3. Ms. Lewinsky's Confidants 
Between 1995 and 1998, Ms. Lewinsky confided in 11 people about her
relationship with the President. All have been questioned by the OIC, most
before a federal grand jury: Andrew Bleiler, Catherine Allday Davis, Neysa
Erbland, Kathleen Estep, Deborah Finerman, Dr. Irene Kassorla, Marcia
Lewis, Ashley Raines, Linda Tripp, Natalie Ungvari, and Dale Young.(12) Ms.
Lewinsky told most of these confidants about events in her relationship
with the President as they occurred, sometimes in considerable detail. 
Some of Ms. Lewinsky's statements about the relationship were
contemporaneously memorialized. These include deleted email recovered from
her home computer and her Pentagon computer, email messages retained by two
of the recipients, tape recordings of some of Ms. Lewinsky's conversations
with Ms. Tripp, and notes taken by Ms. Tripp during some of their
conversations. The Tripp notes, which have been extensively corroborated,
refer specifically to places, dates, and times of physical contacts between
the President and Ms. Lewinsky.(13) 
Everyone in whom Ms. Lewinsky confided in detail believed she was telling
the truth about her relationship with the President. Ms. Lewinsky told her
psychologist, Dr. Irene Kassorla, about the affair shortly after it began.
Thereafter, she related details of sexual encounters soon after they
occurred (sometimes calling from her White House office).(14) Ms. Lewinsky
showed no indications of delusional thinking, according to Dr. Kassorla,
and Dr. Kassorla had no doubts whatsoever about the truth of what Ms.
Lewinsky told her.(15) Ms. Lewinsky's friend Catherine Allday Davis
testified that she believed Ms. Lewinsky's accounts of the sexual
relationship with the President because "I trusted in the way she had
confided in me on other things in her life. . . . I just trusted the
relationship, so I trusted her."(16) Dale Young, a friend in whom Ms.
Lewinsky confided starting in mid-1996, testified: 
[I]f she was going to lie to me, she would have said to me, "Oh, he calls
me all the time. He does wonderful things. He can't wait to see me." . . .
[S]he would have embellished the story. You know, she wouldn't be telling
me, "He told me he'd call me, I waited home all weekend and I didn't do
anything and he didn't call and then he didn't call for two weeks."(17) 

4. Documents 
In addition to her remarks and email to friends, Ms. Lewinsky wrote a
number of documents, including letters and draft letters to the President.
Among these documents are (i) papers found in a consensual search of her
apartment; (ii) papers that Ms. Lewinsky turned over pursuant to her
cooperation agreement, including a calendar with dates circled when she met
or talked by telephone with the President in 1996 and 1997; and (iii) files
recovered from Ms. Lewinsky's computers at home and at the Pentagon. 
5. Consistency and Corroboration 
The details of Ms. Lewinsky's many statements have been checked, cross-
checked, and corroborated. When negotiations with Ms. Lewinsky in January
and February 1998 did not culminate in an agreement, the OIC proceeded with
a comprehensive investigation, which generated a great deal of probative
evidence. 
In July and August 1998, circumstances brought more direct and compelling
evidence to the investigation. After the courts rejected a novel privilege
claim, Secret Service officers and agents testified about their
observations of the President and Ms. Lewinsky in the White House. Ms.
Lewinsky agreed to submit to a proffer interview (previous negotiations had
deadlocked over her refusal to do so), and, after assessing her credibility
in that session, the OIC entered into a cooperation agreement with her.
Pursuant to the cooperation agreement, Ms. Lewinsky turned over the dress
that proved to bear traces of the President's semen. And the President, who
had spurned six invitations to testify, finally agreed to provide his
account to the grand jury. In that sworn testimony, he acknowledged
"inappropriate intimate contact" with Ms. Lewinsky. 
Because of the fashion in which the investigation had unfolded, in sum, a
massive quantity of evidence was available to test and verify Ms.
Lewinsky's statements during her proffer interview and her later
cooperation. Consequently, Ms. Lewinsky's statements have been corroborated
to a remarkable degree. Her detailed statements to the grand jury and the
OIC in 1998 are consistent with statements to her confidants dating back to
1995, documents that she created, and physical evidence.(18) Moreover, her
accounts generally match the testimony of White House staff members; the
testimony of Secret Service agents and officers; and White House records
showing Ms. Lewinsky's entries and exits, the President's whereabouts, and
the President's telephone calls. 



