 1996 Lewinsky transferred from White House to Pentagon 

November 1996 President Clinton reelected 

March 29, 1997 Last intimate contact between President and Monica Lewinsky 

December 5, 1997 Lewinsky appears on Jones Witness List 

December 19, 1997 Lewinsky served with subpoena to appear at deposition and
produce gifts from President Clinton 

December 24, 1998 Lewinsky's last day of work at the Pentagon 

December 28, 1997 Lewinsky meets with the President and receives gifts;
later gives box of gifts from the President to Betty Currie. 

January 7, 1998 Lewinsky signs affidavit intended for filing in Jones case. 

January 13, 1998 Lewinsky accepts job offer at Revlon in New York 

January 16, 1998 Special Division appoints Independent Counsel Kenneth W.
Starr to investigate Lewinsky matter 

January 17, 1998 President deposed in Jones case 

January 18, 1998 President meets with Betty Currie to discuss President's
deposition 

January 21, 1998 Lewinsky matter reported in press; President denies
allegations of a sexual relationship and of suborning perjury 

April 1, 1998 Judge Wright grants summary judgment for President Clinton in
the Jones litigation 

July 17, 1998 President served with grand jury subpoena, later withdrawn in
return for testimony 

July 28, 1998 Immunity/Cooperation Agreement reached between Lewinsky and
OIC 

August 17, 1998 President testifies before the grand jury; later he
publicly acknowledges improper relationship 

September 9, 1998 OIC submits Referral to Congress pursuant to 28 U.S.C. §
595(c) 



Table of Names




The Principals 

William Jefferson Clinton President of the United States 

Paula Corbin Jones Plaintiff in a civil suit against President Clinton 

Monica Lewinsky Former White House Intern and Employee 

Betty Currie Personal Secretary to the President 

Vernon Jordan Friend of President Clinton, 
and Partner at Law Firm of 
Akin, Gump, Strauss, Hauer & 
Feld 

The First Family 

Hillary Rodham Clinton First Lady of the United States 

Chelsea Clinton Daughter of the President and First Lady 



Presidential Aides/Advisors/Assistants 

Madeline Albright Secretary of State 

Sidney Blumenthal Assistant to the President 

Erskine Bowles White House Chief of Staff 

Lanny Bruer Special Counsel to the 
President 

Stephen Goodin Aide to President Clinton 

Nancy Hernreich Deputy Assistant to the 
President and Director of 
Oval Office Operations 



John Hilley Assistant to the President and 
Director of Legislative 
Affairs; Monica Lewinsky's 
Supervisor 

Harold Ickes Former Deputy Chief of Staff 

Janis Kearney Special Assistant to the President and Records Manager 

Timothy Keating Special Assistant to the 
President and Staff Director 
for Legislative Affairs; Monica Lewinsky's Immediate 
Supervisor 

Ann Lewis Director, White House 
Communications 

Evelyn Lieberman Former Deputy Chief of Staff 

Bruce Lindsey Deputy White House Counsel 

Sylvia Mathews Deputy White House Chief of 
Staff 

Thomas "Mack" McLarty Former White House Chief of 
Staff 

Cheryl Mills Deputy White House Counsel 

Dick Morris Former Advisor to President Clinton 

Bob Nash Assistant to the President and 
Director of Presidential 
Personnel 

Leon Panetta Former White House Chief of Staff 

John Podesta Deputy White House Chief of 
Staff 

Hon. Bill Richardson U.S. Ambassador to the United 
Nations 

Charles Ruff White House Counsel 

Marsha Scott Deputy Director of Personnel 

George Stephanopoulous Former Senior Advisor for 
Policy and Strategy 

Barry Toiv Deputy White House Press Secretary 



Other White House Personnel 

Karin Joyce Abramson Former Director of the White House Intern Program 

Caroline Badinelli Former White House Intern 

Douglas Band Former White House Intern 

Tracy Anne Bobowick Former White House Employee, 
Correspondence Office 

Laura Capps Former White House Intern 

Jay Footlik Former Employee of the Office of Presidential Personnel 

Patrick Griffin Former Assistant to the 
President and Director of 
Legislative Affairs 

