Volume VI: Document Supplement, Part D, Documents Cited in Referral: Tabs 47-83, Bates Numbers 812-968

2207

Volume VI: Document Supplement, Part D

Documents Cited in Referral: Tabs 47- 83, Bates Numbers 8 12- 968

REFERRAL

TOTHE

UNITED STATES HOUSE OF REPRESENTATIVES

PURSUANTTO

TITLE 28, UNITED STATES CODE, 8 595( c)

DOCUMENT SUPPLEMENT D

SUBMITTEDBY

THE OFFICE OF THE INDEPENDENT COUNSEL

SEPTEMBER~, 1998

2209

Index

2210

INDEX: Documents cited in the 595( c) Referral

09- Sep- 98

Bates # or Tab# Production Name Description

*Tab 00 1 *Tab 002 *Tab 003 *Tab 004 *Tab 005 *Tab 006 *Tab 007 *Tab 008 *Tab 009 *Tab 010 *Tab 011 *Tab 012 *Tab 013 *Tab 014 *Tab 015 *Tab 016 *Tab 017

*Tab 018 N/ A *Tab 019 N/ A *Tab 020 N/ A *Tab 02 1 N/ A *Tab 022 N/ A *Tab 023 N/ A

N/ A N/ A N/ A

N/ A N/ A N/ A N/ A N/ A N/ A

N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A

Main Stairway to Family Quarters Movie Theater in East Colonnade I l/ 14/ 95 LA Times news article 1 l/ 14/ 95 Washington Post news article 1 l/ l 6/ 95: Facts on File, World News Digest -- pg. 852 1 l/ 1 6/ 95 Washington Post news article I l/ l 7/ 95 USA Today news article I l/ 20/ 95 Washington Post news article I l/ 23/ 95: Facts on File, World News Digest -- pg. 868 2/ 19/ 96 Weekly Compilation of Presidential Documents 2/ 28/ 96 Newsday news article 7/ 4/ 97 Drudge Report Final 8/ l l/ 97 Washington Post news article 8/ l l/ 97 Newsweek article 9/ l 3/ 97 NY Times news article 9122197 Forbes news article 1 O/ 4/ 97 to 1 O/ 23/ 97 Digest of Other White House Announcements I l/ 9/ 97 LA Times news article 1 l/ 14/ 97 Baltimore Sun news article I l/ l 5/ 97 Washington Post news article l/ 20/ 98 subpoena to William Jefferson Clinton, VO02 1 I2 l/ 98 Washington Post news article l/ 2 l/ 98 “The News Hour with Jim Lehrer”

Bates # or Tab# Production Name DescMtion

*Tab 024 *Tab 025 *Tab 025A *Tab 026 *Tab 027 *Tab 028 *Tab 029 *Tab 030 *Tab 030A *Tab 03 1 *Tab 032 I *Tab 033

*Tab 034 *Tab 035 *Tab 036 *Tab 036A *Tab 036B *Tab 037 *Tab 038 *Tab 039 *Tab 040 *Tab 04 1 *Tab 042

*Tab 043 *Tab 044 *Tab 045

N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A N/ A

N/ A N/ A N/ A N/ A N/ A

N/ A

N/ A N/ A

N/ A

N/ A N/ A N/ A

N/ A

N/ A 3125198 Washington Post news article N/ A 4/ l 7/ 98 letter to DAG Eric Holder from the OK

N/ A 6198 California Lawyer article l/ 21/ 98 “All Things Considered”

l/ 2 l/ 98 White House Briefing l/ 2 l/ 98 Excerpts of Telephone Interview of Clinton by Roll Call l/ 22/ 98 Remarks by President Clinton at the White House

1122198 America Online article l/ 22/ 98 FBI Receipt of Property l/ 22/ 98 ABC News Special Report with Peter Jennings l/ 22/ 98 Roll Call interview with William Jefferson Clinton

l/ 22/ 98 Seatle Times news article

l/ 23/ 98 FBI Receipt of Property, w/ attached letter l/ 24/ 98 CBS News Show: Saturday Morning

l/ 25/ 98 Face the Nation I /26/ 98 Nightline l/ 26/ 98 ABC News Special Report with Peter Jennings l/ 26/ 98 White House Education News Conference l/ 27/ 98 AP news article l/ 27/ 98 NBC: The Today Show

2/ 5/ 98 Remarks by President Clinton 2/ 6/ 98 Joint News Conference with President Clinton

2114198 Washington Post news article 2/ l 7198 Chicago Tribune news article

315198 closed hearing transcript excerpt

3/ 17/ 98 Memoradum w/ attachments, In re: Grand Jury Proceedings

Production Name

N/ A N/ A

N/ A

N/ A N/ A

N/ A N/ A N/ A

N/ A

N/ A N/ A N/ A

N/ A

N/ A N/ A N/ A N/ A

N/ A N/ A

N/ A N/ A N/ A N/ A N/ A

Bates # or Tab#

*Tab 046 *Tab 047 *Tab 048 *Tab 049 *Tab 050 *Tab 05 1 *Tab 052 *Tab 053 *Tab 054 *Tab 055 *Tab 056 *Tab 057 *Tab 058 *Tab 059 *Tab 060 *Tab 06 1 *Tab 062 *Tab 063 *Tab 064 *Tab 065 *Tab 066 *Tab 067 *Tab 068 *Tab 069 *Tab 070 *Tab 07 1 *Tab 072

Description

6/ l 5198 Brief of Appellant William J. Clinton

6129198 US News & World Report news article

7/ l 5198 letter to IC Smaltz from Richard Rogers ’ 7/ l 7198 subpoena to the White House, D14 15

7122198 CBS News transcript, HARDBALL

7126198 NBC News Meet the Press 7128198 Motion of William J. Clinton for Continuance 7128198 Transcript of Status Hearing , In re: Motion to Continue 7129198 FBI Receipt of Property 713 II98 letter to David Kendall from Bob Bittman

713 II98 letter to Bob Bittman from David Kendall 713 l/ 98 letter to David Kendall from Bob Bittman

813198 letter to Bob Bittman from David Kendall

813198 letter to David Kendall from Bob Bittman

813198 FBI Laboratory Report

813198 FBI 302 813198 letter to Judge Starr from DAG Eric Holder

816198 letter to AG Reno from IC Smaltz

816198 FBI Laboratory Report

817198 Washington Times news article

8/ l 0198 Newsweek article 8/ l II98 letter to AG Holder from Judge Starr

811 II98 Memorandum Order, In re: Grand Jury Proceedings

8/ l 3198 NY Times news article

8113198 USA Today news article

8/ l 3198 Washington Post news article

8113198 Washington Times news article

Bates # or Tab# Production Name Deschtion

*Tab 073 *Tab 074 *Tab 075 *Tab 076 *Tab 077 *Tab 078 *Tab 079 *Tab 080 *Tab 08 1 *Tab 082 *Tab 083 08 12- DC- 00000002 0824- DC- 0000000 1 to 2 0824- DC- 000000 13 0824- DC- 000000 I4 0827- DC- 00000002 to 18 0828- DC- 00000003 0828- DC- 00000004 0828- DC- 000000 12 0828- DC- 000000 13 0828- DC- 00000023 083& DC- 00000007 0830- DC- 00000017 083 1 -DC- 00000008 to 11 0832- DC- 00000004 to 5 083% DC- 00000980 083% DC- 00001070

N/ A N/ A

N/ A

N/ A N/ A

N/ A N/ A N/ A

N/ A N/ A

N/ A

Lewinsky, Monica Currie, Betty Currie, Betty Currie, Betty United States Secret Service US Mission to the UN US Mission to the UN US Mission to the UN US Mission to the UN US Mission to the UN Revlon Group, Inc. Revlon Group, Inc. Pagemart McAndrews & Forbes Holding Department of Defense Department of Defense

8/ l 7198 Newsweek article 8/ l 7/ 98 FBI Laboratory Report

8/ l 7198 AP news article 8/ l 8/ 98 Washington Post

8124198 facsimile to Jackie Bennett from Gary Grindler

8127198 memo

813 II98 letter to Bob Bittman from David Kendall

917198 memo Jones v. Clinton, 1998 WL 551961,9/ 1/ 98 order Lyrics to “Surfacing” 18 U. S. C. section 2246 Passport photo page

1123198 letter to Judge Starr from Karl Metzner “Love Notes” supplement 2/ l 4/ 97 Washington Post “Love Notes” Epass Access Control Reports 3114197 to 12122197 Toll records lOl21l97 to 1 l/ 19/ 97 Toll records Monica Lewinsky’s resume 1 l/ 3/ 97 letter from Monica Lewinsky to Ambassador Richardson I O/ 3 I I97 schedule for Ambassador Richardson Ill 3198 letter from Monica Lewinsky to Jenna Sheldon

1211 II97 letter from Monica Lewinsky to Richard Halperin Pager records for Moncia Lewinsky Toll records I l/ 6/ 97 letter from Monica Lewinsky to Vernon Jordan

6124197 typed note to Betty Currie

Bates # or Tab# Production Name Description

0833- DC- 00001857 0833- DC- 00001876 0833- DC- 0000 1906 0833- DC- 00001934 0833- DC- 0000 1974 0833- DC- 000027 16 0833- DC- 00002880 0833- DC- 00003207 0833- DC- 00009446 0833- DC- 000 17867 0833- DC- 00017869 0833- DC- 00017875 0833- DC- 00017886 0833- DC- 00017890 0833- DC- 00017903 to 04 0833- DC- 000 17908 I 0837- DC- 0000000 1 to 27

0843- DC- 00000004 0845- DC- 00000002 0845- DC- 00000004 to 17 0845- DC- 000000 18 to 2 1 0845- DC- 00000022 to 25 0845DC- 00000188 0845- DC- 00000190 0845- DC- 00000 191 to 193 0849- DC- 00000090 to 97

Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Department of Defense Speed Service Couriers, Inc. United States Secret Service Tripp, Linda Tripp, Linda Tripp, Linda Tripp, Linda Tripp, Linda Tripp, Linda Tripp, Linda Rader, Campbell, Fisher & Pyke

315197 E- Mail

313197 e- mail from Linda Tripp to Monica Lewinsky 2124197 E- Mail 2119197 E- Mail

214197 E- Mail Notification of Personnel Action Job Description Travel voucher

2/ l 9197 E- Mail 1 O/ 6/ 97 to 1 O/ 9/ 97 Toll records 1 O/ l 5197 to 1 O/ 20/ 97 Toll records Tol I records Tol I records Tol I records Toll records Tol I records Courier receipts re: Monica Lewinsky 1216197 Epass Access Control Record Handwritten notes Handwritten notes Handwritten Notes Handwritten Notes Handwritten note Letter from Linda Tripp to Newsweek Handwritten notes President Clinton’s Responses to Plaintiffs Third Set of Interrogatories

Bates # or Tab# Production Name Description

0849- DC- 00000098 to 102 0849- DC- 00000 12 1 to 13 7 0849- DC- 00000352 0849- DC- 00000586 0849- DC- 00000634 to 636 0852- DC- 00000035 0852- DC- 00000037 0852- DC- 00000044 to 45 0854- DC- 00001485 0856- DC- 00000002 0880- DC- 00000002 to 8 0902- DC- 00000003 0902- DC- 00000030 0902- DC- 00000033 0902- DC- 00000037 to 38 0902- DC- 0000005 1 0902- DC- 00000 13 5 to 13 8 0902- DC- 0000023 1 0902- DC- 00000232 0902- DC- 0000025 1 09 16- DC- 00000003 0920- DC- 000000 13 to I8 092Q- DC- 000005 17 to 525 092 1 -DC- 0000006 1 to 62 092 1 -DC- 0000009 1 to 15 1

092 t- DC- 00000459 to 466 Rader, Campbell, Fisher & Pyke

Rader, Campbell, Fisher & Pyke Rader, Campbell, Fisher & Pyke Rader, Campbell, Fisher & Pyke Rader, Campbell, Fisher & Pyke American Express American Express American Express First Union Bank American Express Lindsey, Bruce Carter, Francis Carter, Francis Cater, Francis Carter, Francis Catrer, Francis Carter, Francis Carter, Francis Carter, Francis Carter, Francis Park Hyatt Rader, Campbell, Fisher & Pykc Rader, Campbell, Fisher & Pyke McCormack, Hon. James Rader, Campbell, Fisher & Pyke

McCormack, Hon. James Attachment to President Clinton’s Responses to Plaintiffs Third

Set of Interrogatories Plaintiffs Witness List Videotaped Deposition of William Jefferson Clinton Definition of “Sexual Relation” Affidavit of Jane Doe #6 (Monica Lewinsky) Credit card statement Credit card statement

12/ 17/ 97 billing statement 516196 Check No. 594 12/ l l/ 97 letter from Monica Lewinsky to Ursula Fairbairn Handwritten notes Address l/ 12/ 98 to l/ 20/ 98 billing statement FedEx USA Airbill l/ 7/ 98 billing statement l/ 6/ 97 phone memo Subpoena issued to Monica Lewinsky in the Paula Jones case

12122197 to 12128197 appointment book 1 I5198 appointment book 1 I6198 phone message Receipt Subpoena issued to Monica Lewinsky in the Paula Jones case 12/ l 8197 Order in Jones v. Clinton, LR- C- 94- 290 11 I6197 Clerk’s minutes for in- camera hearing Plaintiffs Motion to Compel Responses to Plaintiffs Second Set of Interrogatories to Defendant Clinton 12/ l II97 Order in Jones v. Clinton, LR- C- 94- 290

Bates # or Tab# Production Name Description

092 1 -DC- 00000736 to 744 092 I -DC- 0000075 1 to 752 092! -DC- 00000770 to 772 092 I -DC- 00000775 to 778 0929DC- 00000056 095% DC- 00000060 0964- DC- 00000862 0968DC- 00000073 0968- DC- 00000 187 0968- DC- 00000236 0968- DC- 00000263 0968- DC- 00000303 0968- DC- 0000084 1 0968- DC- 00002947 0968- DC- 00003300 0968- DC- 00003301 0968- DC- 00003458 0968- DC- 00003459 0968- DC- 00003475 0968- DC- 00003477 0968- DC- 00003479 0968- DC- 00003506 0968- DC- 000035 10 0968- DC- 00003522 0968- DC- 00003533 0968- DC- 00003546 0968- DC- 00003550

McCormack, Hon. James McCormack, Hon. James Rader, Campbell, Fisher & Pyke Rader, Campbell, Fisher & Pyke NationsBank United States Secret Service White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House

I/ 8/ 98 Order in Jones v. Clinton, LR- C- 94- 290

I/ 9/ 98 Clerk’s minutes for in- camera hearing l/ 14/ 98 Clerk’s Minutes Motion of Jane Doe #6 for Protective Order and Motion to Quash Bank Statement 1 O/ l 1 I97 Presidential Protectee Movement Log

1216197 pager record Schedule 1 l/ 13/ 97 schedule

3129198 schedule Schedule 11 I1 3/ 97 Diarist notes

415196 Press Schedule

8/ l 7197 schedule 1 l/ 22/ 97 to 1 l/ 25/ 97 Presidential press schedule Presidential Press Schedule 2196 calendar for Hillary Rodham Clinton

3196 calendar for Hillary Rodham Clinton 7197 calendar for Hillary Rodham Clinton

10197 calendar for Hillary Rodham Clinton

12197 calendar for Hillary Rodham Clinton

2128197 Presidential Call Log

3129197 Presidential Call Log

511197 Presidential Call Log

5/ 24/ 97 Presidential Call Log

714197 Presidential Call Log

7/ l 4197 Presidential Call Log

Bates # or Tab# Production Name DescriDtion

0968- DC- 00003556 0968- DC- 00003558 0968- DC- 00003569 0968- DC- 00003799 0968- DC- 00003843 I OOO- DC- 00000767 to 772 10 12- DC- 0000000 1 I 0 13- DC- 00000095 to 96 10 14- DC- 00000022 1033- DC- 00000033 to 35 1033- DC- 00000115 to 1 I6 1034- DC- 00000060 to 63 l034- DC- 00000099 1034- DC- 00000 103 1034- DC- 00000 109

1034- DC- 00000111

I 037- DC- 0000000 1 to 2 l037- DC- 000000 11 I037- DC- 000000 17 1037- DC- 00000022 I037- DC- 00000033 1037- DC- 00000038 to 40 I 03 7- DC- 00000042 1037- DC- 00000063 1037- DC- 00000086 to 87 l037- DC- 00000 103

White House White House White House White House White House Bell Atlantic Bacon, Kenneth Bell Atlantic Cellular One Bell Atlantic Mobile Bell Atlantic Mobile Jordan, Vernon Jordan, Vernon Jordan, Vernon Jordan, Vernon Jordan, Vernon Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday

7124197 Presidential Call Log 8/ l 6197 Presidential Call Log 1 O/ l II97 Presidential Call 1 l/ 13/ 97 schedule 3129197 schedule

514196 Marcia Lewis Phone Bill

4128197 letter from Kenneth Bacon to Lorrie McHugh

214198 statement of Toll calls for Debra Finerman 3125197 to 4124197 Calls Toll records Toll records

lOl2Ol97 to 1 l/ 01/ 97 schedule for Vernon Jordan 1218197 to 1211 O/ 97 schedule for Vernon Jordan 12122197 to 12124197 schedule for Vernon Jordan 1 I1 2198 to 1 I1 4198 schedule for Vernon Jordan

Ill 9198 to II2 II98 schedule for Vernon Jordan 5/ l 8197 Card 12/ 9/ 97 e- mail from Lewinsky to Davis 1 I I7197 e- mail from Lewinsky to Davis 1 l/ 5/ 97 e- mail from Lewinsky to Davis

10122197 e- mail from Lewinsky to Davis E- mails between Monica Lewinsky and Catherine Allday Davis

8114197 e- mail from Lewinsky to Davis I I/ 6/ 97 e- mail from Lewinsky to Davis 914197 e- mail from Monica Lewinsky to Catherine Allday Davis 713198 e- mail from Catherine Allday Davis to Monica Lewinsky

Bates # or Tab# Production Name Descriotion

l037- DC- 00000107 1037- DC- 000001 I5 1037- DC- 00000 167 to I69 1037- DC- 00000 17 I

l037- DC- 00000255 to 256 I037- DC- 00000258 to 259 1037- DC- 00000265 to 266

1037- DC- 00000280 1037- DC- 00000296 1037- DC- 000003 18 1037- DC- 00000337 to 38 1037- DC- 0000034 1 1037- DC- 00000553

1037- DC- 00000583 105 1 -DC- 00000003 to 4 1064- DC- 00000008 1065- DC- 00000006 1065- DC- 00000008 l078- DC- 00000002 l089- DC- 00000970 1178- DC- 00000005 I I is-~~- 000000 I 1 I 178- DC- 000000 13

1178- DC- 000000 14 Davis, Catherine Allday

Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday

Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday Davis, Catherine Allday

Davis, Catherine Allday Bell Atlantic Renaissance Vinoy Resort St. Regis Hotel St. Regis Hotel Washington Post White House White House White House White House White House

6/ 17/ 97 e- mail from Monica Lewinsky to Catherine Allday Davis E- mail between Monica Lewinsky and Catherine Allday Davis E- mails between Monica Lewinsky and Catherine Allday Davis

8/ l 3197 e- mail from Monica Lewinsky to Catherine Allday Davis

914197 e- mail from Monica Lewinsky to Catherine Allday Davis

912197 e- mail from Monica Lewinsky to Catherine Allday Davis 6117197 e- mail from Monica Lewinsky to Catherine Allday Davis

712197 e- mail from Catherine Allday Davis to Monica Lewinsky E- mail from Catherine Allday Davis to Monica Lewinsky 1 l/ 19/ 97 e- mail from Lewinsky to Davis E- Mail from Lewinsky to Davis E- mail from Monica Lewinsky to Catherine Allday Davis 1 l/ 5/ 97 e- mail from Monica Lewinsky to Catherine Allday Davis 9/ 2/ 97 e- mail from Monica Lewinsky to Catherine Allday Davis Copy of Computer Disk

l/ 13/ 98 Toll records Hotel receipt Receipt Receipt

IO/ 16196 Typed note IO/ l II97 Presidential Call Log Presidetial Call Logs 12/ l 9197 Presidential Call Log

12l19l97 Presidential Call Log

Bates # or Tab# Production Name Description

1 I78- DC- 000000 15 1178- DC- 00000016 I 178- DC- 000000 18 I 178- DC- 000000 19 1178- DC- 00000020 1178- DC- 0000002 1 1178- DC- 00000023 1178- DC- 00000026 1205- DC- 000000 16 12 16- DC- 00000022 to 23 1222- DC- 00000024 1222- DC- 00000032 l222- DC- 0000004 I l222- DC- 00000045 1222- DC- 00000083 to 85 1222- DC- 00000 102 1222- DC- 00000 1 I2 to 113 1222- DC- 00000156 to 157 l222- DC- 00000 I79 l222- DC- 00000 183 1222- DC- 00000 189 1222- DC- 00000 196 I222- DC- 00000 197 I222- DC- 000002 16 to 2 17 1222- DC- 000002 19 l222- DC- 00000234 1222- DC- 00000242

White House White House White House White House White House White House White House White House GTE Company of California Bell Atlantic United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service United States Secret Service

12130197 Presidential Call Log l/ 6/ 98 Presidential Call Log l/ 16/ 98 Presidential Call Log

Ill 7198 Presidential Call Log l/ l 7198 Presidential Call Log

l/ 18/ 98 Presidential Call Log

l/ 19/ 98 Presidential Call Log WAVES records: Vernon Jordan

1125198 toll record from California Toll records

l/ 21/ 96 itinerary for the White House

315196 White House itinerary 313 l/ 96 intinerary Schedule 1 l/ l 5/ 95 to I Ill 8/ 95 Presidential Movement Logs 2119196 Presidential Movement Log

3129196 and 313 l/ 96 Presidential Movement Logs 1 l/ l 5195 Presidential Protectee Movement Logs Presidential Movement Logs

l/ 7/ 96 Presidential Protectee Movement Log 1 I2 II96 Presidential Movement Log

2/ 4/ 96 Presidential Movement Log

2/ l 9196 Presidential Movement Log 313 1 I96 Presidential Movement Logs 417196 Presidential Movements

2128197 Presidential Movements

5124197 Presidential Protectee Movement Log

Bates # or Tab# Production Name

l222- DC- 0000025 I 1222- DC- 00000254 1222- DC- 00000325 1222- DC- 00000328 1234- DC- 00000049 1234- DC- 00000050 1234- DC- 00000357 1248- DC- 00000008 l248- DC- 00000288 1248- DC- 00000291 1248- DC- 00000305 1248- DC- 00000307 1248- DC- 000003 1 I l248- DC- 000003 12 I248- DC- 000003 13 to 3 15 1248- DC- 000003 19 1248- DC- 00000327 to 328 1248- DC- 0000038 1 l248- DC- 00000444

13 18- DC- 0000000 I to 2 l342- DC- 000004 10 136 1 -DC- 00000002 to 42 I362- DC- 00000549 1362- DC- 0000 1 I 7 1 1407- DC- 00000005 140% DC- 00000005 14 14- DC- 0000000 1

United States Secret Service United States Secret Service United States Secret Service United States Secret Service White House White House United States Secret Service White House White House White House White House White House White House White House White House White House White House White House White House Young, Dale White House White House United States Secret Service United States Secret Service White House Rader, Campbell, Fisher & Pyke Rader, Campbell, Fisher & Pyke

71 I4197 schedule

7124197 schedule 1213 1195, 117196 Secret Service agent duty schedule 212 II96 Secret Service agent duty schedule 11 II 3197 schedule 11 I1 3197 Presidential Movement Log 8122197 to 1213 1 I97 Epass Access Control Report 417196 Telephone Memorandum l/ l 7198 Diarist schedule notes Daynotes Ill 7198 Presidential Call Log l/ 17/ 98 Presidential Call

Ill 8198 Presidential Call l/ l 8/ 98 Presidential Call Log l/ l 8198 Presidential Call Log l/ l 9198 Presidential Call Log l/ 21/ 98 Presidential Call Log

12l19l97 Presidential Call Log I /I 3198 Presidential Call Log

914197 note from Monica Lewinsky to Dale Young Photograph Index of books located in the Oval Office study 1 Ill 5195 Presidential Protectee Movement Log Secret Service agent duty schedule 1216197 TO 12124197 WAVES for Robert Bennett

1215197 Facsimile sheet

712 II98 letter to Julie Corcoran from Donovan Campbell, Jr.

Bates # or Tab# Production Name Descrlntion

1414- DC- 00001006 to 1014 1414- DC- 00001188 to 1192 1414- DC- 00001327 to 32 14 14- DC- 0000 1334 to 46 I4 14- DC- 00001534 to 1546 14 15- DC- 00000001 1472- DC- 00000006 1472- DC- 00000007 1472- DC- 00000008 1472- DC- 000000 15 1472- DC- 00000017 1472- DC- 000000 18 to 20 1 SO& DC- 00000007 to 8 1506- DC- 00000027 lSO6- DC- 00000029 l506- DC- 0000003 1 1506- DC- 00000050 1506- DC- 00000057 to 58 1506- DC- 00000068 1506- DC- 00000070 1506- DC- 00000 102 1506- DC- 00000 139 1506- DC- 00000 144 1506- DC- 00000 188 to 189 1506- DC- 00000 192 1506- DC- 00000222

I506- DC- 00000264 Rader, Campbell, Fisher & Pyke

Rader, Campbell, Fisher & Pyke Rader, Campbell, Fisher & Pyke Rader, Campbell, Fisher & Pyke Rader, Campbell, Fisher & Pyke White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House

1 I9198 Order in Jones v. Clinton, LR- C- 94- 290 12/ l 8197 Order in Jones v. Clinton, LR- C- 94- 290 hearing excerpt hearing excerpt 12/ l 5/ 97 Pleading in Jones v. Clinton, LR- C- 94- 290

813198 letter from David Kendall to the OIC 1 Ill 5195 Call Log 11115195 Telephone memorandum 1 l/ l 5195 Telephone memorandum 11 I1 7195 Telephone memorandum

2/ I 9196 Telephone memorandum 2/ l 9196 Telephone memorandum

8/ l O/ 95 Presidential schedule 1213 1 I95 Presidential schedule I213 1195 Telephone memorandum I I7196 Telephone memorandum I I2 If96 Telephone memorandum l/ 30/ 96 Presidential schedule 214196 Telephone memorandum 214196 Telephone memorandum 2/ l 9196 Telephone memorandum 313 l/ 96 Telephone memorandum

417 Telephone Memorandum Presidential schedule 512196 Presidential Call Log Presidential schedule

715196 Presidential schedule

Bates # or Tab# Production Name Descrbtion

l506- DC- 00000268 1506- DC- 00000275 l506- DC- 00000328 l506- DC- 00000334 to 335 1506- DC- 00000353 1506- DC- 00000373 to 374 1506- DC- 00000426 to 427 1506- DC- 00000523 to 525 I506- DC- 00000558 1506- DC- 00000559 1506- DC- 00000638 2004- DC- 00000083 2004- DC- 00000085 to 88 2004- DC- 00000090 to 9 1 827~ DC- 000000 18 CZ- DC- 000000 10 CZ- DC- 000000 16 DB PHOTOS 0004 DB PHOTOS 0044

DB PHOTOS 0048 DB- DC- 0000000 17 DB- DC- 000000022

DB- DC- 000000027 DC- DC- 00000004 to 5 DF- DC- 00000002 to 12 MSL- l249- DC- 0139 to 141

White House White House White House White House White House White House White House White House White House White House White House Bell Atlantic Bell Atlantic Bell Atlantic United States Secret Service Driscoll, Richard Driscoll, Richard Lewinsky, Monica Lewinsky, Monica

Lewinsky, Monica Lewinsky, Monica Lewinsky, Monica

Lewinsky, Monica Outline for job interests of Monica Lewinsky Willis- Vento, Caroline Fair market value appraisal Lewinsky, Monica 2/ l/ 98 handwri~ en proffer Lewinsky, Monica Letter from Monica Lewinsky to William Jefferson Clinton

716196 Presidential schedule 7/ I 9196 Presidential Call Log Presidential schedule Schedule Presidential schedule 218197 Schedule I 10/ 10/ 97 Presidential schedule 1 I2 1196 Diarist notes Presidential schedule Presidential schedule Diarists notes, Presidential call Toll records Toll records Toll records 2124197 to I2128197 Epass Access Control Report Fair market value appraisal Fair market value appraisal Blue Dress (photo) Audio- tapes from Monica Lewinsky’s answering machine (originals in Quantico) evidence picture Draft letter from Monica Lewinsky to William Jefferson Clinton

I l/ 12/ 97 letter from Monica Lewinsky to William Jefferson Clinton

Bates # or Tab# Production Name Description

MSL- 55- DC- 0001 MSL- 55- DC- 0094 MSL- 55- DC- 0124 MSL- 55- DC- 0177 MSL- 55DC- 0178 MSL- 55DC- 0179 MSL- 55- DC- 0184 to 186

Lewinsky, Monica Lewinsky, Monica Lewinsky, Monica Lewinsky, Monica Lewinsky, Monica Lewinsky, Monica Lewinsky, Monica

MS;- DC- 00000456 Lewinsky, Monica MS~- DC- 00000489 to 90 Lewinsky, Monica MSL- DC- 0000062 1 to 22 Lewinsky, Monica

Draft note from Monica Lewinsky to William Jefferson Clinton Letter drafted on Monica’s home computer Letter drafted on Monica’s home computer Letter from Monica Lewinsky to William Jefferson Clinton Letter from Monica Lewinsky to William Jefferson Clinton I l/ 2/ 97 letter from Monica Lewinsky to Betty Currie Note created on Monica Lewinsky’s home computer “Happy National Boss Day?” Handwritten note tnvi~ tion to William Jefferson Clinton’s Birthday Party 3/ 2/ 97 handwritten letter from Monica Lewinsky to William Jefferson Clinton 9/ 30/ 97 letter from Monica Lewinsky to William Jefferson Clinton October 1997 Calendar November 1997 Calendar Typed note M&- DC- 0000 I

MSL- DC- 00001 MS\- DC- 0000 I MSL- DC- 0000 I

050 White House 051 Lewinsky, Monica 051A Lewinsky, Monica 052 Lewinsky, Monica MSL- DC- 0000 1166 to I 168 MSL- DC- 00001176 to 1177 MSL- DC- 00001192 MSL- Do- 0000122 I MSL- DC- 00001227

MSL- DC- 0000 1228 MSL- DC- 00001230 V002- DC- 0000000 1 to 5

V002- DC- 00000006 to 7 Lewinsky, Monica

White House White House Lewinsky, Monica Lewinsky, Monica

Lewinksy, Monica Lewinsky, Monica Clinton, William Jefferson

Clinton, William Jefferson Draft Affidavit

6/ 29/ 97 draft letter from Monica Lewinsky to Marsha Scott 7/ 6/ 97 letter from Monica Lewinsky to Marsha Scott Page from Monica Lewinsky’s schedule book 6/ 29/ 97 note from Monica Lewinsky to William Jefferson Clinton 3/ 14/ 997 memorandum from Cliff Bernath for the Record 4128197 letter from Kenneth Bacon to Lorrie McHugh l/ 27/ 98 letter from David Kendall to Bob Bittman, with attachments l/ 28/ 98 letter from David Kendall to Bob Bittman