C. Sexual Contacts 
1. The President's Accounts 
a. Jones Testimony 
In the Jones deposition on January 17, 1998, the President denied having
had "a sexual affair," "sexual relations," or "a sexual relationship" with
Ms. Lewinsky.(19) He noted that "[t]here are no curtains on the Oval
Office, there are no curtains on my private office, there are no curtains
or blinds that can close [on] the windows in my private dining room," and
added: "I have done everything I could to avoid the kind of questions you
are asking me here today. . . ."(20) 
During the deposition, the President's attorney, Robert Bennett, sought to
limit questioning about Ms. Lewinsky. Mr. Bennett told Judge Susan Webber
Wright that Ms. Lewinsky had executed "an affidavit which [Ms. Jones's
lawyers] are in possession of saying that there is absolutely no sex of any
kind in any manner, shape or form, with President Clinton." In a subsequent
colloquy with Judge Wright, Mr. Bennett declared that as a result of
"preparation of [President Clinton] for this deposition, the witness is
fully aware of Ms. Lewinsky's affidavit."(21) The President did not dispute
his legal representative's assertion that the President and Ms. Lewinsky
had had "absolutely no sex of any kind in any manner, shape or form," nor
did he dispute the implication that Ms. Lewinsky's affidavit, in denying "a
sexual relationship," meant that there was "absolutely no sex of any kind
in any manner, shape or form." In subsequent questioning by his attorney,
President Clinton testified under oath that Ms. Lewinsky's affidavit was
"absolutely true."(22) 
b. Grand Jury Testimony 
Testifying before the grand jury on August 17, 1998, seven months after his
Jones deposition, the President acknowledged "inappropriate intimate
contact" with Ms. Lewinsky but maintained that his January deposition
testimony was accurate.(23) In his account, "what began as a friendship
[with Ms. Lewinsky] came to include this conduct."(24) He said he
remembered "meeting her, or having my first real conversation with her
during the government shutdown in November of '95." According to the
President, the inappropriate contact occurred later (after Ms. Lewinsky's
internship had ended), "in early 1996 and once in early 1997."(25) 
The President refused to answer questions about the precise nature of his
intimate contacts with Ms. Lewinsky, but he did explain his earlier
denials.(26) As to his denial in the Jones deposition that he and Ms.
Lewinsky had had a "sexual relationship," the President maintained that
there can be no sexual relationship without sexual intercourse, regardless
of what other sexual activities may transpire. He stated that "most
ordinary Americans" would embrace this distinction.(27) 
The President also maintained that none of his sexual contacts with Ms.
Lewinsky constituted "sexual relations" within a specific definition used
in the Jones deposition.(28) Under that definition: 
[A] person engages in "sexual relations" when the person knowingly engages
in or causes -- (1) 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 . . . . "Contact" means intentional touching,
either directly or through clothing.(29) 

According to what the President testified was his understanding, this
definition "covers contact by the person being deposed with the enumerated
areas, if the contact is done with an intent to arouse or gratify," but it
does not cover oral sex performed on the person being deposed.(30) He
testified: 
[I]f the deponent is the person who has oral sex performed on him, then the
contact is with -- not with anything on that list, but with the lips of
another person. It seems to be self-evident that that's what it is. . . .
Let me remind you, sir, I read this carefully.(31) 

In the President's view, "any person, reasonable person" would recognize
that oral sex performed on the deponent falls outside the definition.(32) 
If Ms. Lewinsky performed oral sex on the President, then -- under this
interpretation -- she engaged in sexual relations but he did not. The
President refused to answer whether Ms. Lewinsky in fact had performed oral
sex on him.(33) He did testify that direct contact with Ms. Lewinsky's
breasts or genitalia would fall within the definition, and he denied having
had any such contact.(34) 


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