George Hannie White House Butler 

Jocelyn Jolley Former Director of Congressional Correspondence 
in the White House 

Maureen Lewis Former White House Employee, 
Correspondence Office 

Glen Maes White House Steward to 
President Clinton 

Bayani Nelvis White House Steward to 
President Clinton 

Charles O'Malley White House Operations Deputy 
Chief 

Jennifer Palmieri Former Special Assistant to the Chief of Staff 

Debra Schiff Receptionist, West Wing Lobby 



Jamie Beth Schwartz Former Special Assistant to 
the Social Secretary in the White House Social Office 

Patsy Thomasson Director of the Office ofAdministration, Executive Office
of the President 

Kathleen Willey Former White House Volunteer 

Michael Williams Former White House Intern 



Department of Defense Employees 

Kenneth Bacon Assistant Secretary of Defense 
for Public Affairs; Monica 
Lewinsky's Pentagon Supervisor 

Elizabeth Bailey Special Assistant to the 
Secretary of Defense for White 
House Liaison 

Clifford Bernath Former Deputy to Assistant 
Secretary of Defense for 
Public Affairs 

Donna Boltz Assistant in the Office of the 
Assistant Secretary of Defense 
for Public Affairs 

Jeremy "Mike" Boorda Admiral, United States Navy (deceased) 

Richard Bridges Colonel, Director for Defense 
Information 

Rebecca Cooper Chief of Staff, United States 
Mission to the United Nations 

Monica Ramirez Cranick Sergeant, Broadcast Engineer, 
Office of the Secretary of 
Defense for Public Affairs 

Marsha Dimel Administrative Support 
Specialist for Personnel and 
Administration in the National 
Security Council 



Charles Duncan Former Special Assistant to 
the Secretary of Defense for 
Public Affairs 

Kate Friedrich Special Assistant, National 
Security Advisor 

Jeff Gradick Commander, Military Assistant 
to the Deputy Assistant to the 
Assistant Secretary of Defense 
for Public Affairs 

James Graybeal Lt. Commander, Military 
Assistant to the Deputy 
Assistant to the Assistant 
Secretary of Defense for 
Public Affairs 

Mark Huffman Office Manager, Office of 
Public Affairs, United States 
Department of Defense 

Jodi Kessinger Former Administrative 
Assistant, Office of the 
National Security Advisor, 
National Security Council 

Janet Reno Attorney General of the United 
States 

Darby Ellen Stott Special Assistant, White House 
Press Secretary 

Mona Sutphen Special Assistant to the 
United States Ambassador to 
the United Nations 

Robert Tyrer Chief of Staff for the 
Secretary of Defense 

Isabelle Watkins Executive Assistant to Bill 
Richardson 



Monica Lewinsky's Friends/Family/Acquaintances 

Andrew Bleiler Former Boyfriend of Monica 
Lewinsky 

Catherine Allday Davis Friend of Monica Lewinky 

Kelly Lynn Davis Friend of Monica Lewinsky 

Neysa Erbland Friend of Monica Lewinsky 

Kathleen Estep Counselor to Monica Lewinsky 

Deborah Finerman Aunt of Monica Lewinsky 

David Grobanie Owner of Briarwood Bookstore 

Dr. Irene Kassorla Therapist to Monica Lewinsky 

Walter Kaye Family friend of Monica 
Lewinsky 

Marcia Lewis Mother of Monica Lewinsky 

Ashley Raines Friend of Monica Lewinsky and 
White House Director of Office and Policy Development 
Operations and Special Liaison 

Peter Strauss Husband of Marcia Lewis 

Linda Tripp Friend of Monica Lewinsky 

Natalie Rose Ungvari Friend of Monica Lewinsky 

Dale Young Family friend of Monica 
Lewinsky 



Monica Lewinsky's New York Employment Contacts 

Celia Berk Managing Director of Human 
Resources at Burson-Marstellar 

Ursula Fairbairn Executive Vice President, 
Human Resources and Quality of 
American Express 

Peter Georgescu Chairman and Chief Executive 
Officer at Young & Rubicam 

Richard Halerpin Executive Vice President and 
Special Counsel to the 
President of Revlon 

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