Bates # or Tab# Production Name Description

V002- DC- 00000008 to 15 VOO2- DC- 000000 I6 to 32 VOq2- DC- 00000052 to 55 VOq2- DC- 00000056 to 92 VOq2- DC- 00000093 to 1 I6 VOqZ- DC- 00000 159 to 160 V002- DC- 00000469 VOQ2- DC- 0000047 1 VOO2- DC- 00000475 V004- DC- 00000134 V004- DC- 00000 I35 V004- DC- 00000 143 V004- DC- 00000 148 VOO4- DC- 00000 15 1 V004- DC- 00000 I54 V004- DC- 00000 158 V004- DC- 00000 159 VOO4- DC- 00000 160 V004- DC- 00000 161 V004- DC- 00000 162 V004- DC- 00000 164 VOO4- DC- 00000 I65

VOO4- Do- 00000 166 Clinton, William Jefferson

Clinton, William Jefferson Clinton, William Jefferson Clinton, William Jefferson Clinton, William Jefferson Clinton, William Jefferson Clinton; William Jefferson Clinton, William Jefferson Clinton, William Jefferson Akin Gump Akin Cump Akin Gump Akin Gump Akin Gump Akin Gump

Akin Gump Akin Gump Akin Gump Akin Gump Akin Gump Akin Gump Akin Gump Akin Gump

President Clinton’s Responses to PlaintiM’s First Set of Interrogatories President Clinton’s Responses to Plaintiff’s Second Set of Interrogatories President Clinton’s Supplemental Responses to Plaintiffs Second Set of Interrogatories President Clinton’s Responses to Plaintiffs First Set of Requests for Production of Documents and Things President Clinton’s Responses to Plaintiffs Second Set of Document Requests 2/ 2/ 98 letter from David Kendall to Bob Bittman 2/ 3/ 98 letter to Bob Bittman from David Kendall Book, “The Presidents of the United States” 3/ 16/ 98 letter from David Kendall to the OIC I l/ 3/ 97 to 1 l/ 4/ 97 Toll records 1 l/ 4/ 97 to 1 l/ 6/ 97 Toll records 1 l/ 26/ 97 to 1 l/ 27/ 97 Toll records 12/ i I /97 to 12/ l S/ 97 Toll records 12/ l 9197 to 12123/ 97 Toll records I2/ 30/ 97 to l2/ 3 l/ 97 Toll records l/ 5/ 98 to l/ 7/ 98 Toll records 1 f7198 to l/ 8/ 98 Toll records

118198 to 119198 Toll records

i/ 9/ 98 to 111 O/ 98 Toll records l/ IO/ 98 to l/ 13/ 98 Toll records l/ 15/ 98 to l/ 16/ 98 Toll records l/ 16/ 98 to l/ 19/ 98 Toll records l/ 19/ 98 to 1121198 Toll records

Bates # or Tab# Production Name Description

V004- DC- 00000 167 VOO4- DC- 00000 17 1 VOO4- DC- 00000 172 V004- DC- 00000 I 83 V005- DC- 00000058 VOdS- DC- 00000060

vod5- D~- ooooOo6~ vod6- DC- 00000007 VOd6- DC- 00000008 vod6- DC- ooooooo9 vOd6- DC- 00000020 vod6-~- oooooio9 vod6- DC- oooooti8 vod6- DC- oooooi57 vod6- DC- 00000158 vod6-~- oooooi59

VOU6- DC- 00000 162 V006- DC- 00000 167 VOU6- DC- 00000 I 78 VO06- DC- 00000 I 80 V006- DC- 00000 I 8 I VOd6- DC- 00000 183 VO~ 6- DC- 00000 I98 VO~ 6- DC- 0000022 1 V066- DC- 00000222 V006- DC- 00000223 to 224

Akin Gump Akin Gump Akin Gump Akin Gump Laughlin, Gayle Laughlin, Gayle Laughlin, Gayle White House White House White House White House White House White House White House White House White House

White House White House White House White House White House White House White House White House White House White House

l/ 21/ 98 to l/ 22/ 98 Toll records 12/ l l/ 97 visitor record I211 9197 vistor record 12/ 8/ 97 Request for Messenger Service l/ l 5/ 98 phone record 1 I20198 phone record 11201’98 phone record

419196 to 12/ 30/ 96 WAVES report for Monica Lewinsky 2/ 24/ 97 to I l/ 13/ 97 WAVES report for Monica Lewinsky 12/ 6/ 97 to 12/ 28/ 97 WAVES report for Monica Lewinsky WH Personnel Action sheet for Monica Lewinsky Work history report Notification of Personnel Action White House Gift Record Gift Donor Information 9/ 4/ 96 letter from William Jefferson Clinton to Monica Lewinsky White House Gift Register 1 O/ 30/ 95 Gift Unit - draft leter Photograph White House Gift Record White House Gift Record Monica Lewinsky’s resume 1995 summer White House intern list 5/ 30/ 97 schedule sheet 6/ 10/ 97 e- mail from Marsha Dime1 to Katherine Veit 6/ 12/ 97 e- mail from Marsha Dime1 to Roseanne Hill w/ attachment

Bates # or Tab# Production Name DascriMon

V006- DC- 00000225 V006- DC- 0000039 1 VOO6- DC- 000005 1 I VOO6- DC- 000005 12 to 522 V006- DC- 0000052 1 V006- DC- 00000534 V006- DC- 00000572 VOO6- DC- 00000682 VOU6- DC- 00000694 VOU6- DC- 00000747 VOU6- DC- 0000 1347 VOU6- DC- 0000 1770 VOU6- DC- 0000 1792 VOU6- DC- 0000 1796 VOU6- DC- 00001813 to 1814 V006- DC- 0000 1826 VOO6- DC- 0000 I 84 1 V006- DC- 0000 1842 V006- DC- 0000 1843 V006- DC- 0000 1844 VOO6- Do- 0000 1845 V006- DC- 0000 1846 V006- DC- 0000 1847 V006- DC- 00001855 V006- DC- 00001856 VOO6- Do- 0000 1859 V006- DC- 0000 1865

White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White house White House White House White House White House White House White House White House White House White House White House

White House pre- employment information sheet WhoDB - Contact Manager Information 12/ S/ 97 Holiday Reception list excerpt 1215197 White House Party list excerpt, report dated on 12/ 30/ 97 1215197 White House Party list excerpt, report dated on 12/ 30/ 97 6114196 Radio Address 2/ 8/ 96 to 2/ l II96 Presidential schedule 8118196 and 8119196 William Jefferson Clinton Schedule 412196 Schedule of William Jefferson Clinton 2/ 9/ 96 to 2112196 Presidential schedule 419196 E- Mail 7/ 24/ 97 e- mail

3129197 WAVES Request

2128197 WAVES Request 12/ 5/ 97 e- mail: WAVES Operations Center to J. Schwartz Photograph Photograph Photograph Photograph Photograph Photograph Photograph Photograph Photograph Photograph Photograph videotape

Bates # or Tab# Production Name Descriotion

VOO6- DC- 00002064 V006- DC- 00002065 V006- DC- 00002066 V006- DC- 00002067 V006- DC- 00002068 V006- DC- 00002069 to 2070 V006- DC- 0000207 1 V006- DC- 00002095 VOO6- DC- 00002 130 VOO6- DC- 00002 140 VOO6- DC- 00002 142 V006- DC- 00002 146 V006- DC- 00002 I47 V006- DC- 00002 156 V006- DC- 00002 158 V006- DC- 000022 14 V006- DC- 00002243 VOO6- DC- 00002287 VOq6- DC- 00002289 VOq6- DC- 00003646 VOq6- DC- 000037 12 VOq6- DC- 00003 7 14 VOq6- DC- 00003 7 15 VOq6- DC- 00003 7 I 6 VOQ6- DC- 000037 19 VOQ6- DC- 00003720 V006- DC- 00003 73 5

White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House White House

l/ 9/ 98 Presidential Call Log l/ 14/ 98 Presidential Call Log l/ 17/ 98 Presidential Call Log l/ 18/ 98 Presidential Call Log l/ l 8/ 98 Presidential Call Log l/ 19/ 98 Presidential Call Log l/ 21/ 98 Presidential Call Log

8Jl6J97 schedule 3/ 29/ 97 Presidential Movements 7/ 4/ 97 schedule 7114197 schedule 8/ l 6197 schedule 8/ l 6197 schedule 1 l/ l 3/ 97 Presidential Movement Log 12/ 6/ 97 Presidential Movement Log 714197 diarist notes 11 /I 3197 Diarist notes 4/ 9/ 96 e- mail from Gunia to Dagenais E- Mail Coorespondence History tracking sheet 2/ 24/ 97 memo from Betty Currie to William Jefferson Clinton White House Gift List White House Gift List 61 I 4196 Radio Address 4f8196 phone message

2J28J97 Radio Address Photo Request

2229

2230

2231

TAB Documents

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Tab 47

2234

2235

ation Search Result Rank 1 of 1 9/ 98 USNWR 1920 9/ 98 U. S. News & World Rep. 1920 1998 WL 8126910

Page 1 Database USNWR

Monday, June 29, 1998 Vol. 124, No. 25 Outlook; Washington Whispers; Newsletter The press on Brill on the press; Hooray for Hollywood; Hooray for the CIA; Operator, get me China; Life after Webb Starr unbowed, Clinton's favorite

flicks, the star- struck CIA and more Timothy Noah; Julian E. Barnes; Ted Gest; Marianne Lavelle; Kenneth T. Walsh;

Marci McDonald; William J. Holstein; Gordon Witkin; Gary Cohen The press on Brill on the press Starr unbowed, Clinton's favorite flicks, the star- struck CIA and F e

Like every other reporter in Washington, Whispers can't resist p& tiying "gotcha" with Steven Brill, who wrote a much- discussed magazine article lacerating the media's Lewinsky sex- scandal coverage. Brill quoted with apparent approval CNN president Rick Kaplan's views on Monicagate excesses. But he somehow neglected to mention that Kaplan is a longtime friend of President Clinton's who (Whispers groupies will recall) told CNN staffers last fall to limit use of the word scandal in reporting on Clinton's 1996 campaign fund- raising. - Brill's castigation of Kenneth Starr for talking to reporters made Whispers wonder whether the 21 other independent counsels ever dished. Here's what its survey found: Five independent counsels, including Starr, acknowledge talking to the press. Eleven claim they did not-- or will not (but may of course be fibbing). The other six couldn't be reached; one of the six, James McKay, was accused of improper leaks during his investigation of Lyn Nofzinger and Ed Meese.

Incidentally, Brill's brouhaha doesn't seem to have dampen; d Starr's prosecutorial zeal. Last week, Bell Atlantic notified Robert Weiner, the spokesman for the White House Office of Drug Control Policy, that Starr had subpoenaed his phone records. Weiner‘ s bit role in the scandal, Monicagate connoisseurs will recall, consisted

teing questioned before the grand jury on phone calls he and his z"% made to the Columbia , Md., Democratic Club to (he says)

:gratulate" officials for their press release saying Linda Tripp Copr. 0 West 1998 No Claim to Orig. U. S. Govt. Works

2236

f'? 9/ 98 USNWR 1920 Page 2 uld be prosecuted under state law (for surreptitiously tape Gording Monica Lewinskyf . Weiner says Bell Atlantic told him Starr's office asked the company not to notify Weiner of the subpoena, but Ma Bell rejected this request on advice of counsel. Legal experts say this prosecutorial secrecy is extremely common in violent- crime cases, but less common in nonviolent cases. Bell Atlantic won't comment on any specific subpoenas, but company spokeswoman Sandra Arnette says, "It is our policy to notify a customer in the event we receive a subpoena, unless the subpoena specifically states not to."

Hooray for Hollywood. Who cares what the American Film Institute thinks are the best U. S. films of all time? Whispers wants to know what inveterate film buff President Clinton thinks are the best films of all time! It's widely known that Clinton's favorite movie is High Noon and that Clinton, like all other Homo sapiens, adores Casablanca. But here, for the first time anywhere, are the commander- in- chief's Top Five Picks: 1.) High Noon; 2.) Casablanca; 3.1 Gone With the Wind (this one's a tad politically incorrect, but at least it's not The Birth of a Nation); 4.) Schindler's List (this one is arguably too politically correct); and 5.) The Bridge on the River Kwai (presumably President Clinton can explain what happens in t' 's film's famously incoherent final 15 minutes),

moray for the CIA. Still smarting from a public and L .. gressional castigation for failing to predict India's nuclear tests, CIA brass hope to be rehabilitated by the Showtime cable channel. Showtime is filming a movie called The Agency at Langley, for which the CIA has agreed to provide 60 staffers as extras. When the call went out for volunteers to spend a Saturday strolling through the CIA lobby before the movie cameras, the response was so great that some departments had to hold a lottery to pick who could appear. (None of those chosen, thank goodness, were undercover operatives,) Whispers can't be more specific because-- get this-- the CIA says the precise number who clamored to be in the movie is classified.

Operator, get me China. Iridium LLC, a satellite communications company based in Washington, D. C., may have a more intimate link with a controversial Chinese military- related group than does Loral Corp. (which is currently getting barbecued by the New York Times and others for allegedly transferring too much rocket know- how't6 China) - This is a little complicated, but bear with us: Iridium's Chinese partner, Iridium China (Hong Kong) Ltd., is managed by mainland- born Wang Mei Yue. Wang Mei Yue also happens to be head of China Aerospace International Holdings Ltd. (CASIL) in Hong Kong. CASIL is F : of China's defense industrial complex, and is also where Liu Chioying, the daughter of a top Chinese military official, was

'. oyed as a vice president; she is the figure who allegedly Copr. 0 West 1998 No Claim to Orig. U. S. Govt. Works

2237

6/ 29/ 98 USNWR 1920 Page 3 ?eled money to the Democratic Party. There are other ties between . iL and Iridium besides Wang: According to the South China Morning Post of Hong Kong, three officials from CASIL sit on the board of Iridium China. Iridium, which is ringing the globe with 66 low- flying satellites for mobile telephone use, needs a Chinese partner to build and complete its global network linking 239 countries. Whispers can't help wondering whether some of that satellite know- how is flowing from Iridium China to CASIL and somehow improving China's military communications network. Iridium, Iridium China, and CASIL all declined comment.

Meanwhile, Whispers hears that in early June, representatives from the Treasury and Justice departments got together to discuss the results of an investigation by the Office of the Comptroller of the Currency (OCCJ. The OCC reported that over the past year or two, hundreds of millions of dollars had moved from Chinese banks to American banks, with no seeming explanation; the amounts of cash, and the techniques used to move the money, have made investigators suspicious. Those at the June meeting speculated that the funds could have been stolen from the Chinese government, and there was also chatter about possible tie- ins with the investigation of Chinese contributions to the Democratic Party. Whispers has no idea whether ant1 of these suspicions are justified but would be glad to hear from \* Jne who knows what it's all about.

,fe after Webb. Congressman Dan Burton's investigative committee is poking into the political donations of Mark Jimenez, a Florida businessman suspected of funneling South American money to the Democratic National Committee. Several of Jimenez's employees recently pleaded the Fifth Amendment when asked about their political contributions.

E- mail address: whispers@ usnews. com '* Why do you write such scathing articles about me?" "I don't know."

Monica Lewinsky and Maureen Dowd, meeting for the first time at a restaurant near Dowd's New York Times office

"There are always going to be leakers. The question is what do guys like you and me do about them?" c

Steven Brill, talking to a reporter about his magazine's attack on Kenneth Starr's talks with the press (which Starr says weren't leaks)

"Tt tickled me to death. We may need to have a rejoicing ce- mony."

Copr. 0 West 1998 No Claim to Orig. U. S. Govt. Works

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Page 4 '9f98 USNWR 1920

T. E. Smith, mayor of Bay Springs, Miss., where former Sunbeam .irman Albert Dunlop closed two plants, on Dunlop's firing

"There was no kind of ethnic cleansing," Slobodan Milosevic, president of Yugoslavia, denying widespread reports of violence against ethnic Albanians in Kosovo

TABULAR OR GRAPHIC MATERIAL SET FORTH IN THIS DOCUMENT IS NOT DISPLAYABLE Drawing: Frankly my dear . . . uh, you gonna finish that jelly doughnut? (Richard Thompson for USN& WR); Drawing: A little wobbly on *nonpartisan' too. (Tom Toles for USNCWR)

---- INDEX REFERENCES ---- COMPANY (TICKER): Bell Atlantic Corp. (BEL) Word Count: 1131 6/ 29/ 98 USNWR 1920 END OF DOCUMENT

Copr. 0 West 1998 No Claim to Orig. U. S. Govt. Works

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Tab 48

2240

2241 . .

U. S. Depad... ent of Justice Office of Professional Respohsibility

Woshittxmr. D. C. 20530

July 15, 1998 Mr. Donald C. Smaltz Independent Counsel P- 0. Box 26356

ib3 GLCJ11OCO SiLX: rt, suit= 2GC

Alexandria, VA 22313 Dear Mr. SmaLtz:

In a December 5, 1997 letter to the Attorney General, you expressed concern about alleged comments attributed by the media to senior Department of Justice officials which were critical of yourself and other independent counsels. The Attorney General responded in a January 20, 1998 letter deploring such comments if

they were in fact made and advising that your letter had been referred to this Office for review.

Your letter suggested that publication of the alleged comments could influence jurors hearing a case then pending or members of a future venire. The letter also noted the possible application of Rule 3.6 of the A. B. A. 's Model Rules of Professional Responsibility which bars attorneys from making extrajudicial statements having "a substantial likelihood of materially prejudicing" a pending case.

Based on our review of the excerpts you cited, we concluded that the alleged comments did not in these circumstances violate Rule 3.6 because their general nature made it unlikely that they would have (( a substantial likelihood of materially prejudicing" any case. In particular, none of them disparaged any specific witness, item of evidence or prosecution theory. Rather, they pertained to matters then. under active public debate.

In addition, Rule 3.6 applies only to lawyers. "who [are] participating or ha[ vel participated in the investigation" at issue, a requirement no Department official meets. its terms, And while, by the rule's prohibitions extend as well to any "lawyer associated in a * l * government agency with [such] a lawyer," the rule still does not apply to Department officials since independent counsels are not part of the Department.

Because Rule 3.6 is inapplicable in this case and no other ethical rule appears to prohibit the reported comments, we must

- 2 - conclude that no further inquiry into them by this Office is justified. This conclusion does not, however, mean that we found the comments to be appropriate.

If you have any questions, please contact me or Assistant Counsel Paul Colby on (202) 514- 3365.

Sincerely, Richard M. Rogers Deputy Counsel

2244

2245

DlsIRIcTOF

To: The White House ATTN: Michelle Petersen, Esq. SUBPOENA TO TESTIFY

BEFORE GRAND JURY

SUBPOENA FOR: OFERSON l3 DDcuMEmS) OR cxuEcms)

United States District Court for the District of Columbia Third & Constitution Avenue, IJ. W. Washington, D. C.

I Grand Jury, Third Floor

I July 23, 1998/ 9: 15 a. m.

YOU ARE ALSO COMMANDED to bring With you the fotlowing docmtmt( s) or ohjeds): ’

See attached Rider.

0 Please see additional intonation on reverse.

This subpoena shrlr n In effect until you are granted bea* to depart by the court of by an offkef 8+ W on behalf of the coud

us. yAolslMlE A MTE July 17, 1998

of the United 8 Off& of the Independent Counsel 1001 Pennsylvania Avenue, N- W., Suite 490- Nort

Washington. D. C. 20004

(202) 514- 8688

2246

Subpoena (ID1415 To: The White House

A. Produce the following items in the possession/ custody of President Clinton:

2. 3. 4. 5. 6,

VOX The Notebook Geek Love W VeY A Silver Cigar Holder, and

An Antique Paperweight depicting the White House circa 1900

Personal appearance is not required if the requested documents are delivered on or before the return date to Special Agent of the Federal Bureau of Investigation (telephone

Suite 490- North, 1001 Pennsylvania Avenue, N. W.,

Washington, 20004, for submission to the Grand Jury. If you choose to deliver documents in lieu of a personal appearance, you

must (i) state in a cover letter whether such production contains all responsive documents, and (ii) attach a copy of this subpoena

to the cover letter. 1.

a. The term "document" or "documents" as used in this subpoena means all records of any nature whatsoever within your

possession, custody or control or the possession, custody or control of any agent, employee, representative (including, without limitation, attorneys, investment advisors, investment bankers, bankers and accountants), or other person acting or purporting to act for or on your behalf or in concert with you, including, but not limited to, draft, pending or executed contracts and/ or agreements, sample documents, insurance policies, financial guarantee bonds, letters of credit, communications, correspondence, calendars, daytimers, datebooks, telegrams, facsimiles, telexs, telefaxes, electronic mail, memoranda, records, reports, books, files (computer or paper), summaries or records of personal conversations, meetings or interviews, logs, summaries or records of telephone conversations

- 1 -

2247 -

and/ or telefax communications, diaries, forecasts, statistical statements, financial statements (draft or finished), work papers, drafts, copies, bills, records of payments for bills, retainer records, attorney time sheets, telephone bills and records, telefax bills and records, tax returns and return information, employee time sheets, graphs, charts, accounts, analytical records, minutes or records of meetings or conferences, consultants' reports and/ or records, appraisals, records, reports or summaries of negotiations, brochures, pamphlets, circulars, maps, plats, trade letters, depositions, statements, interrogatories and answers thereto, pleadings, docket sheets, discovery materials, audit letters, audit reports, materials underlying audits, document productions, transcripts, exhibits, settlement materials, judgments, press releases, notes, marginal notations, invoices, documents regarding collateral or security pledged, settlement statements, checks disbursed or received at settlement, inspection reports, title policies, financial statements and/ or federal tax returns submitted by any person in support of any loan application, items related. the repayment, if any, of any interest or principal on the loan, items relating to any default on the loan, commission records, evidence of liens, documents relating to filings under the Uniform Commercial Code and/ or its equivalent, foreclosure and mortgage documentation, cashiers checks, bank drafts, money orders, bank and brokerage account statements, debit and credit memoranda, wire transfer documentation, opening account cards, signature cards, loan applications, any employment and bank account deposit verification documents, loan histories, loan files, records of loan repayment or any and all efforts to secure repayment, including foreclosure or records of lawsuits, credit references, board resolutions, minutes of meetings of boards of directors, opinion letters, purchases and sales agreements, real estate contracts, brokerage agreements, escrow agreements, loan agreements, offer and acceptance contracts, or any other contracts or agreements, deeds or other evidence of title, escrow accounts and any other escrow documentation, savings account transcripts, savings account deposit slips, savings account withdrawal slips, checks deposited in savings accounts, checking account statements, canceled checks drawn on checking accounts, deposit slips and checks deposited into checking accounts, credit card accounts, debit and credit documentation, safe deposit records, currency transaction reports (IRS Forms 4789), photographs, brochures, lists, journals, advertising, computer tapes and cards, audio and video tapes, computerized records stored in the form of magnetic or electronic coding on computer media or on media capable of being read by computer or with the aid of computer related equipment, including but not limited to floppy disks or diskettes, disks, diskettes, disk packs, fixed

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hard drives, removable hard disk cartridges, mainframe computers, Bernoulli boxes, optical disks, WORM disks, magneto/ optical disks, floptical disks, magnetic tape, tapes, laser disks, video cassettes, CD- ROMs and any other media capable of storing magnetic coding, microfilm, microfiche and other storage devices, voicemail recordings and all other written, printed or recorded or photographic matter or sound reproductions, however produced or reproduced.

The term "document" or "documents" also includes any earlier, preliminary, preparatory or tentative version of all or part of a document, whether or not such draft was superseded by a later draft and whether or not the terms of the draft are the same as or different from the terms of the final document.

b. The term "communication" or "communications" is used herein in its broadest sense to encompass any transmissi. on or exchange of information, ideas, facts, data, proposals, or any other matter, whether between individuals or between or among the members of a group, whether face- to- face, by telephone or by means of electronic or other medium.

C. '* Possession, custody or control" means in your physical possession and/ or if you have the right to secure or compile the production of the document or a copy from another person or entity having physical possession, including, but not limited to, your counsel.

d. The term "referring or relating" to any given subject means anything that constitutes, contains, embodies, reflects, identifies, states, refers to, deals with, or is in any manner whatsoever pertinent to that subject including, but not limited to, documents concerning the preparation of other documents.

e. The term “you" means yourself and any of your companies, partnerships and business entities with which you have been affiliated and any employees, partners, associates or members of any firm with which you have been affiliated in the course of your work for any of the persons or entities named in this rider, and any such firms and the affiliates of those firms.

2. trutiou a. The originals of all documents and communications must be produced, as well as copies within your possession, custody, or control.

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2249

b. If any original document cannot be produced in full, produce such document to the extent possible and indicate specifically the reason for your inability to produce the remainder.

C. Documents shall be produced as they are kept in the usual course of business, as organized in the files.

d. File folders, labels, and indices identifying documents called for shall be produced intact with such documents. Documents attached to each other should not be separated.

e. In reading this rider, the plural shall include the singular and the singular shall include the plural.

f. The words "and" and "or" shall be construed conjunctively or disjunctively as necessary to make the request inclusive rather than exclusive. The use of the word "including* ' shall be construed without limitation.

g- In the event that any document, or portion thereof, called for by this subpoena is withheld on the basis of any claim of privilege or similar claim, that document shall be identified in writing as follows: (a) author; (b) the position or title of the author; (c) addressee; (d) the position or title of

the addressee; (e) any indicated or blind copies; (f) date; (g) a description of the subject matter of the document; (h) number of pages; (i) attachments or appendices; (j) all persons to whom the document, its contents, or any portion thereof, has been disclosed, distributed, shown, or explained; and (k) present. custodian. Each basis you contend justifies the withholding of the document shall also be specified. With respect to those documents or records as to which you may claim privilege, or attorneys' work product, set forth as to each such document the basis for such claim, including the purpose and circumstances surrounding the creation of the document, the identity of each person who has been privy to such communication reflected in the document, the identity of any person or entity instructing the subpoena recipient or the attorney of the subpoena recipient to withhold production of the document, and whether you will submit the document to the Court for an in a determination as to the validity of the claim. If the existence of a joint defense

agreement or any agreement as to common interest is relevant to the assertion of any claim of privilege or similar claim, please provide a copy of that agreement; if any such agreement is not in writing, please set forth the date of the creation of the agreement, the identities of all parties to the agreement and the

-4-

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specific individuals who entered into the agreement on behalf of those parties, and the objects, purposes, and scope of the agreement.

h. In the event that any document called for by this subpoena has been lost, destroyed, deleted, altered, or otherwise disposed of, that document shall be identified in writing as follows: (a) author; (b) the position or title of the author; (c) addressee; (d) the position or title of the addressee; (e) indicated or blind copies; (f) date; (g) a brief description of the subject matter'of the document; (h) number of pages; (I) attachments or appendices; (j) all persons to whom the document, its contents, or any portion thereof, had been disclosed, distributed, shown or explained; (k) the date of the loss, destruction, deletion, alteration, or disposal and the circumstances thereof; and (1) the reasons, if any, for the loss, destruction, deletion, alteration, or disposal and the person or persons responsible.

i. If any information or data is withheld because such information or data is stored electronically, it is to be identified by the subject matter of the information or data and the place or places where such information is maintained.

-5-

2251

FAX TRANSMISSION 1

OFFICEOFTEEINDEP~ DENT COUNSEL

I 00 I PENNSYLVANIA, N. W. Sum 490- NORTH WASHINGTON. m 20004

MAIN NUMBER: (202) 5 14- 8688 FAX NUMBER: (202) 5 I 4- 8802

to: Michelle Peterson, The White House fax #: 202- 456- 5055

date: tel #:

July 17,1998 from: tel #:

Julie A. Corcoran, Associate Independent Counsel 202- S 14- 8688 paw: 1 , including this cover sheet.

comment:

-NOTE: This faaimik is intended only for the person or entity to wbicb it is addressed and may contain information that is privileged, confidential, or otherwise protected from disclosure. Dissemination, distribution, or copying of this facsimile or the information betin by anyone otber than the intended recipient, or an employee of agent responsible for delivering tbe message to tbe intended recipient, is prohibit& If you have necived this facsimik in error, piease notify usimmediately by telephone and return

thr f. m. 4milo t.., m. ril

******************** t *t* TX REPORT *tt tt* t***** tL* L***** tr~

TRMi’SrISSION OK

TX/ RX NO

CONNECTION TEL SUBADDRESS CONNECTION ID ST. TIME USAGE T

PGS .

RESULT 3706

94565055 07/ 17 14: 17 03’01

7 OK

FAX TmwsnmsroN

t%‘ FWE OF THE hIDEPENDENT COUNSEL 100 1 PENNSTLVANU. N. W.

Sum 490- Nom WASFIINGTON. DC 20004

t’hN NUMBER: (202) 5 14- 8888 Fu NUMBER: (202) 5 14- 8802

to: Michelle Peterson, The White House fax I#: 202- 456- 5055

date: July 17,1998 tel#:

from: tel #r

Julie A. Corcoran, Associate independent Counsel

202- S 14- 8688 Ppgcsq 1 including this cover sheet.

comment:

2253

Tab 50

2254

2255

Page 3

CNBC News Transcripts SHOW: HARDBALL WITH CHRIS MATTHEWS (8: OO PM ET)

July 22, 1998, Wednesday 2: 05 PM LENGTH: 4456 words HEADLINE: WHETHER MONICA LEWINSKY COULD HAVE SPENT TIME WITH THE PRESIDENT AND THE ISSUE OF IMPEACHMENT

ANCHORS: CHRIS MATTHEWS BODY:

Mr. LEON PANETTA (Former White House Chief of Staff): (From March 30) There's also a group within the White House that thinks that playing hardball is the way you deal with these issues, and that ultimately if you-- if you stonewall these things, they'll go away. I just ha-- in-- in my history in politics in Washington, my view is nothing goes away in Washington. If you try to stonewall things, ultimately it catches up with you. It is much better to be forthright. And those are exactly the words that I often would tell the president.

CHRIS MATTHEWS, host: Time marches on. We have Leon Panetta with us from San Francisco. I wish I was up there with you today. Leon, thank you for joining us.

Mr. PANETTA: Yeah, I'd like to have you here, Chris. MATTHEWS: Thank you. Mr. PANETTA: My pleasure. MATTHEWS: Well, let's talk about-- would those be your words today in speaking to the president?

Mr. PANETTA: Well, I think-- you know, as-- as-- at the time that I said the president ought to come forward, I thought that was one way to try to hopefully end this kind of long nightmare we've been through with this scandal. And, you know, it's -- right now, as I look at the special prosecutor and some of the things he's done over the last few weeks, particularly with regards to the Secret Service, which concern me a great deal because of what it did, I think, to increase the jeopardy to-- to a president's life by virtue of-- of the testifying that's gonna go on here. I'm just not so sure that, perhaps, the president may not be better off right now waiting and seeing what-- what the special prosecutor develops and listening to his lawyers. But at some point, there's no question that he's gonna have to come forward and he's gonna have to be forthright about what happened.

MATTHEWS: I agree with you about the Secret Service, but let me ask you about-- maybe you--~ wanna give you some time here because we rarely have

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somebody on the program who's been in the White House-- in the Clinton White House-- right-- intimately with the president and can describe the sort of culture of the place. It just seems to me, from the outside and being politically I-- political, I noticed-- it seems to me the president and there's-- would seem to be a lot of young people around.

‘I mean, then some grownups like yourself, Erskine Bowles now, Mack McLarty, that you guys seem to be the odd people out, however, the grownups. It seems like the president and the kids seem to have this thing- going on there and it's kind of casual and loosey- goosey, and you guys tried to enforce some discipline on it, but normally, this president seemed to have a sort of a whimsical idea that he could fun with the younger staffers and hang out with them and enjoy their tunes and stuff, thinking about tomorrow, whatever he sings when he sings their songs. It doesn't-- it seems like a kind of a -- a juvenile culture that he seems to enjoy to sh-- joy sharing in. Is that fair?

Mr. PANETTA: Well, Chris, I think you have to go back to how this developed. At-- at the-- at the beginning of the administration, they took a long time selecting the Cabinet and spent most of their time really focusing on those that they wanted within the Cabinet. And suddenly they were at the inauguration day and realized that they had not spent very much time on developing a White House staff. And as a consequence, they relied a lot on people who came out of the campaign -- and as you know, sometimes somebody can be very good in a campaign, but have very little experience in terms of Washington and the White House and the responsibilities to the White House.

So I think part of the problem was that not enough time was spent in selecting the people that ultimately went into the White House and they were for -- in large measure, younger, they were less experienced and I think a lot that contributed to the initial problems. I do have to tell you that I think as a result of the work that I did, that Erskine Bowles did-- I think the discipline within the White House increased a great deal, so that that was not as much as a problem as it was the first two years. As far as the president's concerned, president loves, obviously, to-- to mix with people. He's a people person. That's what got him into the presidency. He likes young people and he likes old people. I mean, I've never seen a person who doesn't like to engage when you're in the presidency. He loves to meet people and he loves to talk with people, and that's his nature.

MATTHEWS: Well, when you-- when you talk on-- took on the chief of staff's job and you, in a way, were stepping down from an enormous policy role of-- of being OMB director and having been chairman of the House Budget Committee and a major Democrat on Capitol Hill, you took a staff job, in a sense, of being chief of staff with the promise that you'd be the traffic controller, that you would stop some of the g-- more zanier characters, some of them who appear on my show, I must say, from getting into the White House to bother the president, that you would be traffic controller and make it more of a corporate kind of setting. How did Monica Lewinsky get through the gate? How did she get to be a person who on a regular basis would bring so- called materials to the president as if she were a Federal Express messenger? I worked in the White House. We had to take our papers down to the basement and then a Marine would take them to the president. It was very formal. The idea that Monica could be bopping around there on a Saturday and just bop in and see the president, drop off some papers. It doesn't seem like the American presidency that I was used to working in.

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Mr. PANETTA: . . .with having interns open mail and be in the office and have a little sense of what it was like to-- to operate in a-- in a congressional office. Well, you do the same thing in the White House, but most of the interns operated in the old Executive Office Building.

‘MATTHEWS: Right. Mr. PANETTA: Very few operated within the confines of the White House itself.

MATTHEWS: How did this one get through? Mr. Panetta-- Leon-- Leon, you're a great, clean guy. I still think you're probably as confused as I was. How in the world did this young intern get to be friends with the president of the United States?

Mr. PANETTA: Well, hell, you're-- that's the whole case that you're talking about, Chris.

MATTHEWS: OK. Let me ask you this. When Evelyn Lieberman, your deputy, booted her over to the-- to the Pentagon to get her out of the way, what paper passed by you? Did you get any kind of in-- any kind of red light here or yellow light this girl was trouble, she was a stalker, she was hanging around the president, he's getting teased by her or anything like that?

Mr. PANETTA: Well, Evelyn Lieberman was-- as the public needs to know, was one of my deputies. She was deputy chief of staff, and she was responsible for overseeing personnel and working on the schedule as well. And there was no finer first sergeant...

MATTHEWS: Right. Mr. PANETTA: . . . in the White House than Evelyn Lieberman. And so she would be responsible, frankly, for telling staff members or interns or whoever if they were in the wrong place at the wrong time, if they weren't in the proper dress. She would discipline them. She would discipline members of the press as well...

MATTHEWS: Right. Mr. PANETTA: . . . if they were in the wrong place. So she was good at that. And she would usually come to me and she'd say, you know, Look, I did this and I did that, ' and I'd back her up 100 percent. In this case, she came to me and she said, There's this individual. She's hanging around-- inappropriately around the-- the Oval Office. I wanna get rid of her and I'm gonna get rid of her. ' And I said, Fine. Let's do it. '

MATTHEWS: You didn't have to check it out with the president. Mr. PANETTA: No, no, this was-- this wa... MATTHEWS: You ne-- you never checked it. Mr. PANETTA: No, sir.

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MATTHEWS: And what was the-- what was the defining issue here of why she was moved to the Pentagon?

Mr. PANETTA: Ev-- Evelyn Lieberman. When-- when she says somebody's gotta move, it's OK with me.

MATTHEWS: And you didn't have any idea who this woman was at the time, this young girl?

Mr. PANETTA: Nope. MATTHEWS: You never heard of Monica Lewinsky?

Mr. PANETTA: Well, I mean, I-- I-- from now-- now-- now... MATTHEWS: Did she have a reputation of being something of a space cadet? Mr. PANETTA: Now-- now do I-- do I remember her? You know, yeah. MATTHEWS: Does this-- I mean, I would know if a spa-- I would-- I know, but I would remember if a space cadet were wandering around my office.

Mr. PANETTA: No. Exactly. MATTHEWS: And-- and I'd say, Who's that? What's she up to? She seems to have a lot of crazy stuff on her mind, ' or, She seems to be in love with somebody here or something. ' I mean-- and this -- we've seen these talking points where the word stalker' was used and huge liar. ' She's used them about herself. so I don't know. And they were on her mainframe computer. It isn't like it's being denied.

Mr. PANETTA: Chris... MATTHEWS: And here's a woman who‘ s willing to say those things that-- she sounds a little bit odd. But I want to get back to the president, because you said he set the tune. He liked a lo-- a lot of young people around and they made him feel breezy or they would-- they relaxed him or whatever, you-- you suggested. And you said you really couldn't control that part of him. But I wanna ask you

this: Are there anybody-- are there any interns assigned the duty of coming to see the president on Saturday with papers of any kind? Have you ever come across an intern with that kind of duty roster?

Mr. PANETTA: No, of course not. MATTHEWS: OK. We'll be back with more HARDBALL on CNBC. (Announcements) Mr. PANETTA: (From "Meet the Press") I have to tell you that perjury about consensual sexual relations doesn't strike me as being an impeachable offense and I don't think it strikes most of the members of Congress as being an impeachable offense.

MATTHEWS: Mr. Panetta-- Leon Panetta, where would you place such an offense? I mean, we were talking about the allegations that the president may have

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CNBCNewsTranscripts, July22, 1998 Page8 engaged in a relationship with a 21- year- old intern, sort of in a loco parentis situation with him. He was en-- she was entrusted to him by her parents in a situation where she was working among adults, but hardly seen as an adult but as an intern. If there wer-- if ther -- if there was an intimate relationship between these two people, you say it's not impeachable. What is it then? How should Congress and the American people respond to evidence?

The latest polls in The Wall S-- in The Washington Post and AB-- ABC poll, that very clearly shows over 60 percent of the people believe the president had this relationship, that nobody's charging him with rape, obviously. It's a consensual relationship, but they're also charging him with-- or most people believe that he-- that he lied about it when he was under oath. And a lot of people can understand that, too. I have to tell you that. A lot of people I talk to say, Hey, people cover up infidelity. It happens all the time. ' What do we do with this case, though?

Mr. PANEM'A: Well, Chris, you know-- I mean, you-- you and I have, obviously, a standard that goes back to our backgrounds. You know, I'm a pre- Vatican, too, Catholic. I was raised by-- taught by...

MATTHEWS: You're not that old, Leon. Mr. PANETTA: I was taught by nuns and priests and fear of... MATTHEWS: Right. Well, you had the Jesuits like I did, and they can get through anything.

Mr. PANETTA: Yeah. MATTHEWS: So what do we do-- what do we do-- what do we do with the pr-- should the Congress just simply say, if they get a report-- and this evidence is accumulating-- should they simply say, Well, we'll pass a resolution or we'll all give speeches in one minutes, and that'11 be the end of it'? If you can't impeach the guy, you give a nice speech or issue a press release? What do you do?

Mr. PANETTA: Well, you know, Chris, I think we all have to kind of stand back and see, you know, what this thing looks like. Look, if-- if the special prosecutor can't prove obstruction of justice for whatever reason and he can't prove subornation of perjury for whatever reason and the only charge he has is that the president lied about a sexual relationship-- consensual sexual relationship, however you wanna describe it, within the White House, and that's the only charge that goes forward to the House of Representatives, I just have to tell you, you know, again, when you look at the whole picture, is that, in and of' itself, an impeachable offense? I don't 'think so. Now, you know, how the House-- what the House does and how they make that determination is something we're gonna have to see. But, clearly, whether they decide to go with a censure, whether they decide to go with something f-- something less is something that the leadership of the Congress as well as the members are going to have to decide.

MATTHEWS: Did you know Kathleen Willey at the White House, Leon? Mr. PANETTA: NO, I didn't.

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MATTHEWS: What do you make of that case, where the president's accused by-- these talking points clearly are-- three- quarters of which are aimed at covering up whatever the president's conduct, or shaping the testimony of Linda Tripp with regard to the conduct of the president in-- in with-- with Kathleen Willey, a grown- up who came looking for a job in a somewhat bad situation. Her husband was about to commit suicide. She sought a job. She accused on "60 Minutes," we all saw it, the president of the United States of gross behavior toward her. Of course, gross behavior is gross behavior. But if he acted illegally to try to bring a-- to shape or tamper with witnesses in their testimony, would that reach, do you think, the standard of an impeachable offense?

Mr. PANRTTA: Well, again, you-- you know, Chris, we-- we have to see what the special prosecutor ultimately determines here as he looks at the evidence an-- and this investigation wraps up what -- whatever evidence they're-- they're able to pull together. But, clearly, if-- if some kind of obstruction of justice, where the president in some way deliberately made efforts to prevent or inhibit somebody in-- in the course of an investigation...

MATTHEWS: Mm- hmm. Mr. PANETTA: . . . or a criminal offense, then I think that's a more serious charge. I do...

MATTHEWS: Yeah. Mr. PANRTTA: There's no question in my mind. MATTHEWS: Remember Rose Mary Woods? She worked for-- well, one of your old bosses, Richard Nixon, back when you were in civil rights enforcement, and you quit as a matter of honor, we all remember, 'cause you didn't think they were

enforcing civil rights in the Nixon administration. Remember Rose Mary Woods? She was accused of-- in fact, she took the bullet for it. She said, Yeah, I-- my-- my leg reached over about 20 feet across the room and-- and killed about 18 minutes of Watergate tape. ' And she took the bullet.

Mr. PANETTA: Yeah. I remember the pictures. MATTHEWS: Yeah. I remember those cartoons. I sometimes think of Betty Currie, although she's-- well, she's just as political as Rose Mary Woods is. Rose Mary Woods was a loyalist and a real politician, and I don't wanna say-- and nobody really thinks that Betty Currie was some sort of-- just a clerk or a clerical person. She had a tremendous political background and loyalty. What i-- what is her role here? I mean, is she supposed to just sort of say, Well, I'll tell them what I have to tell them, but no more. I'm gonna try tp be loyal an-- and deal with it as best I can, but I've gotta worry about breaking the law myself'? I mean, she's going to be asked if-- if she was out giving gifts to Monica Lewinsky, if she was trying to get-- on her own initiative, trying to get Monica Lewinsky's-- jobs up with Ron Perelman up -- who runs the Revlon company, out-- I mean, these are incredible reaches, it seems to me, for an assistant to-- to about-- to undergo or undertake without some sort of push from the boss, you know. Why is she out getting-- running an employment service for Monica Lewinsky? It seems odd.

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Mr. PANETTA: Well, Chris, look... MATTHEWS: Doesn't it? Mr. PANETTA: Yeah. Let me just tell you, my relationship with Betty Currie in-- in the White House -- I don't know of anybody who is more honest or decent than-- than Betty Currie. She's just the most decent person I've ever met, particularly in that kind of position. You know, most of the time, people in high office will hire hit- and -- hit- and- run people to-- to run the-- run the shop and really s-- really shut the door on people.

MATTHEWS: Right. Mr. PANBTTA: Betty was not that kind of individual. She was very different. She as always nice to everybody who came through. She was always listening to-- to whatever the president wanted to do. She was that kind of person. And whatever she's testified to, there's no question in my mind that she's testified to the truth.

MATTHEWS: Ed Rollins, join in. Mr. ED ROLLINS (Republican Strategist): Well, th-- 1 think-- first of all, I have the greatest respect in the world for Leon, who I've known for many, many years, and-- and having been raised by the Dominican nuns, I-- I-- I have a certain moral compass, too. I think the most...

MATTHEWS: We're gonna have to have a Knights of Columbus meeting later tonight.

Mr. ROLLINS: Right. I-- I th-- 1 think the most-- I think the most telling comments tonight, Leon, is you talking about how you did try and put a discipline in this White House. This girl got around that discipline, and obviously, interns didn't float in and out of...

MATTHEWS: It takes two to tangle. Mr. ROLLINS: Y-- you know, interns didn't float in and out of the White Houses I worked in.

MATTHEWS: Right. Mr. ROLLINS: But the reality is that -- that this president had to basically want to see this girl and everybody else responded either negligently or-- or positively. The bottom line: If this was a college president instead of the president of the United States, a married college president, and he was caught messing around with one of his students, there's no question he'd be fired. Whether the president should be fired or not, I think, is gonna ultimately depend on the evidence that you-- you talked about today. But I think that this...

MATTHEWS: OK. Mr. ROLLINS: . . . I think this is a serious issue.

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MATTHEWS: Ed-- we'll be back with Ed Rollins and Leon Panetta in just a minute on HARDBALL on CNBC.

(Announcements) MATTHEWS: Well, let's commit what I like to call substance abuse. Let's talk about some substantive issue. Leon Panetta, you were chairman of that-- chairman of the-- or, actually, director of the OMB, as well as chairman of the House Budget Committee. There's a big fight brewing between now and Election Day and I guess it's the most important political fight of the year, apart from this whole question, and that is, what do we do with this surplus that seems to be building up, at least potentially? The Republicans want a huge tax cut of up to-- up to $ 700 billion over 10 years. The Democrats under Bill Clinton say, You've gotta save that money to preserve Social Security. ' What do you make of that fight?

Mr. PAMETTA: Well, Chris, let me tell you something, having been involved in that battle to get to a balanced budget and having worked on the economic plan. Now that they've reached a balanced budget, they have to remember that they've got a $ 5 trillion debt out there.

MATTHEWS: Yeah. Mr. PAMETTA: We're still picking up about $ 1 billion a day on interest on that kind of debt. The smartest thing they could do is to put that surplus away, pay off the debt and not start spending it, because the reality is, in a few years, when the baby boom generation hits, we're gonna be back in a deficit, so I think both sides, frankly, ought to back off, let the surplus be used to pay off the overall debt. How that winds up, I don't know. You know, it's a political year. The likelihood is we may get the worst of all worlds, which is a tax cut, plus what-- what the president wants to spend it on.

MATTHEWS: I g-- I-- I guess-- what would be the estimate for how much the federal government's spending in interest now, about $ 400 billion a year?

Mr. PAMETTA: Sure, it's about... MATTHEWS: About 8 percent? Mr. PANETTA: Actually, that's e-- that's-- that's exactly right. It's-- it's-- it's over $ 1 billion a day in interest that's accumulating. That's crazy. We are not in some kind of, you know, totally balanced budget situation. We are in a situation where we've got a huge national debt. It continues to accumulate and it's-- it's great that we've reached a balanced budget, and I think it's to the president's credit, Congress' credit that we're there.

MATTHEWS: And your credit.

Mr. PANETTA: Well... MATTHEWS: You were budget director. Mr. PANETTA: . . . I'll-- I'll take...

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MATTHEWS: And I love the way... Mr. PANETTA: . . . I'll take some credit of it. MATTHEWS: Leon-- Leon, I love it when you talk conservative. Anyway, let's go

to Ed Rollins. What do you make of that? You can't beat Leon for fiscal-- fiscal responsibility. He's a real grown- up. What do you make of the other guys down in Washington?

Mr. ROLLINS: I-- I-- I-- I think we've gone full circle. He's now a Republican again. That's where he s-- that's where he star-- we both started as young Republicans. The...

MATTHEWS: Somebody's accused me of that recently, too. Go ahead. Mr. ROLLINS: I-- I-- I think-- I think the bottom line is this, though: I-- I think that if the president wants to increase Social Security taxes, he should put a bill through Congress because, obviously, if he takes the-- the surplus today and dumps it into Social Security-- I mean, I think that's-- that's a-- that's a false way of raising taxes. I think Republicans feel this is taxpayers' money. If we're not gonna spend it all, then they ought to give it back to taxpayers.

MATTHEWS: Well, politically, what do you think's the smart move? You go out today-- you look at all the polls and people are saying they're most concerned, even though it's 1998 and the economy's rolling, thanks to some smart fiscal and monetary decisions of the last seven or eight years-- but the fact of the matter is that people still have a real sensitivity-- and you know it as well as I do-- about Social Security.

Mr. ROLLINS: Sure. MATTHEWS: They know that this boom ain't gonna last. At some time in the early part of the next century, people like you and I are gonna be out there trying to get our checks, and the fact of the matter is there ain't gonna be a whole lot of money there compared to the number of people waiting in line.

Mr. ROLLINS: Well, then you need to change the system. I mean, I think-- I think that's the-- that's the argument that people have to make here, is that we-- the system will be underfunded because there won't be enough people paying into it. Let's not play funny games. We played gimmick games with the budgets all during the deficit years. Now that we have a little bit of surplus-- and I agree with Leon totally-- the surplus may be there for a short period of time, not a long period of time. You know, let's do something fiscally responsible. We either give it back to the taxpayers or basically don't spend more money. But I-- we have to fix the Social Security system by other-- other means than just dumping more money in there, though.

MATTHEWS: Mr. Panetta, do you think the president was smart in coming out for teaching character in high school? Was that a shrewd move this week?

Mr. PANETTA: Absolutely. I think-- I think it's... MATTHEWS: I mean, pushing-- he-- he's-- he's talking up school uniforms and...

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Mr. PANETTA: Yeah. MATTHEWS: . . .he's sort of offering himself as the national hall monitor, and I think-- I'm just wondering if that's an odd sort of juxtaposition with what's going on in the rest of his life these days.

Mr. PANETTA: Well, the president has had a pretty consistent record in the White House of going after that kind of issue, of doing the school uniforms, of arguing for greater discipline, as well as for additional funding in-- in education. So I-- I think-- you know, he-- he's had-- and it probably goes back to the time when he was governor at Arkansas, but I don't think there's any question but that the American people respond...

MATTHEWS: OK. Mr. PANETTA: . . . to the whole issue of better discipline in schools. MATTHEWS: Leon Panetta, thanks for joining us from San Francisco. Great man. Mr. PANETTA: Thank you. MATTHEWS: 'Rivera Live's" up next with the latest on the Clinton investigation. Join me next time for more HARDBALL.

LANGUAGE: English LOAD- DATE: July 23, 1998

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Sunday, July 26, 1998 Interview: Rahm Emanuel, adviser to President Clinton, discusses the Ken Starr

investigation and managed care MR. RUSSERT: And we're back. Rahm Emanuel, welcome. MR. EMANUEL: Good morning. MR. RUSSERT: As you heard, I just reported that the suspect, Russell Weston, was seen outside the White House on Thursday and again on Friday. And according to senior law enforcement officials, after he was wounded, he was mumbling President Clinton's name.

YR. EMANUEL: Mm- hmm. YR. RUSSERT: What do you know? MR. EMANUEL: I mean, I know what you reported; I know what I've read in the paper. We've had-- Chuck Ruff in the counsel's office has been briefed by Secret Service, and then I think there's been some information, but that's about-- 1 think what the public has is the correct information as we know it right now.

MR. RUSSERT: Do you think incidents like this bolster the head of the Secret Service, Lou Merletti's, comments and attitudes that things like this can happen within moments and all the more reason why Secret Service agents have to keep in close proximity to the president at all times?

MR. EMANUEL: Tim, I think you and I have talked-- I mean, both of us have family that are in the law enforcement community. I have an I uncle who's a police officer in Chicago. And every morning those officers get up, they say goodbye to their family, and that could be the last time they see them. I think it would be inappropriate at this time to kind of look at the policy implications. I think there will be time for that, and plenty of people will have views about that and there should be a discussion about that. I think we're at a ime now-- 1 think the best thing we can do as a nation, as one Lily, is make sure that the families of those slain officers know

:t they have the prayers and the thoughts of the American people ,., ch them, regardless of what anybody's particular view of any policy

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_26/ 98 MTPRESS (No Page) sue related to this incident is.

Page 14 MR. RUSSERT: In my conversation with Congressman Thomas, we talked about pressures to prevent this from happening again. One of the suggestions is a construction of a visitor's center on the east front of the Capitol, where people will be funneled into it, and enhanced security, a cost of $135 million, a lot of discussion as to whether public funds should be used for the building of that visitor center. Would the Clinton administration look at funding such a visitor's center?

MR. EMANUEL: Well, we haven't discussed this yet at the White House. Obviously, this is something we're going to want to work with Congress. I wouldn't rule it out, obviously, at this point. That would be something proper. But I think in all those instances I don't want this to get ahead. That will be one of the things that will be looked at. I think what Mr. Lou Merletti has said in the past is something, obviously, people will think about and discuss. And we should have those discussions, particularly to this notion of a facility going into the House and Senate chambers that's outside. That's where the public flows. And if people think that's the r rrect thing to do for security purposes, obviously. We add our

~- 1 recommendation on Pennsylvania Avenue and immediately we acted >n it for security purposes. So I think you have to take steps _ .Ite that when people recommend, for security purposes.

MR. RUSSERT: You wouldn't have any objection to using public funding to build such a visitor's center?

MR. EMANUEL: You know, Tim, it's a fair question. I'm, obviously, not going to rule it out. I can't say yes or no at this point. You know, obviously, if security thinks it's important, it's something we're going to look for and look to.

MR. RUSSERT: And let me turn to the headlines of the day. Clinton Receives Order to Testify in Lewinsky Case. First Sitting President Subpoenaed to Appear at a U. S. Grand Jury. This president has made history.

MR. EMANUEL: So has Ken Starr, has made history. He's the first office of independent counsel that ever had two, as we know, ongoing investigations of its office. It has one with Michael Sheehan looking into it and it has another one by the D. C. Bar that we know about. They're looking into the conduct, both professional and ethical, of that office. And I'm-- go ahead.

tiR. RUSSERT: Will the president comply with the subpoena? LY~ R. EMANUEL: Well, first of all, don't know the nature of whether

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!6/ 98 MTPRESS (No Page) Page 15 2 exists or not, but what we do know is that Mr. Kendall, the president's attorney, is working with the office of independent counsel to get them the information they need. And I also think it's important to know that, as you know, Tim, in the last four years, while this office has been going on and $40 million has been spent, in fact, the president has found a way, with Mr. Kendall working with Mr. Starr, to get the information that the grand jury needs. Twice before he has testified.

MR. RUSSERT: So somewhere, somehow this president will testify under oath about the Monica Lewinsky situation?

MR. EMANUEL: David Kendall is instructed to work with Ken Starr to find a way to get the information that the grand jury needs. And we have done it in the past, and worked it out with the office of independent counsel over the last four years, as has Mrs. Clinton, I think, testified three times. So we have found a way to get the information the grand jury needs.

MR. RUSSERT: The president wants to testify under oath? MR. EMANUEL: The president wants to get the information that the L, nd jury needs and has instructed Mr. Kendall to talk to Mr.

lrr to do exactly that. MR. RUSSERT: Let me talk about an issue of credibility. As you know, NBC News called you three times on Thursday and five times on Friday...

MR. EMANUEL: Right. MR. RUSSERT: . . .and asked specifically whether a subpoena had been issued based on information we had obtained. And eight times we were told, no. Did you mislead us or did the White House lawyers mislead you?

MR. EMANUEL: Tim, what I said is we don't comment. We don't issue subpoenas and we don't comment on them. I can't characterize whether we've ever got them or whether we've ever received them or what the content of them. I don't know to that fact.

MR. RUSSERT: But we specifically asked whether you received the subpoena, and you said, no.

MR. EMANUEL: Tim, no. What we did, I discussed with you and I s .d we don't comment on them. To my knowledge, I don't know if l. Lve gotten it or not. I said exactly that to you.

MR. RUSSERT: Why then at 11: OO on a Friday night, after the Copr. 0 West 1998 No Claim to Orig. U. S. Govt. Works

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!6/ 98 MTPRESS (No Page) Page 16 gitol Hill shooting, did the White House kind of put out the word the subpoena had been received?

MR. EMANUEL: Now, Tim, I think what the White House said is what we've said with Jim Kennedy, what Michael McCurry said and what I have said here. We don't issue them, we don't comment on them.

MR. RUSSERT: So we can expect, inthe very near future, the president to be under oath and answer questions from Ken Starr?

MR. EMANUEL: I think what you can expect is that Dave Kendall is now working with the office of independent counsel, Ken Starr, to find that information and to get-- find out a way to get the information to the grand jury.

I'd like to make one other note, Tim. You know, August 5th will be four years of the anniversary of Ken Starr's appointment. Four years ago and about $40- some odd million later, there has not been a single report by that office on the issue of Whitewater, on the issue of the travel office, on the issue of the files.

qe is-- the office of independent counsel under Ken Starr's -Adership is incapable of writing a report that would clear the

sident or the first lady. And I want you to know August Sth, ,, j. s than two weeks from now, is the anniversary of Ken Starr's appointment. I don't think any American ever thought four years ago that we would be at this situation or that office has stayed open and spent $40 million, that we would not be able to come to a conclusion over a 24- year- old real estate deal, over whether, in fact, what happened with the travel office. And he is incapable of writing a report that would clear the president and the first lady.

And he has literally got one standing-- what we do know it's one of the longest standing investigations, one of the most expensive investigations, one of the most intrusive investigations, including now has a unique distinction and hallmark that it's the only investigation that has two ongoing investigations into it.

MR. RUSSERT: Let me ask you about one other investigation. Charles Labella, who was appointed by Janet Reno to head up the Justice Department investigation into campaign contributions; Louis Freeh, the non- partisan director of the FBI-- both of them have said unequivocally, there needs to be an independent counsel to look at campaign irregularities, both of Democrats and Republicans. Why won't the president support these two men?

k- l R. EMANUEL: The decision on the independent counsel is made ed on the law and the fact, and that's the way the attorney g= neral's going to make her decision, and that's what she's going to

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,26/ 98 MTPRESS (No Page) Page 17

. She's going to weigh everybody's opinion-- she has said it publicly as recently as Thursday -- that decision's based on the fact and the law.

MR. RUSSERT: But if the president wanted to pick up the phone and say, "Charles Labella, your hand- picked chief investigator, the director of the FBI, have found the grounds for an independent counsel. It is important that we clear up this mess, Madame Attorney General. Please, I'm imploring you, appoint an independent counsel"?

MR. EMANUEL: Well, I think, first of all, the attorney general makes this decision based on fact and law, Tim. She has shown before she's ready to make that call on the office of the independent counsel; surely, shown that many times before. And on this situation, she'll decide based on the fact and the law and not based on any public pressure from any quarter.

MR. RUSSERT: And joining me in questioning today is David Broder of The Washington Post. David.

YR. BRODER: Mr. Emanuel, the couple issues that actually affect p-= ople's lives, starting with the State of the Union address and,

?quently, since then, the president has asked for legislation that . did give patients in managed- care programs some rights.

MR. EMANUEL: Mm- hmm. MR. BRODER: On Friday, the House passed a patients' bill of rights bill that guarantees payment for emergency- room services, ends the gag rule on doctors, gives women direct access to gynecologists, provides internal and external appeals process. Why is the president threatening to veto that bill?

MR. EMANUEL: Well, it's simple, David-- is that the Gingrich bill falls far short of what the president seeks in the bipartisan Dingell- Ganske bill that represents Congressman Dingell, a Democrat, and Congressman Ganske, a Republican. It doesn't-- it leaves millions of Americans out of coverage. It doesn't guarantee heart specialists and cancer specialists. It doesn't guarantee the continuity of care in case of-- while you have a family doctor, that doctor's cut off from insurance, it doesn't guarantee that you get to continue with that doctor. It also doesn't end the bad practice of giving a bonus to doctors who deny care. And so it doesn't meet, I think, one of the most important principles guaranteed almost every

?rican, a patients' bill of rights. Millions of Americans will be *ft out by that bill, and I don't think we should create

sand- class citizens when it comes to a patients' bill of rights. c., should have coverage for everybody, not limited and discreet.

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.r- 126/ 98 MTPRESS (No Page) Page 18 -lions of Americans will be left out. MR. BRODER: Accepting for the moment at least that it doesn't do everything that the administration would like, it does contain guarantees that are not now in the law. Many people think that the Democrats would rather have this as an issue for November than have a bill.

MR. EMANUEL: David, you've been here a long time in Washington. You've watched this for eight months. Let me just go over the history. Two years ago, the president's commission called for a patients' bill of rights. He announced it in his State of the Union. And in that eight months, he also signed an executive order guaranteeing 85 million Americans a patients' bill of rights who are under Medicare, Medicaid and federal health plans. And in those eight months, the leadership in the House and the Republican leadership called on the insurance industry to open up their wallets to help defeat this bill-- any bill. And John Linder, the head of the Republican congressional campaign committee, recently said, "All we need is a vote on this to protect ourselves." Well, the goal here is not to protect the Republicans in the House; the goal here is to

,e a patients' . bill of rights to Americans with health insurance. 1R. BRODER: We should note... MR. EMANUEL: And this bill falls far short, and the Dingell- Ganske bill does accomplish the goals of every person getting a patients' bill of rights and should not limit that.

MR. BRODER: We should note just for the record that neither the president's commission nor the executive order contains provisions for an external lawsuit.

MR. EMANUEL: Right. MR. BRODER: Let me ask about one other issue quickly. MR. EMANUEL: Sure. MR. BRODER: Tax cuts. Is there a tax cut that the president is willing to sign into law this year?

MR. EMANUEL: Well, two things. One is, you know that in his own budget, there is a tax cut for child care and there's a tax cult for rptirement savings. What his principle is is that we must have c ial Security first when it comes to the surplus and that we cannot

czve a tax cut that eats into the surplus that then postpones any ial Security reform, which is essential. And I think now we have L, gartisan agreement in the Senate. So he is for a tax cut. It's

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bf- 26/ 98 MTPRESS (No Page) Page 19 his budget. It's one that's paid for. It's child care and retirement as well as environmental tax cuts, On the'issue of tax cut versus Social Security, the president's belief is, we should not dip into the surplus to pay for a tax cut. We need to basically preserve the surplus, in order, first, to fix Social Security. That's our first goal. Then we can look at that.

MR. BRODER: On Social Security, tomorrow, the president is in Albuquerque for another roundtable. Will he leave open the door to private savings accounts as, part of the Social Security system, or is he going to close the door to that?

MR. EMANUEL: No, the whole commission and the whole one- year dialogue on Social Security is to, literally, A, focus on what the level of the problem is, what it needs to strengthen and preserve Social Security and see what other options are. He's not going to close off anything or limit anything or say, "This has to be part of it." That will be part of the dialogue.

I want to answer one other point and reaffirm something. When it comes to the debate about tax cuts and Social Security, this is in , Congressional Daily, what a senior GOP aide said about the House

Republicans. I think it's very telling. He said, and I read from "They need to realize," referring to the House Republicans, "that =y are out of time, out of resources, out of credibility with the Senate. Because of their stupidity and ineptitude, there is no feasible way we can get a major tax cut through Congress before adjournment. The Senate aide said House leaders are embarked on an exercise that is futile. This is not some Mickey Rooney, let's put on a show, back- lot production." Ladies and gentlemen of the jury, I couldn't have said it better.

MR. RUSSERT: That has to be the last word. Rahm Emanuel, thanks very much for joining us.

MR. EMANUEL: Thank you. MR. RUSSERT: Coming next, for the Republicans, Don Nickles of Oklahoma; for the Democrats, Bob Kerrey of Nebraska, Then, former

r White House counsel Jack Quinn and former federal prosecutor Barbara Olson square off on Ken Starr versus Bill Clinton.

(Announcements) Program Time: lO: OO- 11: OO AM Nielson Rating 4584700 R..- irence: 980726

d Count: 2769 I L6/ 98 MTPRESS (No Page)

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Tab 52

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2279

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA -

-. _- __. .- - - -1 - 1 ,_ ._. - )- .- ) Misc. No. (NH@ IN RE GRAND JURY PROCEEDINGS )

1 1 (UNDER SEAL)

MOTION OF WILLIAM J. CLINTON FOR CONTINUANCE

William J. Clinton, through undersigned counsel, hereby moves this Court for a two- week continuance, to August 11,1998, of the return date of a subpoena delivered to his counsel seeking the President’s testimony today, July 28, 1998, before the grand jury. The reasons why this Motion should be granted are set forth in the accompanying memorandum.

Respectfully submitted, D& id E. KkndaIl(# 252890) Nicole K. Seligman Max Stier Alicia L. Marti WILLIAMS & CONNOLLY 725 12th Street, N- W. Washington, DC 20005 (202) 434- 5000

Counsel for Movant William J. Clinton

2280

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

1 1 Misc. No. (NI3. J) IN RE GRAND JURY PROCEEDINGS )

1 1 1 (UNDER SEAL)

Upon consideration of the Motion of William J. Clinton for Continuance and any opposition thereto, the motion is GRANTED.

It is hereby ORDERED that the return date of the subject subpoena is continued to August 11, 1998.

SO ORDERED on this the day of , 1998. NORMA HOLLOWAY JOHNSON

2281

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

) ) Misc. No. (NH@ IN RE GRAND JURY PROCEEDINGS )

1 1 1 (UNDER SEAL)

MEMORANDUM IN SUPPORT OF MOTION OF WILLIAM J. CLINTON FOR CONTINUANCE

For the first time, a sitting President has been subpoenaed to testify before a grand jury. On Friday evening, July 17, 1998, the Office of Independent Counsel (“ Or,“) delivered a subpoena to counsel attempting to compel President William J. Clinton to testify before the grand jury today, Tuesday, July 28, 1998. In response, President Clinton, through counsel, has indicated a willingness to provide voluntary testimony for the grand jury. Despite this response. the OIC has refused to continue or withdraw the subpoena returnable today, necessitating this request to the Court. This refusal creates the prospect of a constitutional confrontation that, with a short continuance, may well be avoided. Accordingly, President Clinton moves this Court for 2

two- week continuance of the return date of the subpoena, to August 11,1998, to permit the parties to seek such a resolution or adequately to prepare appropriate legal papers if a resolution cannot be reached.

I. Background

Six times after January 21, 1998, the OIC invited President Clinton to testify before the grand jury investigating the Monica Lewinsky matter. & Exhibit 1 (correspondence between Mr. Kendall and the OIC regarding the President’s testimony). In response, counsel for President Clinton outlined serious concerns to be addressed before any such testimony would be

2282

considered, including issues that had arisen over the origin and conduct of the OIC’s Lewinsky investigation. The OIC’s most recent mention of the possibility of such testimony was almost four months ago, on April 3,1998, with a response by Mr. Kendall on April 17,1998. See Exhibit 1. The OIC did not respond to the April 17 letter and did not raise the issue with counsel for the President in any way in the almost four months since its last letter.

After this long period of silence, on Friday, July 17, 1998, without warning, the OIC delivered a subpoena to counsel for the President purporting to require President Clinton to testify before the grand jury today, July 28. Exhibit 2 (subpoena and accompanying letter). At the time, President Clinton was traveling outside of Washington, D. C., and he did not return until early Tuesday, July 21, 1998. In light of the need to consider properly the serious issues presented by the subpoena, counsel for President Clinton telephoned Mr. Bittman (of the OIC) on July 22, 1998, and requested that the OIC provide another week, until August 4, for counsel to respond to the July 17 delivery. On July 23, 1998, the OIC offered three more days, if the President would agree not to seek any additional time from the OIC or the Court. Exhibit 3 (July 23, 1998 Letter of Mr. Bittman).

On July 24, 1998, counsel for President Clinton informed the OIC that the President “is willing to provide testimony for the grand jury, although there are a number of questions relating to the precise terms and timing of the testimony which must be worked out.” Exhibit 4 (July 24, 1998 Letter of Mr. Kendall). Counsel for the President also requested that the subpoena be withdrawn while these issues were resolved. The OIC declined to withdraw the subpoena. Exhibit 5 (July 24, 1998 Letter of Mr. Bittman). Subsequently, by letter yesterday, Mr. Kendall wrote to the OIC with a detailed and specific proposal regarding both the format and timing of potential testimony by the President. Exhibit 6 (July 27, 1998 Letter of Mr. Kendall).

2283

Despite this responsive and good faith offer, and the prospect of immediate continuing negotiations, the OIC refused to withdraw or even continue the return date of the subpoena beyond 1: 30 p. m. today unless “the President commits in writing to testify on a date certain on or before August 7, 1998.“. See Exhibit 7 (July 27,1998 Letter of Mr. Bittman).

II. Argument

The OIC’s denial of a brief continuance here is wholly unreasonable. There is a very real possibility that the President and the OIC will be able to agree on timing and procedures whereby the President may provide information to the grand jury. The subpoena plainly raises fundamental separation of powers concerns, - see Exhibit 8 (“ Starr Subpoena- Poses Constitutional Conflict,” Chicago Tribune, July 27,1998); (Interview of Professor Paul Rothstein, ABC News, July 26,1998), which have not previously been presented to a court and adjudicated. The Supreme Court observed in the Paula Jones case that “although Presidents have responded to written interrogatories, given depositions, and provided videotaped trial testimony . . . no sitting President has ever testified, or been asked to testify in open court-” Clinton v. Jones, -U. S. -, 117 SCt. 1636, 1643 n. 14 (1997). There may, however, be no need to resolve the novel question whether a President may be compelled to testify before a grand jury. But more time is needed to explore whether a resolution short of litigation is possible.

The OIC’s assertion that it needs the President’s testimony on or before August 7, 1998, is patently unfounded. The Whitewater investigation has dragged on for more than four years. The OIC last raised the question of the President testifying in early April, and it then did not respond in any way to counsel’s April 17 letter on this subject. As the OIC well knows, in the past when the President’s testimony has been sought, it has taken weeks to schedule an appropriate date, because of the President’s many commitments and because of the length of time his schedule is set in advance. In the present case, counsel have presented the OIC with a

2284

“date certain” for his testimony which is consistent with the President’s schedule and other obligations. The OIC has stated that an earlier date is necessary. Because the President has not immediately agreed, the OIC has refused to continue today’s return date at all. This obstinate refusal demonstrates a desire to precipitate a possibly needless battle, rather than a statesmanlike effort to avoid one.

The OIC’s position is particularly arbitrary here because there are no impending v deadlines, no statutes of limitations are about to run, and no trials are imminent. There is simply

no justification for the OIC’s deadline except its own fiat. This captious and cavalier treatment is particularly inconsistent with the OIC’s often professed “profound respect for the institution of the Presidency.“ ’ While the OIC has stated that it “fully acknowledge[ d] that the President has immense and weighty responsibilities” and that it “want[ ed] in every way to take fully into account those grave duties of state,“ 2 its actions here belie these sentiments and also show how hollow is the OIC’s recent representation that if the President will agree to testify “we and the grand jury -- as we have previously stated -- will accommodate [the President’s] schedule if he cannot appear on the 28* [of July].“ 3

For whatever reasons, the OIC insists that the President agree in writing by I: 30 p. m. today to testify on or before August 7. As explained in detail in a letter from counsel to the President provided yesterday to the OIC, see Exhibit 6, that date is wholly unacceptable, given the President’s schedule and the need for the President to prepare properly for his testimony.

1 Exhibit 1 (Letter of Robert J. Bittman, Esq., to David E. Kendall, Esq., dated March 13, 1998).

2 Exhibit 1 (Letter of Robert J. Bittman, Esq., to David E. Kendall, Esq., dated March 2, 1998).

3 Exhibit 2 (Letter of Robert J. Bittman, Esq., to David E. Kendall, Esq., dated July 17, 1998).

2285

When the Supreme Court indicated last year that a civil case could proceed against a sitting President, it nevertheless insisted that the “high respect that is owed to the Office of the Chief Executive . . , should inform the conduct of the entire proceeding,” and it stressed the importance of avoiding “interference with the President’s duties.” Jones v. Clinton, - U. S. -, 117 S. Ct.

1636, 1650- 5 1 (1997). The Court of Appeals for this Circuit only yesterday, in a case arising from the OIC’s investigation, emphasized the “deference due to the President” as he seeks to meet both public and private legal obligations and ruled that a court “must accommodate the unavoidable, virtually full- time demands of the office.” In re: Bruce R. Lindsev (Grand Jurv Testimonv), No 98- 3060 (D. C. Cir. July 27, 1998) (slip op. at 36, 38). 4

Given the constitutional significance of the issues presented by the subpoena, the lack of any colorable reason to deny a short continuance, the possibility that an agreement might be reached which would accommodate the concerns of both the OIC and the President, and the long delay which will certainly follow if a legal confrontation is forced, we respectfully submit that the OIC’s refusal to continue the subpoena is irresponsible, unreasonable, and oppressive. When the Supreme Court decided the Jones case, it did so on the basis of an explicitly stated assumption that any testimony from the President “may be taken . . . at a time that will accommodate his busy schedule,” Clinton v. Jones, sunra, 117 S. Ct. at 1643. It is just such an accommodation that movant seeks and that the OIC arbitrarily resists.

4 The Court of Appeals noted that “there is a tradition of federal courts’ affording ‘the utmost deference to Presidential responsibilities.“ ’ Id. at 39.

2286

CONCLUSION

For the foregoing reasons, President Clinton’s motion for a two- week continuance should be granted.

Nicole K. Seligman Max Stier Alicia L. Marti WILLIAMS 6% CONNOLLY 1

725 12th Street, N. W. Washington, DC 20005

(202) 434- 5000

Counsel for Movant William J. Clinton

2287

CERTIFICATE OF SERVICE

I certify that I have this 28th day of July 1998 caused one copy of the foregoing Motion of William J. Clinton for Continuance, memorandum in support thereof, and proposed Order to be hand delivered to:

Robert J. Bittman, Esquire Independent Counsel Offke of the Independent Counsel 100 1 Pennsylvania Avenue, N. W. Suite 490- North Washington, DC 20004

2288

2289

Tab 1

2290

2291

Office of the Independent Counsel

1001 Pennsyhmnia .+ eme. IV W Sati@ 490- North

Washingro~~ DC 20004 (202) Sl44588

Fax (202) SI4- 8802

February 2, 1998 David E. Kendall, Esq. Williams & Connolly 725 Twelfth Street, N. W. Washington, D. C. 20005

Re: William Jefferson Clinton, Dear David:

As you know, President Clinton has publicly pledged to cooperate fully with the investigation involving Monica Lewinslcy.

Las: Wednesday, January 28, I invited President Clinton, on behalf of the grand jury, to testify before the grand jury this Thursday, February 5, concerning matters relating to Ms.

Lewinsky. You indicated in our conversation that you would get back to me as to whether the President will so testify. The grand jury awaits the President's decision; please advise me as socn as possible what the President decides.

Sincerely, Robert J. Bittman De? uty Inde zendent Counsel

2292 Office of the Independent Counsel

February 4, 1998 '. Dakid E. Kendall, Esq.

Williams 6 Co~ olly 725 Twelfth Street, N. W. Washington, D. C. 20005

Re: William Jefferson Clinton Dear David:

Although the President has declined the invitation to ttszify before the grand jury tomcrrsw, the grand jury's izves'i L- gation continues apace. Cn behalf of the grand jury and in an effort to accommodate the President's schedule, we respectfully invite the President to testify before the grand jury next Tuesday, Wednesday, or Thursday, February 10 to 12.

The grand jury would like to complete this investigation, as the President stated, "sooner rather than later. . . . [and] as quickly as we can." Kindly advise me by noon this Friday as to whether the President accepts the invitation to testify.

Sincerely, Robert 2. Sittman Deputy Independent Counsel

2293

Office of the Independent Counsel

IO01 Penrqvhania Awmt, IV. W.

Suite #O- North

wadlhgto~ Dc 20004 (202) 214- a688 Fm( 2~) 5144802

February 9, 1998 David E. Kendall, Esq. Williams h Connolly 725 Twelfth Street, N. W. Washington, D. C. 20005

Re: W! 11 iam Jefferson Clintor. Deaz David:

Last Wednesday, we, on behalf of the grand jury, extended a second invitation to the Pre sident to testify before the grand jury about his relationship with Monica Lewinsky. You did not respond to the invitaticn by last Friday, as requested in my letter. The grand jury's work continues. Notwithstanding your failure to respond, the grand jury would be pleased to accommodate the Pre sident's testimony any day or time this week.

Let me make our request specific and clear: the grand jury deserves to know whether the President will respond, favorably, to the invitation. Such an invitation is, of course, fully consistent with our profound respect for the Presidency in our system of separated powers. To that end, we have consulted with the Chief Judge, and she has assured us that the grand jury can accommodate the President's scheduling needs should the President choose to tell his story to the grand jury.

For planning purposes, kindly let me know if the pr3sidey- t wis‘ nes to testify before the grand j? Jry this week.

t:? F Pr3siier, t If

CaF! l” S+ . . - 2;; 2" 'Z this wee'r, Flsase let me know bl/ F ridai, February 13, whether the President wishes to testify

2294

David E. Kendall, Esq. February 9, 1998 Page two

before the grand jury, and if so, when. If I do not hear from you by that date, we will assume that the President will not voluntarily provide testimony before the grand jury. In that event, we will inform the grand jury of this turn of events.

Sincerely, Robert J. Jittman Deputy Independent Counsel

2295

DAVID E KENDALL (202) 434- 514s

LAW OFFICES wILLJAm 8 CONNOLLY

725 TWElFiHm, N. W. WASHINGTON, D. C 20005- 5901

Qoa 434-! sooo - FAXQO214W5029 .

February 13, 1998 CONFIDENTIAL RULE 6( e), F. R. GRIM. P. GRAND JURY StiMIssIoN

e Hand Robert J. Bittman, Esq. Deputy Independent Counsel OfCice of the Independent Counsel 1001 Pennsylvania Avenue, N. W. Suite 490- North Was kington, D. C. 20004

De ar Bcb: This will respond to your letters dated February 4 and 9, 1993. I was unable to respond to your February 4 invitation by the Friday deadline you had indicated in your letter because I

was in the process o f dealing with prejudicial and false leaks of informa+ ,ion about your investigation. I set forth my position on tha: matter in brief public remarks Friday afternoon and in a 15

page letter to Judge Starr which I h& d- delivered to your office that same afternoon. These leaks are highly unfair and prejudicial to the President and others, and, as you may know, on Monday I filed a sealed motion with the Chief Judge seeking judicial remedies in an effort to enforce the secrecy and

C- p 4.- h -V& r* =; An- tiality of the investigative process. I acknowledge your invitation for the President to appear before the grand jury next week. The President has the greatest r2s; ect for the grand ju, ry. However, under the circumstances, it

iS impossible to accept this invitation. The situation in Iraq car -zinues to be dangerously volatile, and this has demanded much cf be-- + '11 Prssidect's time azd attention. The President also has a hea- r,- tray; eI schedule at present. Our access to him has xectssarily beer? limiztd. Moreover, as I informed you during our Feb r- A airy 3 telephone conversation concerning this matter, we have

slm-,- -11 had inadequate opportunity to prepare so that we may give ouz cli3r. t th2 informed advice of counsel which he, like every . ot,", er cLt1zen, des2rves. Your r= Gp, ni: letter references your

2296 WZLIAMS a CONNOLLY

Robert J. Bittman, Esq. February 13, 1998

Page 2 office's aprofound respect for the Presidency in our system of separated powers: However, I am certain that you understand why, in light of the well- publicized and questionable

investigative techniques of your office, we feel we would be derelict in our professional duty to a client unless we assured ourselves that we had adequate opportunity to advise that client appropriately.

In the event you decide to "inform the grand jury of this turn of events", as stated in your letter, I would respectfully request that you also read my letter to the grand jury and make my letter part of the grand jury record.

I thank you for your courtesy.

2297

Office of the Independy.. c” ounsel

Febnary 21, 1998

Dav. i. d E. Kendall, Esq. Williams b Connolly

725 Twelfth Street, X. 1. Washington, D. C. 20003

Re: William Jeffersen Ciinton Des:: Da- Cc! :

We regret the President’s decision not to appear before tlx grand jxy at this time. in lighr of the President's past ar_ d continuing pledges to cocperate with this investigation, we aga:- 3 invite the 3resident tc tes" ' LAY befcre the grand jury aboct his relationship wizh FonLca Lewinsky. We make this invitation ful.. y sensl: ive to the inportanr dx: ies a& responsibilities of the Presider- t. Moreover, as stated in my iast letter, I havG disfxssed this tiatter with Chief Judge Johnscn, and she has ind;, cated that the grand jury will ‘accommodate any special scheduling needs of the Presider, t. We are ready to hear t;? e Prezident's testimony. Kir, dly let me know by Iriday, February

27, whether the Presidea; will agrte to testify before the grand jur;! at any time.

Sincerely,

2298

msel Office of the Independent IO01 Pcnnryhrcmia Averne. N. W. Suite 49& Vorth

Wadington DC 20004

(202) SI4- 8688

Far (202) 5 Id- 8802

March 2, 1998 H24ND DELIVEXED David E. Kendall, Esq. Williams C Connolly 725 Twelfth Street, N. W. Washington, D. C. 20005

Re: William Jefferson Cii ntgp -.. .

Dear David:

Based on your previous declinaticns ax! your failure to respond within the time outlined in my letter of February 21, 1998, we assume that the President has declined our invitation to testify before the grand jury. the President With this letter, we again invite

to provide the grand jury with information concerning its ongoing investigation.

In regard to the various explanations you have been kind enough to advance for declining our four invitations, I note that (1) the state visit of Prime Minister Blair has passed; (2) the "situation in Iraq" has, thankfully, eased; and (3) you have now had some six weeks to "prepare" the President. & letters to Robert J. Bittman from David E. Kendall dated February 4 and February 13. We fully acknowledge that the President has immense and weighty responsibilities. We want into account in every way to take fully

those grave duties of state. Yet since this matter arose, the President has -- with all respect -- found t; rna ta - - play golf, attend basketball games and political fundraisers, and enjoy a ski vacation. i -7 cc : -' ', 0 = - the ___ We assure you that the grand jury's

j ui:/ rgmai.: D-- asident will not take In- and we -- as we have always been -- ezier and the grand

ts accommcdats the D- ZAC: A,-- r 3 sl'ya4.. 's - -- v- i-.._ -..- dU--.

2299

David E. Kendall, Esq. March 2, 1998 Page two

Kindly advise me by noon Wednesday, March 4, 1998, whether the President will accept this invitation. If I do not hear from you by that time, I will assume the President declines the invitation. I look forward to your early -- and, I hope favorable -- reply.

Sincerely, Robert J. Bittrnan Deputy Independent Counsel

2300 DAVID E. KENDALL

(202) 434- 5145

IAW OFFICES w- nLLAm 8 CONNOLLY

725 TVELFlXS- IXZT, N. W. WASHINGTON, D. C 20005- 5901

(202) 434- 5000 - FAxQO2) 434- 5029

March 4, 1998 CONFIDENTIAL, RULE 6! e), F. R. CR1M. P. GRAND JURY SUBMISSION

Robert J. Bittman, Esq. Deputy Independent Counsel - . Ofil. Ce of the Independent Counsel

1001 Pennsylvania Avenue, N- W. Suits 490- North Washington, D. C. 20004

Dear Bcb: This will respond to your letters dated February 21 and March 2, 1993. I apologize for my delay in responding. The fault is mine: as you know, we filed a lengthy reply on Friday in the sealed "leaks" matter, responding to your opposition to our original motion for contempt sanctions. That matter simply absorbed my time, but I am now able to give your correspondence the attention it dese, rves.

As I hcpe you are aware, the President has the greatest respect for the grand jury. I appreciate your own ackncwledgeaent in your March 2 letter of the "grave duties of state" which are uniquely the President's and the "immense and weighty respcnsibilities" he must discharge. The buck really does stop with the President for decision- making on a vast range of issues thaz are critical to this country's safety and economic security.

-Gyi‘ a '- _ -_ I, iS true that net every moment of the da:; is abscrbed by th? dctiss of office, the President is t? Z< Zr& Zr~ l. EdZil'i bc3- i or, a rar. ge Cf i; nccrZan: public 135=;; 23, sclxe

G f Which art visible and some of which are not. In our judgment, our a.-; 1 i -1 I&^_- / to hayfe access to the President is simply

i: su5f: ci? nt a: the present time for purposes of rePreser. z-. ;-~ g him ad5riarelv in the matters with which you are concerned. -

2301

WILLIAMS 6 CONNOLLY Robert J. Bittman, Esq. March 4, 1998 Page 2

Accordingly, he will, on our advice, not be able to accept your invitation for him to testify at this time. I am certain you would agree that the President deserves the same right to the informed assistance of private counsel as does eve-- y other citizen.

Your most recent letter remarks that the situation in Iraq has "thankfully, eased." .this may be true, While there are some respects in which

the situation remains highly volatile, as a glance at today's newspapers will reveal. The continuing Southeast Asian economic crisis and the Bosnian situation also demand a great deal of the President's time, as dc other national security issues, many of which are highly confidential.

On the domestic front, the Presidsnt's scheCu1e is egcally congesied. _ __ 9~ Adminis: r ation's pro_ cosee budget was submitztd to Congr2ss last month, and the Preside,-,: is in the midst of majcr negotiations with the Republican majcriri2s cv2r kzy budgetary obj2czives, such as reserving the bulk of the budgetary sur;: lus for Sccial Security. Other Administraticn initiarives are at cr- tica; stag2s. The President is az: 2np: ing tc hammer cut

national iogislation around a tobacco liasilicy s2cti2mesc. IMCZC!

"town hall" ___. mep+; ngs are scheduled ccncerning the Presiden: 's race initiative, which will focus on the need for szrengchening the Equal Employment Opportunities Ccmmission and the Civil Rights Divisicn of th2 Justice Departmen=. Tbs.- s ;- *- A.?-- -3 also currently in the Whit2 House a sustained focus on major health care FroFosals (expanding Mtdicart coverage to persons ag2 55- 64 who have lost their health coverage due t3 nc faul: of their own; securing passage of an HMO paiif? nt "bill of rights"), cn new education legislation (enacting strong national educational standards; trying to improve math and science achievement), and on highway 1 egFslation/ autc saf2ty bills (f2deral standards for a 7 LOWEZ blocc? alcshcl definition in Di- I cases).

The President also has an e: ctremel; J heav- 1 fortlgn and domestic travel schedule. He will be out of the countr-/ for nearly three weeks this month and next in Africa and Scuth America. Thes2 ar2 majcr Stats visirs to key szrazrglc parts Of the wcrld, and a considerable amount of pre- departure prtparasion, rtvi2w, and study is r2guired, w?. ich will absorb a s- i..- -Zil- ; -. T; fir-- k . amccnt of the Pr2srs2nZ's tiir. 5 in this cocr. try.

2302

WILLIAMS 6 CONNOLLY Robert J. Bittman, Esq. March 4, 1998 Page 3

degree of preparation nece. ssary to assure the President has

adequate and informed legal assistance at the present time. As you are no doubt aware, you have subpoenaed the investigator retained by this firm and by the law firm defending the President in the Paula Jones suit, and the focus of your questioning was on criticism directed at your office. This investigator was retained for lawful, legitimate, and well- recognized pu, rposes, and your subpoena is, in our view, a blatant and unwarranted attempt to intrude into and violate the legal privileges enjoyed by every citizen, including the President, in litigation where that citizen is personally being sued or investigated. No more reassuring is your recent interrogation of Mr. Sidney Blumenthal, who works at the White House, to inquire into criticisms of your office in the press. Finally, I have received no response to my letter (a copy of which is attached hereto) sent to the Independent Counsel more than twc weeks- ago, incc;- ing as to contacts his law firm (Kirkland & Ellis) had wiE:?- Ehe lawyers for Ms. Paula Jones and legal assistance it had rendereti tc her. Some news reports raise troubling issues of possible conflict of interest, and I would lijce tc ge: these resolyied just as SOCT= as possLb12.

You dc, of COU’ S2 - , ha- le a copy of the P12sid2z;‘ s

depos Lticn given on January 17, 1998, in the Jones case, and his swcrn testimony there addresses at length the Mcnica Lewlnsky matter. You have also, as I understand, r2questsd multiple copies of the videotape of this deposition. I believe, theraFore, -- a that the grand jury in fact alrtady has access to sworr: testimcny given by the President about this topic. The ques,, +; ons asked the President by Ms. Jones' counsel were, in faci, surprisingly detailed and particularized. AS you may know, there have been news reports suggesting that Ms. Linda Trip? spent most of the Friday before the President's depositicn with lawyers and agents from your office, after the apprehension of Ms. Lewinsky at a meecing wiCh 81s. TriFp. AL . tne 2 Z- AC - (= f bA2Z 23'1 with your personnel, again according to press repcrcs, Ms. Trip?, with the apparent acquiescence of your office, met in Maryland with lawyers for Ms. Jones. There, she reportedly told them of the tapes she had secretly made of her conversaticns with Ms. Lewinsky, shared with them the contents of these secret tapes, and he1 Ded them devise questions ts ask the President a: his decositlon next betiF?-/? ti- lar, day, the transcript of which ycu have. We

ar ie- as: b?/ 7%:~ f-- me, c ..^ Ms. Trlsc was w? ll aware i *- l a z L S.. r; taz: ings werl --.. - iil2gal and a felons G. dor Mar./ land law. We a z- 2 1.. - tile pracess cf lzvls: lgaiin~ all c:? t lqal l.~, llcarixs cf -se asParent fzists. c :2-

2303

WILLIAMS 6 CONNOLLY Robert J. Bittman, Esq. March 4, 1998 Page 4

Again, I would respectfully ask you to read this letter, with its attachment, to the grand jury and to make them part of

the grand jury record, if your letters to me are shared with the grand jury.

I thank you for your courtesy.

2304

DAVID E KENDALL

(202,434- 3L45

L% W 3mc3 wILLmu 6 CONNOLLY

725 lTEZiHSTiC. 3, NW.

WASHING- ON, D. C 20005- 5901

002) 434- 5000

FAX 0021 U- 5029

2305

WILUrLMS 6 CONNOLLY

KOnor. ible Kecneth W. Starr February 17, 1998 Pase 2

2306

WIUrLMs 6 CONNOLLY &xiOEi~~ t Kt, rtl, et2 W. St==

Februa, y 17, 1998 Pase 3

2307

HonorabLe Kemeth W. Starr Februa, z- y 17, 1998 Page 4

Independent Counsel. to investigate matters'pertainins to the genes case. You have in the past investigated the Jones matcer, acccrding to 3& Washinaton Post. The recent expansion of your jurisdiction ex@. citly requires you to investigate events "concerning the civil case Jones v. Clinton.* YOU have, since your appointment ds Independent Counsel, remained an active partner in the Kirkland & E: lis law firm, as was your ri# x. The partnership includes Mr. Porter.

I hope you can therefore perceive why I am requesting accurate and specific informazion (i) concerxing your OWT., Mr. Porter‘ s, and any other Kirkland & Ellis lawver's, emFloyee's or agent's con. tac; s with and assistance to Ms. gaula CorSiz Jcres and/ or her attorneys or ageslrs Or szpccrzizg groqs, a32 (iii coccernirg what was csr. veyek zo tke A- '--= 9 Go- era: an5 thee -- e ._-_ SDerial Division iz Jana-- y, a& sistaxe, w:? e~; yoc scuck~ 1393, a5ouz Fir.-, s; rc?. f3Z~ ziiC~ S ad

a2 eAqar. siar: ~5 er, czm> ass the Jor. es v. C? i? zar. case.

I thaAak you for your cocr: esy.

2308

Offwe of the Independent Counsel

IO01 Pmmyivanio .dvenue, 3. W Suite SO- North Washingron. DC -70004 (202) iI4- 8688 Fm( 202) iI. l- 5802

March 13, 1998 David E. Kendall, Esq. 'Williams & Connolly

725 Twelfth Street, N. W. Washington, D. C. 20005

Re: warn Jefierson Clinta Dear David:

By your letter last Wednesday, March 4, 139S, the President has now declined five invi: ations to testify and tell his story to the grand jury.

As time goes on, now eight weeks into the investigation, your claim that the ?resFdent continues net to have time to prepare his testimony about Ms. Lewinsky is increasingly difficult for us to understand. We mean no disrespect whatever, mindful as we are of the President‘ s constitutional obligations, but as stated in my letter of March 2, 1998, since the Monica Lewinsky matter began the President has found time to play golf, attend basketball games and political fundraisers, and enjoy a ski vacation. On January 17, 1999, the President was deposed for nearly a full day in the Jones v, m lawsuit. Your co- counsel, Bob Bennett, has even moved to

expedite the trial date in that case. In addition, as you remember, despite the President's weighty responsibilities we had no trouble scheduling the President's depositions for other Whitewater- related matters, and we were able to schedule his testimony in the two trials in Little Rock with relative ease. In those trials, of course, he was summoned as a defense witness, noz by the United States.

You may recall that when t. ie grand jury issued a sL8coe2t for Xrs. Clinton's tzszimony i5 January 1336, ybu and WkrLo !iocss Counsel complarned that she, at minimum, sbouid have first been given the 0pportuni: y to appear voluntarily. You 2r. d iu'h: re tiouse Counsel urged alt+ rnatlves in lieu of a gzazd ]ury

2309

David E. Kendall, Esq. March 13, 1998 Page 2

appearance. As to the President and the Lewinsky matter, however, you have declined five invitations- to testify voluntarily. Moreover, you have suggested no alternatives.

Until last week, the President had repeatedly pledged his full cooperation in connection with the Monica Lewinsky investigation. Last Thursday, flarch 5, 1998 -- one day after the President declined our fifth invitation to appear voluntarily before the grand jury -- the President publicly declared he had "given all the answers that matter" relating to Ms. Lewinsky. The President has also invoked executive privilege under circumstances exceedingly difficult to justify under settled principles of our constitutional system. We are, in consequence, constrained to say this: We now question whether the President ever intends to cooperate with this invpstigation, as promised, and testify.

The silggestion in your letter thtr cc:- ' possessicn of the President's deposition in the Jones :I. C--. Lo i Z q' r, case prcvides the grand jury "access" to the President's information about the Lewinsky matters is, wi: h all resoert, d: slngenuous. The President was questioned in his deposition about a single, na -row _

issue involving Ms. Lewinsky. As you know, zhe Special Divisior. -- upon the soecific request our jurisdiction to include of the Attorney General -- defined

"whether Monica Lewinsky or others suborned perjury, obstructed justice, intimidated witnesses, or otherwLse vkolated federal law . . . in dealing with wlrnesses, potential witnesses, attorneys, or others concerning the civil case Jones V. L I r)~.~ Our inquiry is by law much broader than the narrow issue about which the President was questioned in his deposition.

Let me reifarate: we have profound respect for the institution of the Presidency. Yet, as 1 am sore you agr?", the grand jury is entitled to "every man's evidence." &e. e Unitad States v. N: xot-,, 418 U. S. 683 (1974); Y p., i: v4 s- 2 .,_-. -, tes ". aL! r=, 25 Fed. Cas. 20 (No. 14,692) (C. C. Va. 1807). It is urgeri: that we receive the President's testimony in this ma;: cr as soon as

FOSSibll.

2310 David E. Kendall, Esq. March 13, 1998 Page 3

convenience. In particular, a deposition format -- should .the President refuse his right to present his testimony to the grand jury and face his fellow citizens eye to eye -- is an arrangement we stand ready to discuss. We are ready and able to accommodate any issues of Presidential dignity, as well as security, which of course can be readily accomplished at the United States Courthouse.

Nothing, in short, should stand in the way of the truth's coming out. As should be apparent, we continue to seek -- on behalf of the grand jury -- the President's truthful testimony before that body, which stands ready to sustain any inconvenience in order to respect the President's schedule, while at the same time carrying out its solemn function under our system of law.

Sincerely, $?& l. e Robert J. Bittman Deputy Independent Counsel

2311

DAVID E. KENDALL (2021 434 -5165

LAW OFFICES wILLLAM 6 CON- NOLY

725 TWELFI- H STREET, N. W. 'YASHINCTON, D. C. 20005- 5901

(202) 434- 5000 FAX (202) 434- 5029

March 18, 1998 CONFIDENTIAL RULE 6( e). F. R. CR1M. P.. GRAND JWRY SUBMISSION

Robert J'. Bittman, Esq. Deputy Independent Counsel Office of the Independent Counsel 1001 Pennsylvania Avenue, N. W. Suite 490- North Washington, D. C. 20004

Bv Hand Dear Bob:

Thank you for your letter dated March 13, 1998. I will be equally frank in response.

For over four years now, the President has cooperated in every possible way with the investigation of the Independent Counsel. He has voluntarily given testimony under oath on three separate occasions to the Independent Counsel and twice to defendants (on each occasion, he was cross- examined by the Independent Counsel), he has submitted written interrogatory answers, he has produced more than 90,000 pages of documents, and he has provided information informally in a variety of ways.

I, too, have dealt in good faith'with your investigation for more than four years. Until the recent expansion of jurisdiction to cover the Lewinsky matter, I have not had occasion to raise,

nor have I raised, the kind of concerns I have adverted to in recent correspondence. I will be more specific: the actions of the Office of Independent Counsel in the past several weeks (as

CiiSLiZ- iCL from the actions of the grand jury) lead me to believe that your investigation may not, in fact, be an even- handed search for justice b%~: t rather may be, for whatever rsascn, a campaiq-. to embarrass and harass the President. I believe he is now plainly the object of your investigation.

2312

WILLIAMS 8 CONNOLLY Robert J. Bittman, Esq. March 18, 1998 Page 2

You state that it is "disingenuous" to assert that the President's deposition transcript (including the videotape of the deposition, which you likely will soon have access to) in Jones v. Clinton allows you to obtain the President's information on the Lewinsky matter. We continue to believe that the forty deposition pages of testimony (pp. 48- 86, 202- 204) on this topic set forth the essentials of this matter, although there are doubtless more questions you might be able to devise.

Of more serious concern to us is evidence that your office contrived to obtain the President's deposition testimony through improper and illegal means. Based upon what we have been able to learn thus far (see, e. s the

1998, headlined page one Washington Post article on February 14, "Linda Tripp Briefed Jones Team

on Tapes"), your office, your agent Linda Trip?, and the Paula Jones lawyers apparently colluded to u'se the fruits of Tripp's feionious audiotaping (see Md. Code Ann. § IO- 402 (1997)) of Lewinsky against the President at his deposition on Saturday, Janus- ry 17, 1998. Curiously, Trip? appears to have been given immunity by your office immediately after she contacted you. She then secretly recorded at least one conversation with Tewinsky, an act that (unlike her previous audiotapings) does nm appear to have been in violaticn of wiretap law. According to the Washington Post's February 14 article, Tripp arranged to have Lewinsky apprehended by you r agents about noon on Friday, January 16, then put off a meeting with the Jones lawyers until (we believe) it became clea r that Ms. Lewinsky would not herself agree to wear a recording device tr, gather evidence agains: others. At some point late in the afternoon, Tripp "sent word" to the Jones lawyers that she would talk to them, and she was transported to her home in Maryland (perhaps by one of your agents) where she proceeded to share both the existence of the illegal tapes; ' and their contents with the Jones lawyers, who were able to use this information the next day to question the President. k'

y Under the Maryland electronic surveillance statute which makes one- party telephone call taping a felony, it is a violation of the sta; uts to disclose that an illegal tape has bean made, since the t2r7. "Contents" (ch? disclosure of which are forbidden] is defined co include "any informa: ion ccr. cerr. ing t:? s iSisncity of I? 2 parzi5- s to tk-. s csmmnzicatioC or the existence, substance, purport, or meaIling of that

cximc~ i~ a: icn ” Fd. CCC;* .GZr.. 5 13- G21( 7] [1397j (amshdSL. S

added).

2313

WILLIAMS 6 CONNOLLY Robert J. Bittman, Esq. March 18, 1998 Page 3

The Ethics in Government Act provides in Sec. 593( c) (I. 1 a carefully defined procedure for expanding the jurisdiction of an independent counsel. If a new matter is not "related" to an existing subject of investigation (and the Lewinsky matter plainly was not), the statute does not allow a free- roving investigation beyond the limits of an independent counsel's present jurisdiction. For example, there would be no statutory justification to "wire" a cooperating witness to investigate further a matter not within the jurisdiction of the independent counsel. Section 593( c) (2) (A) of the Act provides that "[ ilf the independent counsel discovers or receives information about possible violations of criminal law by [covered persons] which are not covered by the prosecutorial jurisdiction of the independent counsel, the independent counsel may submit such information to the Attorney General," and the Attorney General "shall then conduct a preliminary invesFigation of the information in accordance with the provisions of section 592" (emphasis added) _ While the Attorney General "shall give great weight to any recommendations of the independent counsel" (ibid.), the determination whether to recommend to the Special Division an expansion of jurisdiction is the Attorney General's alone.

Under the circumstances here, there was no need for a hasty and informal presentation to the Attorney General-- unless the OIC was hoping to use Tripp (and perhaps Lewinsky) to somehow obtain incriminating evidence against the President whose deposition in the civil case was fast approaching. We believe that the Attorney General was not properly informed about the circumstances which ostensibly justified the expansion of jurisdiction sought, and that your recent investigation has in fact been a contrivance to justify post facto the grant of jurisdiction that your office obtained from the Special Division.

It appears to us that you did not seek, the Attorney General did not approve, and the Special Division did not authorize thl;

his relationship with and gifts to lyiss Lewinsky, according to a person informed about the President's testimony." (The Washington Times, Feb. 15, 1998.) At the deoosition, when the President remarked after a series of highiy &CjCecpLy quescrons concernizig Ms. Lcwinsk;~, "I do; 1' t ev22

know what ycu're talking abou:, I don't think," KS. Jones' iawfer, Jam? s Fisher, rsplisd, "Sir, I think this w: lL corns t3 light shortly, and you'll understand." Deposition, transcript, at 85.

2314

WILLIAMS 6 CONNOLLY Robert J. Bittman, Esq. March 18, 1998 Page 4

extension of your jurisdiction based on any specific and credible evidence of criminal activity by a covered person. As you surely know, the expansion of jurisdiction approved by the Special Division, on the basis of an oral application, was to investigate "whether Monica Lewinsky or others suborned perjury, obstructed justice, intimidated witnesses, or otherwise violated federal law . . . in dealing with witnesses, potential witnesses, attorneys, or others concerning the civil case of Jones v. Clinton." No "covered person" was involved in this matter unless and until the President gave testimony which might be regarded by your office as suspect. The Attorney General's written application to the Special Division, submitted after the Court was informed orally of the request, states that the Attorney General had determined that it would be a conflict of interest, under 28 U. S. C. § 591( c) (1) for the Department of Justice to investigate. However, it was still incumbent upon the Attorney General to conduct an appropriate "prelimina, ry investigation" to determine that there was specific evidence from a credible source to warrant further investigation. We do not believe the Attorney General was provided adequate information about or her general Tripp's illegal audiotaping

credibility or about the efforts by your ofrice to acquire evidence which could be used to support the expansion of jurisdiction. We do not believe that such a bootstrap acquisition of jurisdiction as apparently occurred here was ever contemplated by the Ethics in Government ACE.

We have another serious concern about the expansion of jurisdiction in this matter, and I have adverted to this in my letter to you dated March 4, 1998. As you know, I attached a copy of a letter to the Independent Counsel which I had hand- delivered on February 17, 1998, and which sought certain basic information relating to the Independent Counsel's relationship to the Jones v. Clinton civil case. Like your office, I am interested in "'the truth's coming out." Ir is over a month later, however, and I still have received no response of any kind from the Independent Counsel. The Special Division's Order dated January 16, 1998, specifically recites that it approves "an expansion of prosecutorial jurisdiction in lieu of the appointment of another Independent Counsel." The point of my February 17 letter to the Independent Counsel was precisely whether he (as opposed to some other qualified person) should have been appointed by the Special Division under the facts of r- lis --- z .- are?- - The ELhi; cs in Gcvtrr;~. er.~ '-- ex? licirly provides Chat .- Lb -

"[ d] tiring the period ir. which an indenendent counsel is serving

UTlti? Z L? iis chapter (ij such in&-? zdzn: counsel, and (li) any c nerscn associated with a firm with which stich independent counsel A is associated, may not represent in ant ( mazrer any person

in./ GIve”, in any investigaticc or przs? c~ ticn under this chapter."

WILLIAMS 6 CONNOLLY Robert J. Bittman, Esq. March 18, 1998 Page 5

2315

28 U. S. C. § 594( j) (1) (A) -__ As my February. .17 letter to the Independent Counsel made clear, the Chicago Tribune reported six days earlier that one of the Independent Counsel's partners in Kirkland h Ellis, Mr. Richard Porter, may have provided legal advice and services to Paula Jones in her suit against the President. I have written the Independent Counsel seeking information concerning this and other news reports concerning his own relations with Ms. Jones' lawyers. I specifically requested information II(~) concerning [the Independent Counsel's] own, Mr. Porter's, and any other Kirkland & Ellis lawyer's, employee's or agent's contacts with and assistance to Ms. Paula Corbin Jones and/ or her attorneys or agents or supporting groups, and (ii) concerning what was conveyed to the Attorney General and the Special Division in January, 1998, about any such contacts and assistance, when [the Independent Counsel] sought an expansion of . . . jurisdiction to encompass the Jones v. Clinton case." I have heard nothing in response.

I will not repeat here my description of the many grave duties of state which are uniquely the President/ s. As I noted in my March 4 letter, fl [wlhile it is true that not every moment of the day is absorbed by the duties of office, the President is extraordinarily busy on a range of important public issues, some of which are visible and some of which are not." The President leaves on a long- scheduled state visi: to Africa this weekend, and he will be gone until April 3. He then is in South America on another state visit from April 15 to 2C. Such trips require not only travel time but a great deal of preparation time, study, and analysis in advance and after the trip.

I believe that a meeting to discuss my concerns, as well as yours, would be fruitful, and I am available at your convenience for that purpose.

Again, I would respectfully ask you to read this letter to the grand jury and to make it part of the grand jury record, if your letter to me is shared with the grand jury.

I thank you for your courtesy.

2316

Offke of the Independent Counsei

1001 Pennsylvania Averne, N W.

Suite 490- Akrth Warhingtoq DC 20004

po2) 5l4- 8638

Fm (202) 514- 8802

April 3, 1998 EAND DELIVERED David E. Kendall, Esq. Williams h Connolly 725 Twelfth Street, N. W. Washington, D. C. 20005

Re: William Jefferson Clinfon Dear David:

I write in response to your letter of March 18, 1998, in which you declined our sixth invitation for the President‘ s testimony, and- in response to our meeting of March 20, 1998, during which you declined to answer my question whether the President will ever voluntarily testify about the matters involving Monica Lewinsky.

As you know, upon receipt of your letter I immediately called you to take you up on your offer to meet and discuss our mutual concerns regarding our six invitations to the President. Notwithstanding the numerous misstatements in your letter -- which are addressed herein -- 1 was hopeful that in light of the President's public pledges of cooperation we could finally arrange terms under which the President would voluntarily testify about the matters involving Ms. Lewinsky. My hopes were dashed at our meeting when you simply refused to discuss any of the l( issues." Not only did you merely repeat some of the inflammatory allegations in your letter, you avoided even ar'dressina -- meering with: much less answering -- the quescicn I began our

Will the President ever voluntarily testify about the matrers involving Monica Lewinsky? You refused several times to ar. swer this ques? ion. Indeed, when I asked if we were to adtizrss ~3. e "cs~ c~ KT,~~ out: -L2? 1S it? yol;: lsil: 5r tc ycuz sa: isfac: ion would the President then agree to testify, you s? ill refused to answer. This exercise, in the context of the backpedaling and misdirection of your ieLters and the Presidenz's c~ klic stazeme2ts, makes clear tha: :ne President has no

2317

David E. Kendall, Esq. April 3, 1998 Page two

intention -- and never has had any intention -- of cooperating with this grand jury or this investigation. We, of course, regret the President's appaxent decision.

Now I will turn to the variety of irrelevant charges raised in your letter against this Office, the Independent Ccmnsel, and Judge Starr's private law firm. Because our addressing these matters is evidently not dispositive for you, I will address them only briefly.

First, you suggest that the President's deposition in the Jones case amply substitutes for grand jury questioning. You are incorrect. As you are well aware, the jurisdiction of this Office and the scope of discovery in the Jones case are far from coextensive. While the deposition bears on matters within our jurisdiction, the grand jury investigation has unearthed many significant issues not addressed in the deposition.

Second, you accuse this Office of having "conzrived to obtain the President's deposition testimony through improper and illegal means." This, too, is flatly incorrect. All evidence gathered in this investigation has been obtained lawfully and properly.

Third, you charge that this Office, Linda Tripp, and Richard Porter of Kirkland & Ellis "colluded" with attorneys for Paula Jones. As authority, you cite a number of the noCoriously inaccurate media accounts of this investigation, many of which have been based upon statements by "unnamed presidential advisers." Let me set the record straight: This Office has not colluded with Ms. Jones's attorneys -- not directly, not indirectly, and net through Ms. Tripp, Mr. Porter, or any other person. With nothing more than a sheaf of newspaper articles in hand, it is irresponsible of you to charge otherwise.

Fourth, you contend that this Office has undertaken investiaative The 5 steps without proper authority. We disag: es. explnsion of our jurisdiction by the Special Division was preceded by a presentation of information to the Attorney General., a preliminary in7esCigz: ion of such inforzati2r. by her, and a subsequent raccmmendation to the SpeciaL Division. We, ,._ l * I --_ ir. a--...- I;:,:, +, L+-; r 152 ;.~~>~~~ j~ Gezerl knci; s anti fsLI~;; s ~- 2

law. She foilowed the Law in t: his cass. As yocr cmpla~ nt is a legal -azgcmenL about cur authoricy to inves: igaCe, we suggest yoc

2318

David E. Kendall, Esq. April 3, 1998 Page three

Fifth, you assert that the President has "cooperated in every possible way" with this investigation. You know, of course, that this is not true. You and the President have failed to produce financial records that have been under subpoena for several years. The Rose Law Firm billing records, for example, were "re- discovered" at the White House in January 1996 and had been under subpoena for many months. Jane Sherburne, then of the White House counsel's office, testified before the Senate that after the records’ "re- discovery" she suggested to you that the forensic integrity of the records be preserved. Senate Hearing, Z/ 8/ 96, at 69- 71. Ms. Sherburne further testified that her suggestion was dismissed, Id, You testified that you '" did not regard this as a forensic matter," id. at 72, and, of course, the forensic value of the records was in fact compromised after handling by your office. In addition, as you know, I wrote you on March 6, 1998 and March 25, 1998, requesting that the President fully comply with subpoena number VO02 and its instructions so that the grand jury can dntermlne whether the President ever had any documents or things in response to the subpoena that have not been produced. You thus far have responded with, only (3 vague statement that the President "might ha; ze given the President a few additional items, such as ties and a pair of sunglasses, but we have not been able to locate these items. The President frequently does not see and is not aware of nxmezous items which are sent to him by friends and supparters." This response is unsatisfactory and not in compliance with the subpoena. The grand jury needs the additional information demanded by the subpoena's instructions.

Finally, you reiterate that the President is a busy man. We do not disagree, and indeed aze well aware that the President has weighty responsibilities besides his obligation to assist a federal grand jury investigating possible criminal conduct. Nonetheless, we believe that he has found ar, d can continue to find the time to testify in judicial fora -- p+ irziccl arfy Given t? a: we will werk wizh you: to time his appearance so as to reduce dis: uptior! to his schedule.

2319

David E. Kendall, Esq. April 3, 1998 Page four

Having tried and tried, I will now try once again. Please give me a straightforward yes or no answer to the following question: Will the President ever agree to testify voluntarily about the matters involving Ms. Lewinsky? If the President chooses again not to give his testimony, so that the grand jury may at least receive some of his evidence, please provide this Office with any and all exculpatory evidence you may have.

Sincerely, Robert J. Eittman Deputy Independent Counsel

2320

DAVID E. KENDALL (202) 434- 5145

725 't-% 'ELFM STREET, N. W. WASHINGTON, D. C. 20005- 5901

(202) 434~ 50# FAX (20214343029

April 17, 1998 CONFIDENTIAL RULE 6( e), F. R. CR1M. P. s GRAND JtTRy SUBMISSION

Robert J. Bittman, Esq. Deputy Independent Counsel Office of the Independent Counsel 1001 Pennsylvania Avenue, N. W. Suite 490- North Washington, D. C. 20004

Dear Bcb: Thank you for your letter of April 3, 1998. I will try once again to make clear our position with regard to the President's providing testimony on the Lewinsky matter, beyond the transcript and videotape of his deposition in Jones v. Clinton, which your Office now has and is free to submit to the grand jury. I have attempted to do this in my previous correspondence and in our meeting at the federal courthouse on March 20, 1998.

in my several letters and in our meeting, our position could not have been more clearly stated: we have serious objections to the origin and conduct of your Lewinsky investigation, and until those are satisfactorily addressed, we cannot, as a matter of professional duty to our client, allow the President to give further testimony at the present time. The issue remains open, however, and depends on your Office. We remain entirely respectful of the grand jury. Indeed, from recent press accounts, it appears that the grand jurors themselves are performing their civic duty with admirable commitment and at some sacrifice ta their personal lives. Quite frankly, I believe if your Office were to provide the information I have sought over the past several months, this would lighten the burden on us, on you I and on the grand jurors.

2321 WILLIAMS 6 CONNOLLY

Robert J. Bittman, Esq. April 17, 1998 Page 2

Since your letter states it will address my concerns only '. "briefly", 1 will not restate here the issues I have raised at some length in my previous correspondence. I would note only that, once again, your letter stonewalls my request for information concerning contacts between members of the Independent Counsel's law firm (Kirkland & Ellis) and the Paula Jones lawyers as of the January 16, 1998, expansion of your Office's jurisdiction to encompass the Lewinsky matter in the Paula Jones civil Suit. My need for this information is obvious: if in fact personnel at Kirkland & Ellis have provided legal assistance in some way to the Jones side of the civil suit, Judge Starr would a have been qualified under the Ethics in Government Act to serve as independent counsel on the Lewinsky matter-- some other individual, with no connection to the Jones litigation, would have had to have been selected. The information I seek is obviously in your custody and control: Judge Starr need only ask his law partners, if he is not in fact privy to it himself. I first wrote him on February 17, 1998, requesting this information, and I still have not had an answer to my letter. You will recall that I appended a copy of that letter to my March 4, 1998, letter to you-- I will not do so again.

This matter is highly important under the statute, because when Congress enacted the independent counsel legislation, it permitted such counsel to remain in their private law firms and to take on the appointment as a part- time job. I do not fault nor have I criticized the Independent Counsel for remaining at his law firm (where, according to news reports, he has made $1 million a year while serving as independent counsel, s, m, Time, Feb. 2, 1998) 1, but it is, obviously, extremely important that the conflict rules that permit such continued employment under the Act be followed. The statute provides that no person associated with the independent counsel's law firm may "represent in any matter any person involved in any investigation or

prosecution under this chapter." 29 U. S. C. ,§ 594( j)( l) (A) (ii). Thus, if someone at Kirkland & Ellis had "in any matter" represented Ms. Jones, Judge Starr could not properly have been appointed to investigate the Lewinsky matter.

It is true, as your recent letter asserts, that I have based my inquiry on media accounts. I do net have any reason to be1 : a- Js A^_ tlhat ! for e: cazpl?) the FeBruar: l 11, 1993, accouy, t is

"notoriously inaccurate," as you suggest, since it appears in the C. ilicago Trlbuns, a reccta512 r. ews? aper. The Tz- i'0c. e'~ report was in fact quite specific:

2322 WILLIAMS 6 CONNOLLY

Robert J. Bittman, Esq. April 17, 1998 Page 3

"The Chicago- based law firm whose partners include Whitewater independent Counsel Kenneth Starr has begun an inquiry into whether a partner provided unapproved assistance to lawyers representing Paula Jones in her sex harassment case against President Clinton . . . .

[T] he law firm's internal inquiry is focusing on Richard Porter, a partner in the Chicago office and a former senior aide to President George Bush and Vice President Dan Quayle _ . _ .

-John Corkery, associate dean at Chicago's John Marshall Law School, said the ethical issues raised are complicated ones. But in general, he said, 'If an attorney at the Kirkland firm is doing something that amounts to legal work for Jones, that creates a problem for Starr as the independent counsel because Starr's partner is pursuing a related matter in private practice that Starr has the obligation to investigate as part of his official duties. '

'The acts of Starr‘ s partner in the practice of law are Starr's acts, by virtue of their partnership, ' Corkery said."

YOU also assert that many statements in the accounts I cited in my February 17 letter are sourced to (in your words) l'unnamed presidential advisers." With all respect, I do not see any such sources in these articles, although the February 11, 1998, Chicago Tribune article is in part based upon an unnamed "Kirkland & Ellis source". \

I am also surprised at your cavalier dismissal of press reports as a basis for further inquiry. Your own Office has been quite willing even to take legal action on the basis of press accounts, when it has suited your purposes. For example, you successfully moved to disqualify Judge Henry Woods in the Court

of Appeals for the Eighth Circuit "with nothing more than a sheaf of newspaper articles in hand" (to borrow your phrase), although you had chosen not to make such a motion to the Judge himself. As the Court of Appeals noted, "[ tlhe Independent Counsel relies primarily on newspaper articles to support his request." United Sta tes v. Tucker, 78 F. 3d 13i3, 1322- 23 (8th Cir. 1995). By their very nature, questicns involving pcssible conflicts of interest oftcr, arise beta- se of media rebcrts. In a proceeding in Arkansas last year involving the quesiion whether the Independent Counsel suffered a conflict of interest because a job he had accepted ir: the future at Pepperdine University was

2323 WILLIAMS 6 CONNOLLY

Robert J. Bittman, Esq. April 17, 1998 Page 4

partially funded by a virulent opponent of President Clinton, Judge Eisele, a Republican United States District Court judge, commented: ~[ H] aving reviewed the media accounts regarding the Pepperdine issue, I find that it is incumbent upon the Court to make some kind of inquiry." In re Starr, 986 F. Supp. 1144, 1153 (E. D. Ark. 1997). Judge Eisele also observed that -[ iIt is even possible that Mr. Starr, as Independent Counsel, should receive more exacting scrutiny regarding his professional responsibilities than other prosecutors," since the Special Division indicated (when it appointed him to replace Mr. Robert Fiske) that "'the Act contemplates an apparent as well as an actual independence on the part of the Counsel. '" 986 F. Supp. at 1155.

Your letter asserts that the expansion of your jurisdiction to include the Lewinsky matter was approved by the Attorney General and you suggest that this means that the Attorney General has in fact ratified your application. However, one of the very questions I have been asking for over two months-- without receiving an answer of any kind-- is precisely what the Attorney General was told when your Office suddenly requested an expansion of its jurisdiction in January. I have no idea whether the Attorney General was in fact informed of any contacts between Kirkland & Ellis personnel and the Paula Jones camp. The Attorney General is obviously not clairvoyant: if she were not informed of any such contacts, she could hardly be expected to know about them and to have made a decision as to whether, under the circumstances, Judge Starr was in fact the appropriate Independent Counsel to conduct the Lewinsky investigation. It is quite significant, I believe, that the Attorney General's application to the Special Division recites that "Indeoendent Counsel Starr has reuuested that this matter be referred to him" (emphasis added). Thus, your office affirmatively and purposefully sought to extend its jurisdiction over the Lewinsky matter. This expansion request did not originate with the Attorney General.

Instead of providing responsive information, you have advised that we should "raise [this issue] in a judicial forum." We will accordingly assume that we will receive no further resccnse to my F& ruarTy 17 letter and will proceed accordingly.

- xlll r. ct rapear her? ml/ pres- lously expressed concerns * ahc, Lt your Offic2's investigative techniques in the L2winsky rnzLLZ? Y. zeserit press reccrts ir. 2icate :hat 1;:~ plan ;S halie MS.

Trim testifv befor? t: le grand jury. -- Should you have Ns. Trlpp tes: ify, I would resuectfully request that you brief the grand jurv concerninc the illegality of Ms. Tripp's one- party taping of

2324 WILLIAMS 6 COtjNOLLY

Robert J. Bittman, Esq. April 17, 1998 Page 5

MS. Lewinsky's telephone.. conversations in. Maryland, the reasons your office wired Ms. Tripp to tape record Ms. Lewinsky's conversations, your knowledge of how the contents of this tape "leaked" to the news media, your knowledge of the reasons Ms.

Tripp sought out your office rather than the United States Attorney's Office, the timing and details of your federal law immunity agreement with Ms. Tripp, and the restrictions (if any) you placed upon Ms. Tripp's transmittal of illegally acquired taping information (including the existence of illegally made tapes) to the Paula Jones lawyers in the week before the President's deposition.

I have responded to your comments concerning subpoena VO02 in a letter dated April 13, 1998, and will not do so again here. I have also set forth fully in a letter to the Independent Counsel dated April 10, 1998, my conc& m. s about having your Office investigate recent allegations concerning David Hale. In its April 9 letter to Judge Starr, the Department of Justice noted that "the United States Attorney's Office for the Western District of Arkansas was recently provided with information suggesting that David Hale, who we understand is a witness in various matters under your jurisdiction, may have received cash and oth. er gratuities from individuals seeking to discredit the President during a period when Hale was actively cooperating with your investigation." The Department's letter also noted "suggestions that your office would have a conflict of interest, or the appearance of a conflict, in looking into this matter, because of the importance of Hale to your investigation and because the payments allegedly came from funds provided by Richard Scaife [the virulent opponent of President Clinton whom I referred to above]." The Independent Counsel's withdrawal from his Pepperdine commitments does not begin to solve the many probiems that have been noted. For the reasons set forth in my April 10 letter, which involve both fairness and the perception of fairness, your Office should not have anv involvement whatsoever in the investigation of this matter.

For over four years, the President has cooperated fully with the investigation of the Independent Counsel, which has now gone

072 longer than a Presidential term. He has voluntarily given tes: i many under oath on three different occasions to the Independent Counsel and twice to de fendants (on each occasion, he was cr ass- examine? by the Indesszdect Counsel), hs has submitted wrz: te:. inttrrscatory a?. sw2rs, h2 has arcductd mar2 ::? an 9C, OGO

2325 WILLIAMS &CONNOLLY

Robert J. Bittman, Esq. April 17, 1998 Page 6

pages of documents& ', and. he has provided information informally in a variety of ways. This amounts to unprecedented cooperationz' with an investigation of unprecedented duration,

11 You assert that we *have failed to produce financial records that have been under subpoena for several years." This is simply false. You have not specified, nor could you, any such record in our possession that we have not produced.

31 Because your letter contains an unwarranted and false & hominem charge concerning the Rose Law Firm billing records, I respond here simply for the sake of the record, and I do not ask you to read this footnote to the grand jury, unless you choose to do so. I do not complain that you appear to have imperfectly complied with the Independent Counsel's publicly expressed philosophy (viz.," 1 have a job to do and you will never hear me besmirching anyone's reputation. Not once, never in all of this four years of activity, have I ever said anything to besmirch anyone's reputation. . . And you will never And when I say me, find us doinc that.

I’ m not meaning to personalize that. I mean mv colleaaues with whom I'm verv orivileaed to serve." CNN, Special Event Transcript, April 2, 1998) (emphasis supplied). My point is instead that your smear is simply false.

You write that "the forensic value of the [Rose Law Firm billing] recbrds was in fact compromised after handling by [my] office." You reference the highly partisan Senate inquiry chaired by Senator D'Amato, but you distort the

meaning of the very testimony you quote. If you had reviewed the D'Amato testimony more carefully, you would have observed that the billing records were produced in accordance with procedures jointly agreed upon by me, Ms. Sherburne, and Mr. Schuelke. Moreover, your Office was in fact able to do fingerprint analysis of the billing records,

because it made this evidence available to Senator D'Amato's Committee under cover of an undated letter from the FBI

which Senator D'Amato released on June 4, 1996. The fact that your Office had identified Mrs. Clinton's fingerprints on the billing records (not surprisingly, since she was the billinc oartner on the account) was somehow leaked to the A . news media (see, e. c., Newsweek, May 6, 1996; Washington

Times, April 30, 1996). Ire retrsscect, this appears to be a previsw cf ~5s highly prejcdicial i; aks we have ex? eritnced in the las: tic22 months. In any event, two years ago, I

(continued...)

2326 WILLIAM5 8 CONNOLLY

Robert J. Bittman, Esq. April 17, 1998 Page 7

intrusiveness, and indefiniteness. That .you now request we submit "exculpatory" evidence is perfectly consonant with the occasionally Alice- in- Wonderland nature of this whole enterprise. I am not aware of anything the President needs to "exculpate."

I would respectfully ask you to read this letter to the grand jury and to make it part of the grand jury record, if your recent letter to me is shared with the grand jury.

I thank you for your courtesy. Sin rely, ,

Y - DvidE. endall

i'(... continued) wrote strenuous letters of protest, dated April 29 ad 30, 1996, to the Independent Counsel about these leaks, receiving in reply a soothing response dated May 3, 1996 (" Your concerns are noted, and they are shared by this Office") and no further action.

2327

Tab 2

2329

Offke of the Independent Counsel

1001 Pennsylvania Avenue. N. W. Suife 490~ North Washington. DC 20004

(202) 514- 8688 Fax (202) SIJ- 8802

July 17, 1998

BAND DELIVERED

David E. Kendall, Esq. Williams & Connolly 725 Twelfth Street, N- W. Washington, D. C. 20005

Re: William Jefferson Clinton Dear David:

AS you know, beginning January 28, 1998, we, on behalf of the grand jury, have invited the President six times to testify voluntarily about the matters involving Monica Lewinsky. Despite his previous cooperation with other aspects of our investigations and his public pledges to cooperate fully with this investigation and provide "more rather than less, sooner rather than later," the President has unfortunately chosen to decline each and every invitation to give his information to the grand jury. The grand jury simply can wait no longer for the President's voluntary cooperation.

Pursuant to 5 g- 11.150 of the United States Attorneys' Manual and with all the requisite approvals thereunder, enclosed please find a subpoena for President Clinton to appear and give testimony before the grand jury on Tuesday, July 28, 1998, at 9: 15 a. m. If the President agrees to comply with the subpoena and testify, we and the grand jury -- as we have previously stated -- will accommodate his schedule if he cannot appear on the 28th.

We believe you are aware of the status of your client. We would be pleased to state explicitly the status of the President if you desire.

Deputy Independent Counsel Enclosure

2330 FOR THE DISTRICI- OF COLUMBIA

TO: William Jefferson Clinton

SUBPOENA TO TESTIFY BEFORE GRAND JURY

SUBPOENA FOR: liIl PERSON 0 DOCUMENTIS) OR OBJECXSI

YOU ARE HEREBY COMMANOED to appear and testify before the Grand Jury of the United States Di& ict 0nat at the place, date, and time specified below-

PUCE COURTROOLL

United States District Court for the District of Columbia Grand Jury, Third Floor Third & Constitution Avenue, N. W. DATE *ND TlME Washington, D. C. July 28, 1998/ 9: 15 a. m.

YOU ARE ALSO COMMANDED to bring With you the following document( s) or object( s): ’

0 Please see additmnal rntormation on reverse. effect until you are granted leave to depart by the court or by an officer acting 0l- l

2331 Advice of Ri. w

l The grand jury is conducting an investigation of possible violations of Federal criminal laws involving: perjury, subornation of perjury, obstruction of justice, witness tampering, and other Federal criminal laws.

0 Your conduct is being investigated for possible violations of Federal criminal law.

l YOU may refuse to answer any question if a truthful answer to the question would tend to incriminate you.

l Anything that you do say may be used against you by the grand jury or in a subsequent legal proceeding.

l If you have retained counsel, the grand jury will permit you a reasonable opportunity to step outside the grand jury room to consult with counsel if you so desire.

2332

2334

2335

Offke of the Independent Counsel

1001 Penmyhmia Avenue. IV. IV.

Suite 490-. Vorth Warhington. LX 20004

(202) SlC8688

Fax (202) S14- 8802

July 23, 1998

HAND DELIVERED

David E. Kendall, Esq. Williams & Connolly 725 Twelfth Street, N. W. Washington, D. C. 20005

Re: William Jefferson Clinton Dear David:

I write in regards to your request yesterday for additional time to respond to the grand jury's subpoena to President Clinton. Although I conveyed to you yesterday that we had decided not to give any additional time, you asked me to let you know by the close of business Friday, July 24, 1998, if our views changed. We are responding today to give you as advance notice of our decision as possible.

We have carefully reviewed your request and balanced it against the grand jury's desire -- and responsibility -- to complete this investigation as thoroughly and expeditiously as possible. We offer to withdraw the current subpoena to the President and issue a new subpoena with an appearance date of Friday, July 31, 1998, at 9: 15 a. m. if you agree that you will not request any additional time or another continuance, either from this Office or the Court. As before, if the President agrees to comply with the subpoena and testify, we and the grand jury will accommodate his schedule if he cannot appear on the 31st. We believe this extension o f time is entirely reasonable given that the President has been on notice since January that the grand jury wished his testimony and given that all the President must necessarily decide by July 31 is whether he will comply with the subpoena and testify. Kindly advise me by 4: 00 p. m. tomorrow whether the President wishes to accept our proposal; otherwise, the current subpoena will remain in effect.

Robert J. Bittman Deputy Independent Counsel

2336

2338

2339

DAVID E. KENDALL (202) 434- 5145

LAWOFFICES WILLlAus 8 CON- NOJLY

725 TWELFTH STREET, N. W. WASHINCTON, D. C. 20005- 5901

(202) 434- 5000 FAXQ02) 434- 5029

July 24, 1998 CONFIDENTIAL Robert J. Bittman, Esq. Deputy Independent Counsel Office of the Independent Counsel 1001 Pennsylvania Avenue, N. W. Suite 490- North Washington, D. C. 20004

Bv Hand - Dear Bob:

I write in response to your letter of yesterday, which. 1 believe to be now moot.

The President is willing to provide testimony for the grand jury, although there are a number of questions relating to the precise terms and timing which must be worked out. If you are willing to work within the framework of the last three times the President provided such testimony and if you are sincere in your statement that you will work to accommodate his schedule, we should quickly be able to finalize the arrangements.

I will get to you by 4: 00 p. m. Tuesday, but sooner if possible, a more detailed letter, which will include a date for testimony which will accommodate the President's other existing obligations.

I request that you withdraw the pending subpoena, since the issue of the subpoena itself is quite important to us. The precedential effect of such a subpoena is not an issue I have addressed in previous correspondence with you (which ended with my April 17 letter), but I will do so in my next letter.

2340

2341

Tab 5

2342

2343

Offke of the Independent Counsel

IO01 Pennsylvania Avenue. N. W. Suite 490~ North Washington, DC 20004 (202) 51 J- 8688 Fax (202) 514- 8802

July 24, 1998

HAND DELIVERED

David E. Kendall, Esq. Williams & Connolly 725 Twelfth Street, N. W. Washington, D. C. 20005

Re: William Jefferson Clinton Dear David:

We are gratified by your response to my letter of yesterday, and we are pleased by the President's decision to provide testimony for the grand jury.

You indicate in your letter that the President "is willing to provide testimony for the grand jury" and you suggest that such testimony take place in a forum outside the grand jury, on an uncertain future date. We are happy to discuss arrangements for the President's testimony that will be consistent with concerns of security and dignity of the Office of the President. We remain interested, however, in obtaining a prompt commitment to a date certain for that testimony. As you know, we have invited the President on six occasions to testify before the grand jury, and its work continues apace. As a result, we are currently not inclined to withdraw the subpoena. Nevertheless, we would be happy to consult with you at your earliest convenience before next Tuesday morning to work out an acceptable schedule for the President's testimony.

Sincerely, Robert J. Bittman Deputy Independent Counsel

2344

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Tab 6

2346

2347

LAWOFFICES

WILLIAMS 6 CON- NOLLY

DAVID E. KENDALL (202) 434- 5145

725 TWELFTH STREET, N. W. WASHINGTON, D. C. 20005- 5901 EDVARD *LNNETT WlLLlAMS <1920- 19- 3) PAUL R. CONNOLLY ulx?*- 197e~

(202) 434- 5000 FAX (202) 434- 5029

July 27, 1998 Bv Hand Robert J. Bittman, Esq. Deputy Independent Counsel Office of the Independent Counsel 1001 Pennsylvania Avenue, N. W. Suite 490- North Washington, D. C. 20004

CONFIDENTIAL Dear Bob:

This will acknowledge your letter dated July 17, 1998, enclosing a subpoena for the President to appear before the. grand jury on July 28 and will follow up on my letter to you dated July 24, 1998.

As you are well aware, this extraordinary subpoena poses grave and literally unprecedented constitutional questions. While we are obviously cognizant of the holdings in United States

V. Nixon, 418 U. S. 683 (1974) and Clinton v. Jones, U. S. -, 117 s. ct. 1636 (1997), no case has ever held that a sitting President may be compelled by subpoena to provide testimony. for a grand jury, much less to testify before a grand jury. In the past, Presidents have voluntarily provided information to prosecutors for legal proceedings in a variety of ways. President Clinton has twice given testimony at the request of defendants in criminal proceedings, after he had voluntarily given testimony to the Office of Independent Counsel on similar subjects, in circumstances where the defendants plainly had certain Sixth Amendment rights "to have compulsory process for obtaining witnesses in [the defendant's] favor." But neither this nor any other President has been compelled to give testimony to a grand jury by subpoena.

One of the most troubling aspects of this subpoena is its plain conflict with the impeachment provisions of the Constitution, since it is obvious that from the outset of the latest phase of your investigation you h, ave considered the President to be a "target" of your investigation. We believe that the conclusion of then- Solicitor Bork in the investigation of Vice- President Agnew twenty- five years ago is the correct one:

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WILLIAMS 6 CONNOLLY

Robert J. .Bittman, Esq. July 27, 1998 Page 2

the "remarks [of the framers] strongly suggest an understanding that the President, as Chief Executive, would not be subject to the ordinary criminal process . . . . Their assumption that the President would not be subject to criminal process was based upon the crucial nature of his executive powers." 'Memorandum for the United States Concerning the Vice President's Claim of Constitutional Immunity, at 6, In Re Proceedinss of The Grad Jury Impaneled December 5, 1972, Civ. No. 73- 965 (D. Md. 1 (Oct. 5, 1973).

Accordingly, under circumstances in which you have apparently "targeted" your investigation on a sitting President, enforcement of a grand jury subpoena would violate the most fundamental separation of powers principles because it would invade the exclusive prerogatives of the Congress. Under Article I, the House "shall have the sole power of impeachment" and the Senate "shall have the sole power to try all impeachments." Under Article II of the Constitution, the President is duty- bound to uphold the separation of powers framework against unreasonable encroachment by other branches or by an unelected Independent Counsel. In order to protect the institution of the Presidency, we are prepared to litigate to preserve these important principles.

We hope that will not be necessary. For the past four years, we have worked with your Office to devise ways for the President to cooperate with the investigations of the Office of Independent Counsel in a manner that did not infringe his Article II responsibilities. He has voluntarily and unstintingly provided an enormous amount of information in response to a‘ great many requests from the OIC. He has, without the compulsion of subpoena, given testimony under oath on three different occasions to the Independent Counsel. He has twice given testimony for defendants in criminal proceedings and been subject to cross- examination by the Office of Independent Counsel. He has provided more than 90,000 pages of documents to the OIC, he has submitted interrogatory answers, and he has provided information. informally in a variety of ways. This amounts to extraordinary and unprecedented cooperation with an investigation of extraordinary and unprecedented duration, intrusiveness, and indefiniteness.

In my letters to you over the last few months, I have set forth in detail my concerns about your Office's investigation. I will not reiterate those here, but my reservations, as set forth in my correspondence, are substantial and, I believe, well- founded. Regarding leaks, for example,.

2349

WILLIAMS 6 CONNOLLY Robert J. Bittman, Esq. July 27, 1998 Page 3

Chief Judge Johnson's findings with respect to our three show- cause motions provide dramatic confirmation of my concerns.

Despite our serious and enduring concerns about the OIC's investigation, as I indicated in my July 24 letter, the President remains willing to provide the grand jury with the information it seeks, so long as he can do so in a way that is consistent with the obligations of his Office. We believe that, with your assistance, the serious constitutional questions presented here by a subpoena may be mooted. Our proposal is made in good faith and after serious deliberation. It reflects a meaningful attempt to accommodate both your needs and those of the Presidency. We are not suggesting other more limited options utilized by Presidents in the past, such as written interrogatories, which while precedented and defensible, would, we believe, be less satisfactory. The President is prepared to provide the information you seek under conditions that (1) are consistent with the precedents established in this investigation and (2) preserve the constitutional questions both for your Office and the President for later formal legal determination, if necessary.

In our correspondence during the last few months, .you have stated that the OIC "fully acknowledge[ dl that the President has immense and weighty responsibilities" and that the OIC "want[ ed] in every way to take fully into account those grave duties of state." (Your letter to me of March 2, 1998). You stated you wanted to "reiterate" that the OIC had "profound respect for the institution of the Presidency." (Your letter to me of March 13, 1998). We believe that the respect for the Office of the President, which you acknowledge, and which we share, requires that any testimony of the President be given under the following conditions:

1) The subpoena must be withdrawn. The President has on three different occasions voluntarily given sworn testimony when requested by the OIC. On two other occasions (in 19961, the President testified at the behest of two defendants by videotape at their trials. In our view, however, the constitutional considerations raised by your July I7 subpoena are quite different since, for example, a defendant has a Sixth Amendment right to compulsory process to present witnesses in his defense. For the separation of powers reasons discussed above and to avoid a precedent harmful to the institution of the Presidency, we believe that any testimony which the President provides now must be on a voluntary basis.

WILLIAMS 6 CONNOLLY

2350

Robert J. Bittman, Esq. July 27, 1998 Page 4

2) Any testimony by the President must be given by deposition at the White House, under the conditions of the first three OIC interviews. We anticipate that the examination will be (as it has been in the past) respectful, non- repetitive, and given within a specific time period (perhaps three hours). You will inform us of the specific areas you intend to cover (although, obviously, not of the questions you intend to ask). You will make a good faith effort to provide us documents in advance about which you plan to question the President, so he does not have to waste time at the deposition reading them for the first time.

3) Safeguards to prevent leaks must be devised. The President's January 17, 1998, deposition in the Paula Jones case was leaked to the press in flagrant violation of a court order. In this investigation, Chief Judge Johnson has entered orders for the OIC to show cause why it or individuals therein should not be held in contempt for violating Rule 6( e), Fed. R. Crim. P.: "The Court finds that the serious and repetitive nature of disclosures to the media of Rule 6( e) material strongly militates in favor of conducting a show cause hearing." (June 19, 1998, Order, at 5). Moreover, "[ slhould the Court find a direct violation of Rule

6 (e) , the Court reserves the right to take any appropriate steps, including referring the matter to the United States Attorney, the Department of Justice, or a special master for criminal contempt investigation and proceedings." (June 26, 1998, Order, at 2 n. 1). We do not seek to require impossible conditions or guarantees, but in light of the nature of the subject matter, the intense and corrosive media interest, and the history of leaks, there must be strict safeguards as to attendance, handling of the transcript (perhaps lodging the only copy with the court until it is presented to the grand jury), dissemination, etc.

4) This testimony will be given only after the President has an adequate time to prepare for it. In Clinton v. Jones, sunra, the Supreme Court remarked the "'unique position in the constitutional scheme" ' that the Presidency occupies and noted that the President "occupies a unique office with powers and responsibilities so vast and important that the public interest demands that he devote his undivided time and attention to his public duties." 117 S. Ct. at 1646. The Court held in that case that "[ tlhe high respect that is owed to the office of the Chief Executive, though not justifying a rule of categorical immunity, is a matter that should inform the conduct of the entire proceeding, including the timing and scope of discovery, n id. at 1650- 51 (footnote omitted), its assumption and its holding was based upon

"that the testimony of the President, both for

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WILLIAMS 6 CONNdLLY

Robert J. Bittman, Esq. July 27, 1998 Page 5

discovery and for use at trial, may be taken at the White House at a time that will accommodate his busy schedule," id. at 1643.

I last wrote you three months ago concerning the possibility of the President testifying, and I have heard absolutely nothing from you in the interim. In that and other letters, I have made clear that the President's schedule is an extremely full one that is set well in advance. Nevertheless, suddenly and without any advance notice, I received your subpoena at 6: 00 p. m. on Friday, July 17, while the President was away on a long- scheduled trip to Arkansas and Louisiana, and with other significant travel scheduled, seeking his grand jury testimony a mere ten days later. This has recently been an exceptionally busy period, with the trip to China, the continuing Asian debt crisis, the well- publicized events in Russia, tensions in the Middle East and in Ireland, and a host of domestic concerns, such as the drought and a pressing legislative agenda before this Congress ends. We would be derelict in our professional duties if we allowed the President to give testimony without adequate preparation. (Unlike the OIC, the President is one person, with many different public responsibilities). Given his present schedule and duties, it is inconceivable that he would be able to testify in the immediate future. Between today and August 15, the President is already scheduled to be out of town for six days and has an exceptionally busy schedule while here. He has a long- scheduled family vacation between August 15 and 30, but much of this will be absorbed with preparation for a critical trip to Russia and Ireland from August 31 through September 6. The first date the President could conceivably testify consistently with his other obligations would be Sunday, September 13, although we would, in simple fairness, request that his testimony occur on Sunday, September 20. While we are not aware of the witnesses who remain to be interviewed by the OIC, we believe that the pending legal disputes which are now sub iudice will plainly not be resolved before mid- September, and so we do not believe that a mid- September date for the President's testimony would itself unduly delay the completion of your investigation. It certainly would be sooner than any date you might anticipate were you to precipitate a legal confrontation.

I look forward to talking with you at your earliest convenience.

2352

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Tab 7

2354

2355

Office of the Independent Counsel

100 I Pennsylvania .- I venue. N. W. Suite 490- North Washington. DC 20004

(202) 5/ 4- 8688

Fax (202) 514- 8802

July 27, 1998

A HAND DETJVERY

David E. Kendall, Esq. Williams & Connolly 725 Twelfth Street, N. W. Washington, D. C. 20005

Re: miam Jefferson Clinton Dear David:

Thank you for your letter of fily 27, 1998, which we received at 1: 3O p. m. today. Although there is much in your letter with which we disagree, there is no reason at this point to engage in an extended discussion. Instead we wish to remain focused on the subject of obtaining the President's testimony for the grand jury.

Although we remain willing to accommodate the President's security and dignity concerns, we cannot agree with the other restrictions and conditions you suggest. Most importantly, we cannot agree to delay the testimony for another seven- plus weeks. The President has been aware since late January that the grand jury wants to hear his story, and he has declined numerous invitations to provide his testimony voluntarily. Therefore, further extensive delay of the type you propose is simply unacceptable. As a result, we will not withdraw the existing subpoena (as continued per today's telephone call, to 1: 30 p. m. on July 28th). If, however, by tomorrow at 1: 30 p. m., the President commits in writing to testify on a date certain on or before August 7, 1998, then we will continue the subpoena until that date. If the President agrees to a date certain, we will of course work closely with you to accommodate the logistical concerns that you have raised.

Sincerely, fi -A

Robert J. Bittman Deputy Independent Counsel

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July 27, 1998 Monday, NORTH SPORTS FINAL EDITION SECTION: NEWS; Pg. 1; ZONE: N LENGTH: 1137 words HEADLINE: STARR SUBPOENA POSES CONSTITUTIONAL CONFLICT BYLINE: By Naftali Bendavid, Washington Bureau. DATELINE: WASHINGTON BODY:

In subpoenaing President Clinton, Independent Counsel Kenneth Starr has delved into new legal territory and ignited a chain of events that ultimately could lead to a constitutional crisis.

Most starkly, a subpoena is a court order that, if defied, is punishable by imprisonment. But it seems clear that the president of the United States cannot be imprisoned under the Constitution because that would amount to the republic paralyzing its leader. So the meaning of this subpoena is unclear.

More broadly, the Constitution specifically provides a way to pursue criminal charges against a president-- the impeachment process, under which Congress can subpoena the president if it chooses. To many scholars, that suggests that an ordinary prosecutor or even an independent counsel may not summon the president to testify.

"This is an open constitutional- law question," said Georgetown University law professor Paul Rothstein, an expert in constitutional and criminal law. "We are sailing blindly on a dark sea. We dcn't know what will be found to be the constitutional solution."

Meanwhile, White House officials Sunday continued their refusal even to confirm that Clinton has been served with a subpoena. Despite widespread reports that Starr issued such a summons last week, top advisers, including Rahm Emanuel, would say only that negotiations are under way on how Clinton can provide Starr the information he seeks.

Starr's subpoena may be little more than a bargaining move, a way to force a reluctant Clinton to give his version of the events surrounding the allegations that he lied under oath about a supposed affair with White House intern Monica Lewinsky.

If the negotiations fail, Clinton could decide to fight the subpoena. That would set up a clash between the judicial and executive branches that, while echoing President Richard Nixon's defiance when ordered to turn over the Watergate tapes, would be essentially unprecedented.

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Chicago Tribune, July 27, 1998 Page 13

security and other sensitive matters, to that sort of rapid- fire questioning, according to University of Chicago law professor David Strauss.

"1n an imaginary world, you could have the president step outside the grand jury room after each question and meet with the head of the CIA and the head of the Joint Chiefs of Staff and say, 'What do you think? ' * said Strauss, who assisted Clinton's legal team in the Paula Jones sexual- harassment case.

In the real world, that can't happen, Strauss added. "It's hard to think it was the constitutional plan for the president to answer questions like that," he said.

Only twice, scholars say, have the nation's courts seen an issue even remotely like this. In 1807, President Thomas Jefferson was subpoenaed to give information in the trial of Aaron Burr, who was charged with treason. Jefferson declined to testify, but he supplied documents that seemed to satisfy prosecutors.

In 1974, the Watergate special prosecutor sought tapes Nixon had made of. conversations in the Oval Office. Nixon fought the subpoena, but the Supreme Court ruled 8- O against him.

Some say the Nixon case suggests that Clinton must respond to Starr's summons. But others emphasize the di' iference between a president turning over evidence such as tapes and appearing in person to be peppered with questions.

"This is a big game of chicken, as ail negotiations between lawyers are," Tushnet said. When it comes down to it, he added, even top scholars have absolutely no idea how the courts would rule.

The issue highlights yet again the quirky nature of the independent counsel system. No ordinary federal prosecutor would be likely to subpoena the president because the president is his boss and could order him not to do so.

To Strauss, the gravity of the constitutional issues contrasts sharply with the triviality of the underlying allegacisns, which involve possible perjury in a case that was dismissed by a court.

"1 can't imagine there is a real- life prosecutor who would spend more than 10 minutes on a case like this," Strauss said, "let alone establish a new constitutional precedent."

THE LAW. LANGUAGE: ENGLISH LOAD- DATE: July 27, 1998

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123RD STORY of Level 1 printed in FULL format, content and programming copyright (c) 1998 American Broadcasting Companies, Inc. All rights reserved. No quotes from the materials contained herein may be used in any media without attribution to American Broadcasting Companies, Inc.

This transcript may not be reproduced in whole or in part without prior permission. For further information please contact ABC's Office of the General Counsel. Transcribed by

ABC NEWS SHOW: ABC GOOD MORNING AMERICA SUNDAY (lo: 00 am ET)

JULY 26, 1998 Transcript # 98072605- j02 TYPE: INTERVIEW SECTION: NEWS LENGTH: 614 words HEADLINE: PRESIDENTIAL SUBPOENA ISSUES GUESTS: PAUL ROTHSTEXN BYLINE: AARON BROWN HIGHLIGHT: LAST DANCE ON LEWINSKY CASE ABOUT TO BEGIN

BODY: THIS IS A RUSH TRANSCRIPT. THIS COPY MAY NOT BE IN ITS FINAL FORM AND MAY BE UPDATED.

AARON BROWN, Host: Well, it does indeed seem like the last dance on the Lewinsky case is about to begin. So we’ re going to talk a bit about Kenneth Starr's attempt to subpoena the President. He has issued the subpoena. There are lots of questions here, as we've been suggesting this morning, legal and political. Some of those tend to run together.

Joining us this morning is Georgetown iaw professor Paul Rothstein. He joins us from Washington. Good morning, sir.

Prof. PAUL ROTHSTEIN, Georgetown University: Good morning, Aaron, AARON BROWN: Well, I guess because we are in uncharted waters, it's hard to give

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Page4 ABC GOOD MORNINGAMERICASUNDAY, JULY~~, 1998

a clean answer to the most basic question, which to me is, does he have the right to subpoena the President?

Prof. PAUL ROTHSTEIN: Well, the qUeStiOn is an open one under constitutional law. He can probably issue the subpoena, but the big question is whether the President can be forced to comply with it. What are you going to do, throw a president in jail if he doesn't comply with it ? That would tie up the whole country . That would disable the people's president.

The Constitution provides for the only way to get a president out, which is impeachment. There a separation of powers in the Constitution. One branch of government, the courts, is not supposed to intrude on the other branches, the executive, which is the President. But we just don't know.

In the Nixon case, President Nixon was commanded to give up tapes, and in the Paula Jones case, the Supreme Court said President Clinton must respond to a civil lawsuit. But that's all different than requiring the person of the President to appear in a criminal inquiry before a grand jury, where he is the probable target.

AARON BROWN: And -- which is another question. I mean, isn't the argument -- or might the argument from the prosecutor's office be, "Well, we don't intend to indict the President. We're not sure we can. That's really the Congress's job. So he's not really a target of the investigation"?

Prof. PAUL ROTHSTEIN: Well, that would be one of the arguments. The constitutional law question is open. But that would be an argument on one side. But I don't think either side wants to have push come to shove and take this on up to the Supreme Court and maybe lose it. You know, both sides see there's a risk of loss and embarrassment and delay. Starr wouldn't want delay, so maybe that's why they're negotiating, you know, over something less than full grand jury testimony.

AARON BROWN: Read some tea leaves for me, because I'm a little befuddled, which is not unusual in my case, that he went for the President first and not Ms. Lewinsky to start the end game. What do you think his strategy, him, Starr, being here, what is his strategy?

Prof. PAUL ROTHSTEIN: Well, you see, the President is probably getting a lot of information from witnesses themselves as they appear before the grand jury. And then the President will try to fashion his testimony to be consistent with that, insofar as he can, whether he's a guilty president or an innocent president.

So if Lewinsky went first, the President would have that additional... AARON BROWN: Got it. Prof. PAUL ROTHSTEIN:... piece of the jigsaw puzzle. AARON BROWN: Paul, thanks. Paul Rothstein, a law professor at Georgetown University, helping us understand what is quite a complicated legal and

.- political question that both Kenneth Starr and the White House face this morning now _

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Page 5 ABC GOOD MORNING AMERICA SUNDAY, JULY 26.1998

(Commercial Break) LANGUAGE: ENGLISH LOAD- DATE: July 26, 1998

LAW OmCEs

WILLIAMS & CONNOLLY

725 TWELFTH STREET, N. W. WASHINGTON, DC 20005- 5901

VIA HAND DELIVERY Robert J. Bittman, Esquire Deputy Independent Counsel Office of the Indepedent Counsel 1001 Pennsylvania Avenue, NW Suite &go- North Washington, DC

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Misc. No. 98- 267 Washington, D. C. July 28, 1998 4: 30 p. m.

IN RE: . MOTION TO CONTINUE . .

. . . . . . . . . . . . . . . . . . . TRANSCRIPT OF STATUS HEARING BEFORE THE HONORABLE NORMA HOLLOWAY JOHNSON

CHIEF JUDGE, UNITED STATES DISTRICT COURT APPEARANCES: For the Office of Independent Counsel:

For the Movant, President Clinton:

ROBERT BITTMAN, ESQUIRE SAUL WISENBERG, ESQUIRE JOSEPH DITKOFF, ESQUIRE

DAVID E. KENDALL, ESQUIRE NICOLE SELIGMAN, ESQUIRE MAX STIER, ESQUIRE ALICIA MARTI, ESQUIRE

Official Court Reporter: GORDON A. SLODYSKO 4806- A U. S. Courthouse Washington, D. C. 20001 (202) 273- 0404

Computer- Aided Transcription of Stenographic Notes

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2 PROCEEDINGS THE COURT: Good afternoon. COUNSEL: Good afternoon, Your Honor. THE DEPUTY CLERK: Miscellaneous Case Number 98- 267, In re Motion to Continue. Representing the Office of the Independent Counsel are Robert Bittman, Saul Wisenberg, and Joseph Ditkoff. Representing President Clinton is David Kendall, Nicole Seligman, Max Stier, and Alicia Marti.

THE COURT: All right. Counsel, I received this afternoon President Clinton's motion for continuance. I'm sure the Office of Independent Counsel would like a chance to respond to that motion. In the interest of time, and certainly in light of the public interest in moving this matter expeditiously, I will allow each side to present oral argument on the motion for continuance rather than asking the parties to submit written responses. I will hear from each of you for I hope not more than ten minutes a side and then make my ruling. If you need more than ten minutes, I certainly will grant you additional time. But I would hope that we could do it in about ten minutes a side.

And since it is the President's motion, I will hear from Mr. Kendall first.

MR. KENDALL: May it please the Court. We've moved for a two- week continuance of a subpoena ad testificandum delivered to counsel for the President on Friday, July 17th.

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In some ways, Your Honor, I regret the need to burden you with this motion; I think it was unnecessary. But we were unable to

get a continuance worked out with the Office of Independent Counsel.

I would like to explain a little about the background of this, if I may. This is not the first time the President's testimony has been sought. Indeed, on three different occasions he has given testimony at the behest of the Independent Counsel during the Whitewater investigation. The first time this occurred was in June of 1994, when Mr. Fisk was Independent Counsel. The second time was in April of 1995, after the present Independent Counsel was appointed on August 5th, 1994. And the third time was in July of 1995. Now, on each occasion we were able to work out a mutually acceptable way of providing for this testimony.

The President also testified twice by videotape in criminal trials of defendants indicted by the Whitewater grand jury in Arkansas. And on those occasions, the Independent Counsel was able to cross- examine the President.

As is clear from our motion, we had correspondence with the Independent Counsel earlier this spring about the President voluntarily appearing. I had many concerns about this. They were set forth in the correspondence. That correspondence really lapsed in April. The next thing we heard-- was the letter attached to the subpoena which was delivered to

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me at approximately 6: 00 p. m. Friday, July 17th. Your Honor, I initially sought time because this is

the summer. Various people are somewhat scattered. Mr. Kantor, for example, is in China. He's been in China --

THE COURT: Mr. who? MR. KENDALL: Mr. Mickey Kantor. THE COURT: Oh, okay.

MR. KJBTDALL: One of the President‘ s private attorneys who has been advising on this matter.

We were, however, able to make a quite specific proposal to the Independent Counsel, which was delivered yesterday, and that is at Tab 6 of our papers. This is a letter in which I try to outline some of our concerns, how they may be met. It provides a date, a specific date for the President to give testimony and an alternative date. And that, I hoped, would be a good faith offer that would allow us to negotiate, as we have in the past, and settle on both the timing and terms of the President's testimony.

I was surprised that the Independent Counsel refused to withdraw or suspend this subpoena, and therefore, I made

this motion. I think it unseemly for the President of the United States to be in any way in violation of legal process. I think there are obvious reasons for that, And therefore, in an effort to avoid that, we made a motion for a brief continuance.

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5 Your Honor, there are no deadlines, there are no statutes of limitation, there are no pending trials. There is really nothing substantive to warrant the denial of this very brief continuance.

I think that 'we may not in fact need the two weeks. It may be possible that we can very quickly work with the Independent Counsel to come to an agreement on the terms and timing. But as the motion papers make clear, this is a literally unprecedented legal act. The testimony of the President has never been compelled before a grand jury before, and there are very serious constitutional questions, the litigation of which would be quite time- consuming. We don't necessarily want to have to tackle those questions if we can come to an agreement that would allow both sides -- this has happened often in this investigation -- to maintain their positions but work together to get by a common problem.

The President of the United States -- I would be making this motion if it were anybody, in order to get the requisite time to try and work something out; and if things can't be worked out, to get the input of the people necessary to determine the proper arguments to be made on behalf of the President of the United States. The President is the President, however. He has public duties. And the language of the Jones case, the Clinton versus Jones case, is, I think, quite on point here because, while the Supreme Court did rule

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that the President while in office could be subjected to civil litigation, it also ruled that the conduct of that litigation had to be undertaken by the supervising judge with great sensitivity to the President's duties and great deference to the many demands on his time.

It is difficult to convey -- I have represented busy people before. It is difficult to convey how busy the President is, how many demands there are on his time. And in the past it has taken us time to work out not only a time for the President to testify, but a time in which he can be adequately prepared, because he has many duties and many demands. And every client deserves the effective assistance of counsel in getting them ready to testify so they can testify as effectively and accurately as possible.

We quoted some of the language in Clinton versus Jones. One of the things the Court stated was it articulated the assumption that any testimony from the President may be taken at a time that will accommodate his busy schedule. Your Honor, again, I think that the -- we've set forth in the letter the considerations that are important to us, considerations about the President's schedule. And we respectfully submit that this continuance is not lengthy. It may in fact make unnecessary other litigation. And we respectfully would ' request that the Court grant us a two- week continuance.

THE COURT: What do you want to do with the two weeks?

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You know, you ask me for a two- week continuance. Are you asking me to give you two weeks to let the President respond to the subpoena, or are you asking me to give you two weeks to determine how you wish to respond to the subpoena? Just what are you asking me for?

MR. KENDALL: I think the former, Your Honor. I think it's the former.

THE COURT: Well, since I've said a couple of things, you'd better tell me what my former is.

MR. KENDALL: The former, Your Honor, as I understood it, was to enable the President to determine how most appropriately to respond to the subpoena.

It may be -- and I don't know what the -- because I didn't -- I've had communications with Mr. Bittman. I don't know. My own view is that we should take testimony as we have done it before. That has the great value of precedent. And I think not only judges, but lawyers, there's a value in doing things the way they've been done in the past. I think if we can do that and find a date, the rest of the motion will be moot and we will come to agreement on a time and terms. That's what I hope will happen. We will try to make that happen,

Now, it's possible that we will not be able to come to those terms. A subpoena has been issued here. It's possible that the response would be some kind of a motion. And that would be done at the end of that two- week period.

2376 8 so, I think what happens at the end of the two weeks 2 I really depends on what goes on during it. I

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TBE COURT: So you're really not seeking just a two- weeks continuance of the return of the subpoena. You are actually seeking two weeks to determine what you want to do with respect. to the subpoena.

MR. KENDALL: Your Honor, I think that's correct, although --

THE COURT: Because the way I understand it -- I could be wrong, because I haven't seen the subpoena, and I haven't asked anybody to see it, but the way I understand it, the subpoena that he received in July stated that he should appear in person today. Is that correct?

MR. KEXDALL: That's correct, Your Honor. THE COURT: Okay. So, what you're saying to me is you're not asking me to just continue that appearance for two weeks. You're asking me to give you two weeks to raise further or additional legal argument.

MR. KEXDALL: Your Honor, I don't know. It seems to me that I am asking you to continue it as well. What we don't

want to have is the President in violation of the subpoena. And therefore, in the normal case you would phone up the prosecutor and say, "You've subpoenaed my client for Monday;, she's going to be in Chicago that day. Could you move it to Wednesday?" And normally, that's possible.

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THE COURT: Yes.

MR. KENDALL: Depending on the grand jury. Here, I think if we can get the continuance, in the interim I hope we will be able to work out an agreement whereby we won't have to come back to the Court at all, we will do the testimony. If we can't, then at the end of that period we would file a motion.

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THE COURT: All right. MR. KENDALL: Thank you, Your Honor. THE COURT: Thank you. I'll be happy to hear from you now, Mr. Bittman. MR. BITTMAN: Good afternoon, Your Honor. Robert on behalf of the United States. Let me clarify something as to how we got involved in 15 16 17 18

the chronology of what occurred. It was exactly six months ago today that we invited the President the first time to appear before the grand jury. Six months ago today.

Mr. Kendall correctly referred to the fact that our 19

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office has received testimony from the President before. That was via negotiation. But it was always with an invitation first, which the President accepted immediately, and then we hammered out some of the details as to when and how the President would testify.

24 In this case, we, and the grand jury, I might add,

25 felt it necessary to issue a subpoena to the President because

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I 10 1 the President had refused six invitations to testify. They

i were, frankly, just, in my words, stringing us along, and the grand jury. The President publicly stated that he was prepared to cooperate with the investigation and give information sooner rather than later, more rather than less, and yet he refused -- or declined, rather, six consecutive invitations to testify.

As you know, the grand jury has been working very, very hard, at great sacrifice to them. It has had effects on their families; it has had job effects. And they've been working very, very hard. They have been very gracious in allowing us extra days and extra time recently.

This litigation -- or, pardon me, this investigation has also had a number of parties assert various privileges that have burdened not only this Court but the Court of Appeals, and some of them have gone all the way to the Supreme Court.

And we have tried to move things along as expeditiously as possible. The grand jury has been working very hard. And it is time to receive the President's testimony, if he so chooses.

THE COURT: And you say there have been six invitations?

MR. BITTMAN: There have been six invitations. THE COURT: All right. And how did those invitations go? Were they in writing, as opposed to oral?

MR. BITTMAN: The first invitation was oral. The

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11 other five were all in writing. And I believe Mr. Kendall appended all of the invitations to his pleading. All of them are in there.

THE COURT: All right. MR. BITTMAN: And then Mr. Kendall's responses are all there, also.

THE COURT: All right. MR. BITTMAN: With regard to the President's schedule, he is a very busy person. And the Jones v. Clinton case makes it clear that the justice process should accommodate the President's schedule and should defer to him in his official capacity. I'm sure Mr. Kendall knows the President's schedule better than I do, but we have done some research, even in terms of when we set today, to make sure that he was in town. We've checked it in the future, too. And our understanding is that the President, for example, is going away this weekend for some fund- raising events and for some rest and relaxation, and then he's taking a two- week vacation in August.

We do not want to interrupt the President's foreign trips or any official business that the President, obviously, will be involved in. But we think the timing is right. The grand jury, you know, has been working, once again, as I said, very hard. And I don't think I want to reveal to Mr. Kendall exactly why the grand jury wishes the President's testimony now. And we're certainly not obligated to, and we're not going

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12 to. But this is the time.

We have tried to accommodate the President's schedule. We have offered innumerable dates through August 7th. We will 90 -- well, we haven't worked out the exact, precise details of how we would receive the President's testimony, but I'm confident we can do that if we get an agreement from the President that he will appear before -- in the very near future. And that just hasn't been forthcoming.

The date offered by Mr. Kendall in mid- September is just unacceptable. It is just unacceptable to the grand jury's schedule and to the grand jury‘ s investigation. We just cannot wait that long for the President's testimony.

The investigation is very, very important. The President has so stated that. And I don't think that the investigation should wait for him to play golf, for fund- raising events, and for his vacations.

Mr. Kendall in his papers discusses that this could raise some sort of a constitutional crisis. We don't believe so. We have thoroughly reviewed the law and we believe we are absolutely entitled, with the grand jury's approval, to issue a subpoena to the President. The Nixon case made clear that the President of the United States may be subpoenaed in a criminal trial. The Jones v. Clinton case itself authorizes a court to -- that the President appear at a deposition in a civil case. Clearly, if he has to appear in a civil case and answer

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to civil charges, he would have to answer a criminal grand jury subpoena.

The President also, as we've discussed, has appeared before. He's provided depositions to us. He's appeared in criminal trials. He was subpoenaed by the defense in two trials in Arkansas. He testified in those trials -- after being deposed, but he testified. And then in this case, we issued a grand jury subpoena duces tecum, for documents, to the President early on in the investigation and he complied with that subpoena. I think it's odd now to all of a sudden say, well, he's not going to comply with this one.

So, unless Your Honor has any questions for me. We

just want to get this resolved. We wish to know exactly what the President is going to do.

THE COURT: So what I understand from you is that you do maintain that the grand jury wants to have the President appear before it.

MR. BITTMAN: Yes. THE COURT: And that you're saying you need it now. MR. BITTMAN: Yes. THE COURT: Rather than in September. MR. BITTMAN: Yes. THE COURT: Do you have any idea -- and if you don't, I can understand, because I do know enough about grand juries

to know that you can't always tell how many questions a grand

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jury may choose to ask or anything like that. Do you have any sense of how long he might be required to appear before the grand jury? Do you have any sense?

MR. BITTMAN: I think it would be several hours. Less than -- well, I don't know. It would be several hours.

And. let me amend one of my answers with regard to the grand jury's wishes as to whether the President actually appear before them. Without revealing too much of what goes on in the grand jury --

THE COURT: Certainly. MR. BITTMAN: -- that is their belief now. But we 12 13 14 15 16 17 18 19

believe that if given a concrete offer by the President, that is, that he, the President, is willing to do this, to a deposition, perhaps in front of the grand jurors in an area outside the grand jury room, perhaps a deposition, obviously under oath, just before attorneys from our office, something like that in the immediate future, we believe that we can gain the -- that we would speak to the grand jury and see if that nlere acceptable to them. 20 THE COURT: Well, let me just say, I know that even 21 :hose type of issues could seriously be considered Rule 6( e). 22 23 24

3ut I just wanted to get some sense. That subpoena was issued by the grand correct?

jury, is that 25 MR. BITTMAN: Yes _

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15 THE COURT: And that was the subpoena that was returnable today.

MR. BITTMAN: Yes. THE COURT: At 1: 30. MR. BITTMAN: It was actually returnable originally for 9: 15, and then I permitted Mr. Kendall till 1: 30. I extended it to 1: 30.

THE COURT: All right. So your position is that the grand jury wishes to hear from him sooner than later.

MR. BITTMAN: Oh, yes. They have been kept informed throughout about our invitations and the President's declinations. And Your Honor knows that the grand jury's investigation has proceeded. And it is time to hear from this particular witness, the President.

THE COURT: Very well. Thank you. MR. BITTMAN: And we at minimum wish, obviously, a response to whether the President is going to testify and then some concrete terms, because we just can't have this open- ended thing where, okay, in two weeks they may file a motion to quash which is going to further delay the investigation. If a motion to quash is to be filed, we wish to litigate it right away. And, frankly, we would ask Your Honor, if one is filed, for an expedited briefing schedule and expedited hearing, because we want this very, very quickly.

THE COURT: Very well. Thank you.

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16 Mr. Kendall, I'll be happy to hear anything further that you wish to say on this issue.

MR. KENDALL: Thank you, Your Honor. I regret that these somewhat voluminous papers probably hit your desk this afternoon.

THE COURT: Believe me, they did. MR. KENDALL: They hit it with a thud, I'm sure. THE COURT: Yes, they did. MR. KENDALL: Your Honor, at Attachment 6, when Mr. Bittman says --

THE COURT: Which I have not been able -- I have not read your attachments yet, but I have read your motion.

MR. KENDALL: Okay. I would simply direct the Court's attention to that because that was our attempt -- Mr. Bittman and I had conversations and he wanted a specific proposal. This is a specific proposal. It proposes both a time and terms. It's as specific, really, as we can get it.

Your Honor, it's simply not the case that this matter has been in discussion since January. It was in discussion in late January to April, and then we heard -- my last letter, which I've appended here, was not responded to. So there was a long three months, plus, pause in this, and then suddenly we got the subpoena. And so it is not --

THE COURT: Let me ask you, what about letters from the grand jury? I understand that the grand jury was sending

1 him a written invitation? 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

MR. KENDALL: Well, we received invitations from the Office of Independent Counsel. We never got anything from the grand jury itself.

THE COURT: But I mean the invitations from the Office of Independent Counsel indicated, though, that the purpose was for him to appear before the grand jury, wasn't it?

MR. KENDALL: They did, Your Honor. THE COURT: And you didn't consider that to be from the grand jury?

MR. KENDALL: Well, Your Honor, I did. We responded to each one of those. And we responded -- we had many questions. And this Court is familiar with certain of our concerns about this investigation --

THE COURT: Certainly. MR. KENDALL: -- and the way it's progressed. We had, and continue to have, very serious concerns about certain aspects of it. I don't want to have to litigate the constitutional questions, but they are important, they are unresolved. I am reminded when Mr. Bittman -- and, you know, I don't think the Court wants to hear those arguments today. We haven't filed them. But --

THE COURT: No. Just the motion for continuance. MR. KENDALL: Every pancake has two sides, Your Honor, as is well known. And we stand ready to make those at an

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18 appropriate time. But I think the --

I THE COURT: But, you see, that's one of the things

that caused me to ask you gentlemen to come in here today. I wasn't sure what you meant by give you until such- and- such a time, and I really needed you to come in here and tell me, what do you mean? Do you mean that you will be prepared to respond to the subpoena by that day, or do you mean that "I'm going to give this further thought and then two weeks from now I'm going to tell you what I think?" I need to know precisely what you mean.

And I think you have made it clear to me that the motion for continuance that you filed today is not designed to just continue the personal response to the subpoena. In other words, you're not saying, "If you give me two weeks, the President will respond by coming in to see the grand jury or having the grand jury come to see him." And, God knows, I would say to you, recognizing the duties of his office, if it were more convenient, more secure for the grand jury to go to him than for him to come to the grand jury -- and you know what type of atmosphere we have around this building -- then that's one thing. But if what you're saying is III need two weeks to consider how I'm going to deal with this," then that's another question.

MR. KENDALL: Your Honor, again, the letter at Attachment 6 is a very --

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2387

19 THE COURT: As I said, I'll read it tonight. MR. KENDALL: Yes. It's a very specific offer. And it's premised -- we've worked this out, really, three times in the past successfully. I think that both our concerns and the Independent Counsel's concerns were met. I think the letter is a good faith attempt to do that again. And I hope that after discussion, we can work out a way -- reserving our questions. I mean, these are negotiations in which both sides want to reserve their option. But three times before, we've had the President testify and that has --

THE COURT: Three times before testified with respect to what? This case?

MR. KFNDALL: With respect to this investigation. This is the Whitewater -- in other words, he gave testimony about various phases of it, Vincent Foster and David Hale and the 1990 gubernatorial campaign.

THE COURT: But I don't think this grand jury wants to ask any of those questions.

MR. KENDALL: Oh, no. No. I understand that, Your 3onor. This is the Lewinsky --

THE COURT: Yes. MR. KENDALL: And that's what we're talking about nere. My only point is, we've been able to work this out three times in the past. And it's my hope that based upon the proposal we've made in the letter at Tab 6, that we can do it

2388

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again, and so we won't be coming back to Your Honor. THE COURT: Well, let me just say, apparently -- and I've got to believe this -- with your letter dated July 27th, which was yesterday, they have had an opportunity to read that letter before they got your papers that you filed in the court today around midday. Isn't that true? Every reason to believe they've had an opportunity to read that.

MR. KENDALL: That's correct, Your Honor. THE COURT: And even though they have had that opportunity to read it, their stated position on the record is to the contrary of what you're saying -- of what you say your letter says: That they can work it out. In fact, what I heard Mr. Bittman say is that he needs the testimony. You're saying you think you can work it out.

MR. KENDALL: Your Honor, we are trying to work it out to give them the testimony.

THE COURT: Let me just ask you something, Mr. Bittman. Had you read this letter before you came in here today?

MR. BITTMAN: Yes, Your Honor. We responded to it. THE COURT: Oh, you did? And is it here, too? MR. BITTMAN': Yes. THE COURT: Okay. MR. BITTMAN: That's at Attachment 7. THE COURT: I haven't read the attachments, all right?

I. 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

You see, what I -- I mean just applying a little common sense here, if you sent this letter yesterday, they received it, they read it, they responded to it. Still, the subpoena remained outstanding, and the grand jury, who actually was the only body that could authorize that subpoena, apparently was waiting for the subpoena to be responded to today. Then we get your request. And, as I said, you asked me

for two weeks and I just didn't quite understand what that two weeks meant. I understand now, based upon your statement to me, what you mean by giving you that additional two weeks, but that does not take into consideration the body which sought the subpoena. You see, that's what concerns me, Mr. Kendall.

I'm not saying -- and I want you to understand, I'm not saying that this grand jury has a right to subpoena the President of the United States. I'm sure that they have subpoenaed the President of the United States. And what I am

not hearing from you is that "We oppose this subpoena because the grand jury does not have that right." You're saying, "Just give me two weeks to think about something, and then two weeks from now I'll tell you something." And then if two weeks from now you say, "Well, I don't really think they have the right to subpoena the President, and therefore, Your Honor, may I have 25 two more weeks to file a motion to quash the subpoena." I just

2389

I will read them before I leave here this evening, though, okay?

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think that based upon what we all know about this case, the sooner we make a decision, the better.

MR. KENDALL: Your Honor, may I respond to that? THE COURT: Surely you may. MR. KENDALL: And I will respond, I hope, in a factual way. I'm not saying that I want a limitless set of extensions. I think that these are very important constitutional questions. If we go to war over them --

THE COURT: No question about it, but the question is, do we have to deal with the constitutional issue? Because if we do, let's do that head- on.

MR. KENDALL: But, Your Honor, if we go to war over that, that is going to take a lot of time.

THE COURT: We're not going to go to war, and we're going to do it the same way the Court of Appeals has you do things. I just find it so interesting. Everybody needs 10, 12 days if you are here in the district court, but I understand that those judges on the Court of Appeals give two days or three days. I said, "Why can't I exercise that power? I have a commission too." So, no, we aren't going to be in it forever, okay? All right.

I'm being facetious, of course. MR. KENDALL: My only point is, Your Honor, if the object is to get the testimony to the grand jury, I think some statesmanship on both sides is necessary. And I say that about

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2391

23 us as well as the Independent Counsel. I think that if we can work this out, we are obligated to do so, because that really is our civic duty. We've done it three times --

THE COURT: You all have had a long time, apparently, to do that, Mr. Kendall, if what Mr. Bittman says is correct. Mr. Bittman says that there was a subpoena issued one time. Was that correct?

MR. KENDALL: Your Honor, only on the 17th of July. A week ago.

THE COURT: Yes. Only the one on July 17th? MR. KENDALL: Yes. I'm sorry. He mentioned -- excuse me, Your Honor. He did mention a subpoena for certain objects that was issued in January.

THE COURT: Oh, yes, duces tecum, and that was taken care of. But I understand that there have been about six invitations from the grand jury. So, apparently the President has known for some time that the grand jury wished to speak with him.

Now, I don't know, because, God knows, you know, I may have to go up there and see if they have water and a few other things from time to time, but I don't know what goes on before the grand jury as you know. But I would think if somebody had received six letters inviting him to appear before the grand jury, that person -- and I don't mean to be unkind, but certainly his counsel must know that somebody is going to get

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2392

24 tired of written invitations and look to other sources. I mean, that's just common sense.

MR. KENDALL: Your Honor, we've tried in Tab 1 to give you the complete correspondence, because it states our concerns and the responses. And I think in fairness, that correspond- ence terminated when I sent a letter on April the 17th. I didn't know what the answer was. And a very long time elapsed.

My only point here, Your Honor, is that I -- THE COURT: Are you saying that there were no invitations from the grand jury since April 17th?

MR. KENDALL: April 3rd, in fact, Your Honor, was the last.

THE COURT: Was the last letter from the grand jury? MR. KENDALL: Yes. And then all of a sudden, without any warning, we get a subpoena. And that old lawyer's trick, Your Honor, delivering it late Friday night so you can have that date of the week and say, "We served it on July 17th." It came in about 6: 00 o'clock. That is what is forcing this issue.

In the past, we have been able to resolve this. I don't think it's seemly or statesmanlike, or even very reasonable, to put us under the gun of saying, as they say in their response to the letter of yesterday, "Well, you just commit to this date," and it's an unreasonable date in terms of the President's schedule. We're going to have to file a

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motion. I don't think we should be in the position of having to file a motion which, if we can resolve the other issues, may be unnecessary.

THE COURT: Well, why do you need so much time to resolve the other issues?

MR. KENDALL: I'm not sure we do, Your Honor. I'm not sure we do. I'm not sure that we can't do this very speedily. But the scheduling really is a problem.

THE COURT: What you're saying is, you have not as yet made the decision whether you are going to challenge the constitutionality of this subpoena.

MR. KENDALL: We have made a decision, Your Honor, that we've testified in the past, we believe we can testify at this time. But we don't know what their position is and they may force us to challenge this, and then we'll challenge it.

I used the "war" metaphor. We're not going to go to war. But we'll file motions to quash. And my only point is, it is unreasonable -- you wouldn't do this in the normal case, Your Honor. You wouldn't refuse to continue a subpoena for a short time to see if it all was going to be unnecessary. And that's really all we're seeking. And at the end of the day, we may have to file a motion to quash, to bring on the constitutional issue, to preserve the institutional concerns of the Article II entity, person that we represent. It hasn't been necessary in the past; I don't believe it necessarily will

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2394

be necessary now. But it could be. THE COURT: Well, you say it may not be necessary, the amount of time you're seeking, but you still seek that time.

MR. KENDALL: I do, Your Honor. THE COURT: All right. Anything else? MR.. KENDALL: The only thing I would say is, in reference to Mr. Bittman's statement about the President's schedule, it is true, he does have a vacation planned for late August. It's a well- deserved vacation. It, unfortunately, is right on the eve of his Russia trip and Ireland trip. That's a trip from August 31 to September the 6th. Both those countries are very important. A lot of that vacation is going to be absorbed with preparing for the Russia trip.

Again, we are trying -- we've given them the date in September. We are aware from other parties who have been * subpoenaed that the grand jury's work is going on. There are many other legal questions which are in the process of being resolved. We really don't think that this date will delay the grand jury's work, and we want to make it possible, if we can, to give the President's testimony as soon as possible.

THE COURT: Well, let me just say this. You know, even I don't know what the grand jury is doing. And I'm certain that Mr. Bittman has some sense because he knows what has been presented to the grand jury and what he wishes to present to the grand jury. But I haven't the foggiest notion

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27 of what they have presented or what they wish to present. I

I learn most of what I know about that grand jury the same way most citizens in this city do, and we don't know how accurate

that is, but that's from the local press. Now, what concerns me is this: This case is unlike the Jones case. It truly is unlike the Jones case. And even though it is quite unlike the Jones case, we know what the Supreme Court felt about even a civil action of the type that we have there. Here, we have a criminal investigation going on. Here, we know from just reading the press that perhaps witnesses who have been called in before this grand jury have been testifying about certain conduct. I don't know what that grand jury thinks, but it perhaps thinks that "We citizens have been brought from our regular responsibilities and asked to listen to certain evidence, and we have decided, based upon what we have heard, that we need to hear from the President."

Now, maybe they don't have any legal right to hear from the President. Maybe that is an issue we will have to resolve before this subpoena can be honored. But what we need to do, I think, is to move forward, and move forward expeditiously.

Apparently, the President has been given, if you'll excuse this slang, a heads- up by the number of invitations. Did I determine that those invitations were in writing?

MR. KENDALL: Some of them were, Your Honor. They are

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28 reflected, I think, in the correspondence in Tab 1.

THE COURT: As I said, I'll read this. But some of it -- at any rate, he's received six invitations. And apparently the grand jury has determined that "Although we would like to honor your position as our President by simply asking you to appear voluntarily, we have now reached the point I where we believe that you will not honor us with your presence voluntarily, but we do believe that in our search for the truth, we need to hear from you." And now, for him to say, "Give me two weeks to think whether I'm going to challenge this legally or what I'm going- to do, give me two weeks to see if I can work this out with the prosecutor, give me two weeks to see whatever I need to do," but by the time that two weeks is up, Mr. Kendall, you're saying to me he will -- I don't know whether he's going to the Cape this year or not, but I know that's where he generally goes. Whether he will be at the Cape by the time the two weeks is up. And, clearly, I've been told that after leaving the Cape, he'll be going to Russia. So, when, if ever, unless somebody directs him, will he be willing to respond to this grand jury? Or if he isn't willing to respond to the grand jury, tell me.

MR. KENDALL: Your Honor, it's a fair question. THE COURT: Tell me. And then we will do what we have to do.

MR. KENDALL: We've given two dates. I think that's a

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very fair question. you'll see in the letter at Tab 6 -- THE COURT: The July 27th letter? MR. KENDALL: Exactly. THE COURT: All right. MR. KENDALL: We have said, because of the Russia trip, because of the vacation and other travel. And, again, it's very easy to sit there, whether you're reading a newspaper, you're in the Office of Independent Counsel, and say, well, that trip's not necessary, that's just a fund- raising trip, and that's a political trip, and, look, I don't think Ireland is such an important country. Those concerns are the President's, and the President's alone, to balance. And courts -- I mean, again, the teaching of Clinton v. Jones, I think, is that a court must try to accommodate and give deference to the President's schedule.

THE COURT: That's true. And as I said, I understand that very, very clearly, because we know that as President of these United States, this gentleman has concerns that none of us know about. We know that there are issues of state that none of us know about. We know all of that. But I also know this: If he can vacation for a couple of weeks, he can appear before a grand jury, too, you know.

And God knows, he needs a vacation. I know that. I know he needs a vacation. And I don't know that the grand jury will -- he doesn't know how -- the grand jury may just want to

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30 see him. I don't know. They may not have any questions at all.

MR. KENDALL: We did try to make a very specific offer, including a date that would be consonant with his schedule.

THE COURT: But that's sometime in September. MR. KENDALL: It is. THE COURT: Well, as I said, you see, I don't know the interest of the grand jury, either. But one thing is for sure: The grand jury has apparently attempted, even though you've maintained that because there was no further response to some letter you wrote in April, that, therefore, he could think that maybe they didn't want him any more.

MR. KENDALL: Your Honor, I would like to distinguish, if I could, between concerns. We, obviously, would like to help the grand jury in its endeavors. The Office of Independent Counsel we have our differences with about a number of things. They are set forth in the letter. Those concerns have not been responded to. We are willing to forgo some of those or litigate them in other forums. We really did try, nowever, to get a good faith offer that was specific in terms 3f place, way of taking testimony, issues -- and leaks are one Df the things that we are concerned about. But we believe that -here can be safeguards. This is not an impossible task. And ;ime. And the time is really very critical. But we have tried

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31 to put that all in a very specific proposal for the Independent Counsel and for the Court.

THE COURT: All right. Thank you very much. MR. KENDALL: Thank you, Your Honor. THE COURT: Mr. Bittman, I'll hear from you finally. MR. BITTMAN: Thank you. I'll be brief. Robert Bittman on behalf of the United States.

Your Honor, in all respect, I think saying that we are being unreasonable by issuing a grand jury subpoena with the grand jury's approval is a little -- and that we're not willing to accommodate or even give a little bit with regard to the President's schedule, we are, we have been. I think that that argument would have a lot more merit had there not been six invitations.

We've tried to get his testimony since January. We've tried. Since January 27th, we have tried. We've invited him. And we made clear in all those invitations that we will accommodate the President's schedule. And now, for the President to -- and then after six invitations, you know, we in the grand jury decide to issue a subpoena to the President because that's within our power. You know, we tried to accommodate him, we've tried all means necessary to avoid any constitutional confrontation or something like that, but he declined the invitation. What are we left to do? And we have -- back then, when we extended these invitations, we have a lot

1 of .room to negotiate in terms of when and how and where and

2 that kind of stuff. Well, now we're at the end of the

3 4 5

investigation, or near the end of the investigation, we decide, with the grand jury's approval, to issue a subpoena to the President. We don't have many options any more.

6 A. nd. so for them to come in here and say, "Oh, we want

7 them to be more reasonable," we were reasonable back then. And

8 not going to do it.

9 think it is

they were the ones that said, "NO, we're We're not going to agree to this." so I disingenuous, with all respect.

11 .- 12

13 14 15 16 17

I did notify Mr. Kendall last weekend -- and I might also say, if they were really serious about trying to work something out -- and Mr. Kendall did put forward a very specific date. I agree with that. And that's in his correspondence. But the date simply is not acceptable. That's ;he bottom line. It's unacceptable. We told him it was Inacceptable.

18 19 20 21 22 23 24 25

THE COURT: That's the September date? MR. BITTMAN: That's the September date. That is unacceptable. And we have the power, we, with the grand jury, save the power to compel the President. That's what we've decided to do. We didn't want to do that. That's why we issued the six invitations. But they put us in a box. We had :o do it because they weren't going to agree anyway. Now, we lave a limited opportunity in terms of time.

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2401

I notified Mr. Kendall that if they really wanted to work out a date, an acceptable date with us, that we would be available all weekend. Apparently Mr. Kendall -- I read that Mr. Kendall was not available over the weekend. But we responded within hours of his letter to me, and we Said we 8 re

available to work this out, to work out an acceptable date. They didn't provide us with an acceptable date. It's that simple.

We still are willing to work but we're not going to wait two weeks this along.

out an acceptable date, for it. We have to move

THE COURT: Well, I think Mr. Kendall is asking for a little more than two weeks, isn't he?

MR. BITTMAN: He is, because -- THE COURT: You see, that's why I really had to have you all in here today, because I wanted to be certain of what you meant. You could read Mr. Kendall's motion to maybe suggest that, we 11 , ?$ qe’ll be rea& j to go oii that date, and I

said and you could also read it to mean that you won't be ready to go, "but I'll be ready to tell you where I want to go two weeks from now."

And I certainly have a duty to the President, but I also have a duty to the grand jury. And here, this third branch stands behind the first and the second branches, but, you know, I do have a duty myself.

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5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

2402 34 So, anything else you want to say? 1'11 have to take this matter under advisement, but let me just say, I'm in a better position to take it under advisement, having had you _ come today, than I was just based on the papers alone.

MR. BITTMAN: Nothing else from me. Unnnr ll” II” L .

THE COURT: Anything else from you, Thank you, Your

Mr. Kendall?

MR. KENDALL: Thank you, Your Honor. THE COURT: Okay. Well, thank you very much. Let me just say, what I hope to do is call you first thing in the morning and tell you -- I hope to be able to call you first thing in the morning and tell you to come down and pick up my decision or pick up an order or whatever the case nay be relative to oe able to do it.

today's hearing. Okay? I really hope to And if you haven't heard from me by 11 o'clock -- well, let me just say this. If you haven't heard Erom me by 11 o'clock -- no, that isn't what I want to say.

If you have not received a telephone call from me lefore 11 o'cIock, I will try to do a conference call at

Ll o'clock. That's what I want to say. Okay? Thank you very nuch.

(Proceedings concluded at 5: 20 p. m.)

2403

35 CERTIFICATE OF REPORTER I certify that the foregoing is a correct transcription from the record of proceedings in the above- entitled* matter.

&oh 1

Official Court Re rter

2404

2405

Tab 54

2406

2407

ttuti\ AL INtitAU OF WVESj- IGA- IION Receipt for Property Received/ ReturnedlReleasedlSefzed

Page .- f__ 0f I_

On (date) item( s) listed below were: ,E) Received From

J7 cfj- &I 0 Returned To

lime: t ! 0 Released To Cl Seized .

(Name) m 6% tYI d (Street Address) 1109 GWfl. & .‘ z I w’i k 7%. (City) _ 4. I ”

Received by:

2408

2409

Tab 55

2410

2411

Office of the Independent Counsel

IO01 Pennsylvania Avenue, N. W. Suite 490- North Washington. DC 20004 (202) 514- 8488 Fax (202) 514- 8802

July 31, 1998

HAND DELIVERED

David E. Kendall, Esq. Williams d Connolly 725 Twelfth Street, N. W.

Washington, D. C. 20005 Re: William Jefferson Clinton Dear David:

I telephoned you twice this morning but was unable to reach you. Investigative demands require that President Clinton

this I assure you information will be kept strictly confidential and will

restricted to a handful of persons on a need- to- know basis only. Your prompt response to these requests will be greatly appreciated.

Sincerely, GLGQ. V& Robert J. Bittman Deputy Independent Counsel

2412

Ofice of the Independent Counsel

July 31, 1998 Received this 31st day of July, 1998, one double- enveloped package addressed to David

endall, Williams & Connolly, 725 12th Street, Northwest, Washington, D. C. 2000s

2413

Tab 56

2414

2415

DAVID E. KENDALL (202) 434- 5145

CONFIDENTIAL

LAW OFFICES

WILLIAMS t3 CONNOLLY 725 TWELFTH STREET, N. W. WASHINGTON, D. C. 20005- 5901 EDUVARO I) ENNErTVILLlhUs (, 92o.,~ lj~, PAUL R. CONWcx. LY <19* 2., 97*,

(202) 434- 5000 FAX( 202) 434- 5029

July 31, 1998

Robert J. Bittman, Esq. Deputy Independent Counsel Office of the Independent Counsel 1001 Pennsylvania Avenue, N. W. Suite 490- North .

Washington, D. C. 20004

r. “‘; ;_* : .

‘._ 2 ii

(’ : : _ ‘: ..: .

: :

Dear Bob: Bv Hand I received your July 31 letter which refers to "[ iInvestigative demands." As you must surely be aware, the cases require a heightened standard of probable cause for bodily intrusions. &, e. q., Schmerber v. California, 384 U. S. 757, 769 (1966); Winston v. Lee, 470 U. S. 753, 759 (1985); In re Grand Jurv Proceedinss (Suleski), 816 F. Supp. 1196, 1204- 06 (W- D. Ky. 1196). Since the request you make is addressed to the President of the United States, I believe that also applicable to this request are the considerations -identified in Clinton v: Jones,

U. S. 117 S. Ct. 1636, 1650- 1651 (19971, that mandate a "high res=; that is owed to the office of the Chief Executive

. . [which should] inform the conduct of the entire proceeding." Accordingly, I ask that you inform me of the precise factual basis for your request.

I have another. concern and another request. I will not rehearse the history of grand jury leaks in this investigation or the orders that Chief Judge Johnson has entered. While the OIC has retained outside counsel to appeal portions of the district court orders which afforded us discovery against the OIC and while an administrative stay from the Court of Appeals is now in effect, the OIC has not appealed the underlying findings which caused the Chief Judge to enter her orders. In just the last few days, there have been numerous leaks to the news media of reports about a dress of Ms. Lewinsky's which is allegedly stained in

2416

WILLIAMS b CONNOLLY Robert J. Bittman, Esq. ~u3. y 31, I998 Page 2

some way. as to these latter leaks, I do not at the present time have information sufficient to say who may be guilty of any

improper disclosures, but unfortunately such leaks appear to be a

way of life in this investigation. I fear that, if we provide the sample you have requested, false information of any tests that are conducted will be leaked. In its papers in the leaks litigation, the OIC has often adverted to "false" leaks. The only way we can be protected against such a phenomenon is to be made aware of any test results which are conducted, so we will be in a position to respond to false leaks.

If you believe either of these disclosures would be protected by Rule 6( e), we would be willing to stipulate to a motion to the Court for a Rule -S( e) order allowing the release of information to us, and we would undertake not to disclose it further, except on the terms specified in the order.

I would like to discuss these matters with you further and will give you a call after you have received this letter.

Si ce; k- elyn P- DEK/ bb

&* id E. i

Kendall

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Tab 57

2418

2419

Offke of the Independent Counsel

JO0 J Pennsylvania Avenue, N. W. Suite 490- North Washington. DC 20004 (202) 5 I4- 8688 Far (202) 5 14- 8802

July 31, 1998

HAND DELIVERED

David E. Kendall, Esq. Williams & Connolly

725 Twelfth Street, N. W. Washington, D. C. 20005

Re: William Jefferson Clinton Dear David:

This responds to your letter of today, which was delivered to me at 5: 35 p. m.

I assure you that we have substantial factual and legal predication for our request of the President. We are mindful of the legal requirements of our request, and we are certain that the request is lawful and would be upheld by a reviewing court. We make this request, as we have others, respectful of the dignity of the Office of the President. Because of the President's piedge to cooperate with this investigation and out of respect for the Presidency, we have not issued a subpoena for this sample. We do not wish to litigate this matter, and we wish no embarrassment to the President. Yet, we have substantial predication for our request, and we must do our job.

You also refer to the dissemination of information in the media.\ As confirmed by Messrs. Stein and Cacheris, this ’

Office is not the source -- either directly or indirectly -- of the information. That being said, we are sensitive to your desires, consistent with our abiding aim, to insure complete confidentiality. We have -- we believe -- powerful predication for our request of the President, and that representation, which reflects our considered professional judgement, should suffice. If you disagree, then the prudent and wise course may be to proceed under the aegis of the Chief Judge. We would set forth our predication, which we believe is powerful, before the Chief Judge. This would assure you the independent review of an Article III judge, and thereby further insure that the dignitary interests of the President are scrupulously protected. The Chief Judge would also, under our proposed approach, then be in a position to consider any protective order (or evaluate a motion to quash) that you might see fit to request.

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David E. Kendall, Esq. July 31, 1998 Page two

We are not in a position at this early juncture to agree to a release of information subsequent to further examination; such a release to you might raise serious questions of law, as you recognize. Here again, we could go before Chief Judge Johnson for appropriate direction to protect all relevant interests.

Sincerely, Robert J. Bittman Deputy Independent Counsel

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Tab 58

2422

2423

DAVID E. KENDALL (202) 434- 5145

LAWOFFICES

WILLIAMS8 CONNOLLY

725 TWELFTH STREET, N. W. WASHINGTON, D. C. 20005- 5901

(202) 434- 5000 FAX (202) 434- 5029

August 3, 1998 CONFIDENTIAL WRITTEN PURSUANT TO SECRECY PROVISIONS OF RULE 6( e),

FEDERAL, RULES OF CRIMINAL PROCEDURE GRAND JURY MATERIAL,

Robert J. Bittman, Esq. Deputy Independent Counsel Office of the Independent Counsel 1001 Pennsylvania Avenue, N. W. Suite 490- North Washington, D. C. 20004

BY HAND-- TO BE OPENED BY MR. BITTMAN ONLY Dear Bob:

This letter is written after receiving your second letter dated July 31, 1998, and after our telephone conversation this morning. We agree to provide the blood specimen you have requested (today, if possible), pursuant to the following conditions:

(1) This test, any analysis, our written correspondence, and our oral communications on this issue are all to be treated as highly confidential, subject to the full protections of Rule 6( e), Federal Rules of Criminal Procedure. Both the OIC and we will take the utmost precautions to preserve the confidentiality

of this matter.

(2) The sample will be drawn by the White House physician, Dr. Connie Mariano, at the White House, in the presence of two representatives of the OIC, to the OIC. under medical procedures acceptable

The sample will be immediately furnished to the OIC. (3) You will execute an affidavit today setting forth your predication evidence for requesting this test, and you will preserve this affidavit in a secure place. You will set forth in the affidavit the evidence you would have presented to Chief

Judge Johnson, as represented in your second letter of July 31, 1998.

2424

WILLIAMS 6 CONNOLLY

Robert J. Bittman, Esq. August 3, 1998 Page- 2

(4) You will instruct the laboratory that does any analysis related to the specimen we furnish to preserve enough of the item being tested (e. s., any dress of Ms. Lewinsky's) to make possible a later, outside, comparative test of the same type, if

appropriate. I will look forward to receiving a written response to this letter, and we will speak later in the day concerning logistics.

Sincerely, DEK/ bb

2425

Tab 59

2426

2427

Offwe of the Independent Counsel IOOf Pennryivaniu Avenue K. W. Suite 490~ North

Warhingfon, fX 20004 (202) 3 14- 8688 Far (202) 514- 8802

August 3, 1998 RAND DELIVERED David E. Kendall, Esq. Williams h Connolly 725 Twelfth Street, N. W. Washington, D. C. 20005

Re: William Jefferson Cl& ton Dear David:

This responds to your letter of today regarding your agreement to permit a blood sample to be taken from the President this evening at 1O: OO p- m.

(1) We will treat this test, any analysis, our written correspondence, and our oral communications on this matter as highly confidential, subject to the full protections of Rule 6( e).

(2) We agree to permit Dr. Mariano to draw the sample from the President in the presence of two representatives from this Office. Dr. Mariano should use a "purple- top" tube, which she will then turn over immediately to the renresentatives from this Office. I, Robert J

(3) I agree to execute a declaration setting forth the predication for requesting this test. This declaration will then be preserved in a secure place at the OIC.

(4) I have requested that the FBI Laboratory preserve as much of the remaining specimen as possible so as to make possible a later, comparative test, if appropriate.

Sincerely, Robert J. Bittman Deputy Independent Counsel

_, 2428

2430

7- 1 (Rev; 2- 21- 91)

2431 FEDERAL BUREAU OF INVESTIGATION

WASHINGTON, D. C. 20535

Date: August 3, 1998

To: Mr. Kenneth W. Starr Office of the Independent Counsel 1001 Pennsylvania Avenue, N. W. Suite 490- North FBIFiteNo. 29D- OIC- LR- 35063 Washington, D. C. 20004

Lab No. 980730002 S BO

Refenmx: Communication dated July 30, 1998 Your No. 29D- OIC- LR- 35063 Rc: MOZARK;

MC 106

Specimens received: July 30, 1998 Specimens: 43243 Navy blue dress ITEMS NOT EXAMINED NE1 Hanger NE2 Plastic bag

This report contains the results of the requested serological examinations.

Specimen 43243 and samples removed from specimen 43243 are being preserved for possible future DNA analysis. In order to conduct meaningful DNA analysis, known blood samples must be submitted from the victim, suspect or other individuals believed to have contributed body fluids to specimen 43243. Each known blood sample should be collected in one (1) lavender- top blood

Page 1 (over)

2432

vial containing the preservative EDTA, and stored in a refrigerator until submission to the FBI Laboratory.

The evidence and the samples removed from the evidence will be retained in the FBI Laboratory until they are retrieved by a representative from your office.

Page 2 980730002 S BO

2433

ExamilmNanw unit FBI FGk No.:

FEDERAL BUREAU OF INVESTIGATION WASHINGTON, D. C. 20535

Report of Examination

DNA Analysis 1 29D- OIC- LR- 35063

Dare 08/ 03/ 98

wwt No.: 202- 324- 4409 I& No.: 980730002 S BO

Rfzsults of FxiqimioIls:

Semen was identified on specimen 43243. No other serological examinations were conducted.

DNAUl - Page 1 of 1

2434

2435

Tab 61

2436

2437 FD- 302 (Rev. 3- 10- 82)

FEDERAL BUREAU OF DWESTIGATION

rnrc 0fmO. hpi00 Aucrust 3.1998

m On this date, Supervisory Special Agent (SSA) _ was present in the Map Room of the White House, Washington D. C.

with Robert J. Bittman, Deputy Independent Counsel, Eleanor Maricino, M. D., White .House Physician, David Kendall, Attorney and William Jefferson Clinton, President. At approximately 1O: lO pm, SSA observed Dr. Maricino draw blood by venous puncture from Presi II Clinton's right arm, filling one purple top tube (approximately 4ml). She capped the tube and transferred it to SSA -who labeled the tube with the name "William Clinton", the date and SSA _ initials. The tube was placed in a clean disposable test tube and sealed with evidence tape. SSA m promptly returned to the FBI Laboratory, Washington D. C. where at 10: 30, the tube of blood was delivered to DNA Analysis Unit I technician, -_ a, for further processing according to standard practice. This sample will be maintained in the custody of the FBI Laboratory for the duration of the testing process.

Investigatinn on August 3, 1998 Map Room, White House, ~ile# 29D- OIC- LR- 35063

Y SSA Date dictaed Auqust 3,1998

This document contains neither rccotnmcndatiotts nor conclusions of the FBI. It is tic property of the FBI and is loaned to your agency; it and its contents arc not to be distributed outside your agency.

2438

I 2439

Tab 62

2440

2441

@loo2

August 3, 1998 Honorable Kenneth Starr independultcounsel ofike of the krdepmdeatcounsc~ 1001 Pcnnsylvaaia Avmuc, NW was~, Dc2ooa4

Dear Mr. Starr:

In your July 22,1998, Iettcr, you a6ked whether the sccfet SeWice would, at this time, make witncs6cs &vailable to your OffiCx con& tent with the past pmctice of ptoffcrs, illtuvicws, . and depositions. My understanbng isthattbisrcquurtWiUbethesubjecttodayofamccting

between you end Director Merlett3, Which will be attcmkd by Jonathan Schm and Gary CIxGndler from the Depaztmcnt of Justice. In adv- of that meeting, however, I wouid ofikr the following fhoughts on behalfof the Department and the Se+ xct Service regarding a number of

statements in your lettq in order to provide a more complete end accurate b& drop for this afkmoon’s meeting.

Your lcttcr suggests that you undertook the proffer- in~ curdcposi~ process at “significant cost” to your investigation. I do not believe this is an accurak reflection of the facts. In the face of our decision several months ago to assert a protective fitnction pniviftge, the Department and your office sought to find a mutuaiiy acqtable way for your of& e to obtain information from Snnt Se& x personnel that did not fti within this asscrtcd prklcgc. Your office initialiy declined our suggestion to do intervicw5 in advance of dcposition6. The

deposition- only f& mat pmvcd to bc problematic, however, due to its formal@ and due to confbsion over the scope of the privilege (admittedly Causea, in per& by the Department’s periodic x- e- evaluation and nsnowing of its scope)., As a result, we renewed our suggestion #at your of2icc first interview Secret Service personnel. Your office ultimately agreed to try tht interview process, when preceded by proffers of non- privikgcd information by Departmcnt attomcys, so that your attorneys would have an overview of the ofIke& iafonnation before interviews bcgau

The profk- interview- dcpositian fonnst clearly proved tkt be a more mutually beneficial (not to mention much less contentious) method by which your office obtained non- privileged inform& ion from Sccnzt Sarvicz personnel, a6 your attorneys corLxnned scvcral time6 to us.

Through proffers and interviews, your office much more quickly detcnninad the limited number

2442

Honorable Kenneth Starr

Page 2 of officers fkorn whom you needed to obtain sworn deposition testimony. The subsequent depositions then proceeded much more smootb3y, While I am not privy to the details of your investigation, it would appear that your investigation was aided by some of the non- priviieged information that your attorneys received. Under theac cw, the assertion that ahering the normal procedures by which Secret Service witnesses were questioned somehow hindered your investigation appears inconsistent with the facts as we know them.

I believe that some in your office have undervalued the vexy teal and nc@ ive impact that tbc broad summoning of protective personnel and the broad scope of the questioning has had on the Secret Service. At least 30 ofIks were in& viewed, some of them two or even three times, and msny officers who apply lacked fust- hand knowledge relevant to your inquiry wcm questioned about mere rumors they may have heard. Regardless of our record in oonvincing kdexa. I judges to recognize a new protective fimction privilege, there is no question that each and every one of the current secret Service employees whom your o&!- e has questioned fais that he or she has violated a code of ccmf! demiality and trust. As a result, the Secret Service sincerely believes that its morale and its ability to do its mission have been adversely affected

Finally, pkase aIIow me to reiterate that the Departments of Justice and Treasury reached the very difk. dt decision to se& judicial recognition of 8 protective function privilege for entkcly non- partisan purposes, and only afkr an exhaustive review of the complex legal and policy issues at stake. As prosecutors, the Attorney Gcncral and I have been extremely mindful of the effects that our decision to seek the privilege might have had on your invest& ation (not to mention Mure investigations by Depar8ment attorney~)~ Nonetheless, we reached the difficult determination that the potential risk to the life of this and future presidents occasioned by the compelled testimony of Secret Service personnel requimd us to interpose the asserted protective function privilege with respect to information fhlhng within its scope. We trust that you continue to have confidence in the bona fide% of this decision.

Eric H. Holder, Jr. Deputy Attorney General

2443

06/ 03/ 98 &SON 14: 51 FAX

u- s+ ~PrhLJlt of Justice

office of the: Dqm- ty. Aaomcy GcrmaI

DATE : August 3, 1998

TO:

Office of the Independent COUnS~ i

FROM : Eric H. Holder, Jr. Deputy Attorney General

FACSIXIWg mom #: (2021 514- 8802

OFFICE

PzONZ I): 202- 514- 2101

FACSIMIliE

PBom f: 202- 514- 0467

s22Y. m mf&?& s 2. PAGES

2444

2445

Tab 63

2446

2447

OFFICE OF INDEPEND c I- IT COUNSEL DONALD C. SMALTZ

In re Secretary ofAgriculture Espy PO. Box 26356 103 Oronoco Street, Suite 200 Alexandria, VA 22313 (703) 706- 0010 (FAX) 706- 0076

August 6, 1998 The Honorable Janet Reno Attorney General of the United States United States Department of Justice 1 Oti Street and Pennsylvania Avenue, N. W. Washington, D. C. 20530 _ -

Dear General Reno: On December 5, 1997, I wrote to you concerning a series of statements to the press, apparently emanating from the Department of Justice, that disparaged certain independent counsel offices, the independent counsels as individuals, and the _ Special Division of the U. S. Court of Appeals for the D. C. Circuit that appoints independent counsels. A copy of my letter is attached. You responded by letter on January 20,1998, deploring the alleged comments. You further stated that the matter had been referred to the Department’s Office of Professional Responsibility for “whatever action it deems appropriate.” A copy of your letter is attached.

I have now received a letter dated July 15, 1998, from Richard Rogers of your Office of Professional Responsibility, reporting the results of his investiga- tion. A copy of this letter is also attached. I must say that I find this letter to be deeply disturbing, first in what it says, but even more so in what it does not say.

Mr. Rogers’ legalistic response reads more as a brief defending departmental action on narrow legal grounds than as a serious attempt to look at the problem. He concludes that, technically, the press statements attributed to departmental officials did not violate Rule 3.6 of the ABA’s Model Rules of Professional Responsibility because, in his view, they were too general to influence a pending case and, under his interpretation, the rule governs only the behavior of attorneys who have directly participated in the investigation.

2448 The Honorable Janet Reno Attorney General of the United States August 6, 1998 Page 2

These distinctions- are, at best, dubious. While the statements might not have disparaged any specific witness, item of evidence, or prosecution theory, they did directly disparage the prosecutor in high- profile pending cases (at least one before the jury as the remarks became public), and thus could easily have had an impact on the outcome. Moreover, while it is questionable that Rule 3.6 would condone one lawyer for the United States disparaging the work of another lawyer also appearing on behalf of the United States, the fact is that the Blackley matter, which was in trial when these remarks surfaced, was originally investigated by the Department.

My December 5 letter also pointed out that some of the statements attributed to departmental officials, that disparaged Judge Sentelle and the Special Division, might be in violation of ABA Model Rule 8.2, forbidding false statements concerning the qualifications or integrity of a judge. Mr. Rogers does not even bother to comment on this point.

However, the truly disturbing aspect of Mr. Rogers’ letter is what he does not say. He does not pretend to have even considered the issues raised in my letter beyond searching for technical grounds that would take them outside of the ABA Model Rules. Rather, he eschews all further consideration of the problem: “Because Rule 3.6 is inapplicable in this case and no other applicable rule appears to prohibit the reported comments, we must conclude that no further inquiry into them by this Office is justified.”

Your letter of January 20 stated that “[ i] f these alleged comments were made toahe press, I, like you, deplore them and find them wholly inappropriate.” Either Mr. Rogers did not read your letter, or he is getting conflicting orders Ii- om elsewhere. Mr. Rogers takes the position that he need make no inquiry at all regarding the numerous press statements that we brought to your attention so long as he can construct a defense for them under the ethical rules. If the comments were, as both you and I have concluded, deplorable and inappropriate, then the Department should not consider them unworthy of inquiry simply because they can be threaded through a technical reading of the ABA Rules

2449

The Honorable Janet Reno Attorney General of the United States August 6, 1998 Page 3

Apart from the ABA rules, these comments, in my view, violate both the letter and the spirit of Departmental policies and regulations dealing with the media, as contained in Chapter 20, “Publicity and Media Regulations,” Ethics and Professional Responsibility, Department of Justice, November 1995. The issue of the impropriety of the regulations is a question that should not be ignored by the Office of Professional Responsibility and needs, I respectfully suggest, to be addressed.

Because I still do not have a response, I must ask again, as I did in my December 5 letter, that you direct the officials who work for you to temper their public remarks, and to present any concerns or criticisms to the independent counsel offices so that problems can be addressed directly. The clear message of Mr. Rogers’ letter is that “deplorable” and “inappropriate” statements by departmental officers and _ employees are condoned, if not encouraged, so long as they are technically defensible under the ethical rules. I hope that this message is not an accurate one but, if it is, I would appreciate being so informed. I also request whether, in the Department’s view, the referenced statements fall within or without the proscriptions of Chapter 20, referenced above.

Sincer ly, I[& ,&& F -

Donald C. Smaltz ’

Independent Counsel Enclosunes Copies: Richard M. Rogers, Deputy Counsel (w/ encl.)

The Honorable Kenneth W. Starr (w/ encl.) The Honorable David M. Barrett (w/ encl.) The Honorable Carol Elder Bruce (w/ encl.) The Honorable Ralph I. Lancaster, Jr. (w/ encl.)

h:\ data\ ckagay\ rcnolc- I

2450

2451

Tab 64

7- 1 (Rev. 2- 21- 91) To: Reference: Your No.

2453

LAnoaAToRY

FEDERAL BUREAU OF INVESTIGATION WASHINGTON, D. C. 20535

Date: August 6, 1998 Mr. Kenneth W. Starr Office of the Independent Counsel 1001 Pennsylvania Avenue, N- W. Suite 490- North FBIFileNo. 29D- OIC- LR- 35063 Washington, D. C. 20004

Lab No. 980730002 S BO 980803100 S BO

Communication dated July 30, 1998 and evidence submitted August 3, 1998

29D- OIC- LR- 35063

Re: MOZARK;

MC 106

Specimens received: July 30, 1998 and August 3, 1998 Specimens: Received July 30, 1998 (under cover of FBI Laboratory number 980730002 S BO):

Q3243 Navy blue dress ITEMS NOT EXAMINED NE1 Hanger

NE2 Plastic bag Specimen received August 3, 1998 (under cover of FBI Laboratory number 980803100 S BO):

K39 Liquid blood sample from WILLIAM CLINTON This report supplements an FBI Laboratory report dated August 3, 1998 and contains the results of additional serological and DNA- PCR examinations. DNA- RFLP examinat, ions are continuing and you will be advised of the results of those examinations and the disposition of the evidence in a separate report.

This Report Is Furnished For Offkial Use Only

2454

. 7- h 47- 16- 96)

Exam& r Nanu:

unit FBI Fik No.:

FEDERAL BUREAU OF INVESTIGATION WASHINGTON, D. C. 20535

Report of Examination

DNA Analysis 1

29D- OIC- LR- 35063

DMC: 08/ 06/ 98

Phone No.: 202- 324- 4409

Lab No.: 980730002 S BO

980803100 S BO

. Results of Examinations:

Specimen 43243 was examined for the presence of blood; however, none was found.

Polymarker (PM), DQAl, and DlS80 types as listed below were detected for the following specimens:

SPECIMEN LDLR GYPA HBGG D7S8 & WA1 DlS80 43243- l BB BB AB AB AC 1.1, 1.2 24, 24 43243- 2 BB BB AB AB AC 1.1, 1.2 24, 24 K39 BB BB AB AB AC 1.1, 1.2 24, 24

Based on the PM, DQAl, and DlS80 typing results, the source of specimen K39 is included as a potential contributor of the DNA obtained from specimens 43243- l and 43243- 2 (two semen stains removed from specimen 43243). The probability of selecting an unrelated individual at random having the same PM, DQAl and DlS80 types as detected in the questioned specimens is approximately 1 in 390,000 in the Black population, 1 in 43,000 in the Caucasian population, 1 in 39,000 in the Southeastern Hispanic population, and 1 in 220,000 in the# Southwestern Hispanic population.

Based on the amelogenin typing results, male DNA was detected in the DNA obtained from specimens 43243- 1, Q3243- 2 and K39.

DNAUl - Page 1 of 1 _._

2455

Tab 65

2456

2457

-EWS - 8/ 7/ 98 WATIMES Al

Page 1

Friday, August 7, 1998

Richardson didn't have post to offer Evidence doesn't support his statments on Lewinsky Bill Sammon THE WASHINGTON TIMES

U. N. Ambassador Bill Richardson, contrary to what he told Congress last month, did not have an opening on his staff when he offered to hire Monica Lewinsky last October, according to informed sources and documents obtained by The Washington Times.

Mr. Richardson, who was recently confirmed as President Clinton's new energy secretary, planned to create a new position to accommodate Miss Lewinsky's desire for employment in New York City, said sources at the United Nations, the State Department and on Capitol Hill. He panicked when the scandal broke in January and scrambled to find a slot that he could claim had existed long before he interviewed Miss I. ewinsky, the sources said.

-Despite Mr. Richardson's repeated, sworn assertions, he did not ate the position until after independent counsel Kenneth W. Starr served him with a subpoena demanding all documents relating to the job offer. Mr. Starr is trying to determine whether the offer was aimed at distancing Miss Lewinsky and keeping her quiet about her relationship with Mr. Clinton.

"I've heard all this speculation before," said Mr. Richardson's chief of staff, Rebecca Cooper. "Luckily, what allows me to go to sleep at night is knowing that none of this is true."

Mr. Richardson did not return telephone calls, but during his confirmation hearing on July 22, he told the Senate panel that the job he offered to Miss Lewinsky was a low- level, $30,000 position in

New York. After she turned it down, the job was given to U. N. employee Paul Aronsohn, a senior staffer who has handled such high- level issues as nuclear disarmament and the U. N. arrears controversy.

Mr. Aronsohn, who has worked in the U. N. ' s political section for four years, is paid substantially more than $30,000 and was transferred to Washington weeks before Mr. Richardson's testimony, Miss Cooper said.

Explained his spokesman, Calvin Mitchell: "The ambassador is not a personnel officer. He is not to sit in front of the Senate and answer questions off people's personnel files. And he described, in I- mind, what the job was to him and how it was perceived and how it .._ going to function."

,onetheless, the discrepancies raise serious questions about the veracity of sworn testimony by Mr. Richardson, who until now has been a peripheral figure in the Lewinsky scandal. They also suggest that Mr. Richardson took steps to conceal special treatment he afforded a

2458 Page 2

"man who yesterday b, egan telling a grand jury about her relationship h the president.

AN 'EXISTING SLOT'? Monica Lewinsky was not a household name when Mr. Richardson was asked by White House Deputy Chief of Staff John Podesta to interview "this person" in October, the ambassador testified.

"He did not even know her name when he asked me to interview her," Mr. Richardson testified. "I did not know her name."

The request originated with Betty Currie, the president's personal secretary, who relayed it to Mr. Richardson through his friend, Mr. Podesta, according to testimony by Mr. Richardson before the Energy and Natural Resources Committee.

But Mr. Richardson agreed to interview the former White House intern in his Watergate apartment at 7: 30 a. m. He left in the middle of the interview, leaving Miss Cooper and an assistant to finish up, so he could go to the White House for a meeting.

Within a week, Mr. Richardson instructed his staff to offer the job to Miss Lewinsky. After taking declined. some time to think about it, she

__ .n offering Miss Lewinsky a job, Mr. Richardson did not follow -ing procedures normally used at the U. S. Mission at the United ions, which include advertising a position and recruiting several qualified candidates. Within hours after the scandal broke on Jan. 21, reporters demanded to know whether such procedures had been followed.

Miss Cooper and Mr. *Mitchell responded by publicly stating that if Miss Lewinsky had accepted the job offer, she would have been a "schedule- C" employee, or political appointee. On Jan. 26, five days after the scandal broke, Mr. Richardson's office issued an "administrative instruction" to all employees that said "the usual procedures" for hiring and reassigning "do not apply" to political appointees.

Mr. Mitchell said this week he does not know whether the instruction represented a departure from previous policy.

"Everyone from the highest official to the lowest mail clerk instantly knew this was about Monica Lewinsky," said one source close to the case. "I mean, this just came out of nowhere. It was obvious that Richardson's people were trying to retroactively cover their tracks."

On Feb. 2, a team of inspectors from the State Department's Office of Inspector General (OIG) showed up at Mr. Richardson's New York offices to conduct a routine audit of management practices. They

sdiately told U. N. employees that the mission's political branch .--. significantly understaffed, especially in comparison to the

rstaffed press office, according to OIG spokeswoman Tamara

_ ,lkner. Nonetheless, while the inspectors were still conducting their audit at the New York offices in February, Mr. Aronsohn was

2459 Page 3

explicably transferred from the political section to the press tion, Miss Faulkner said.

"OIG was surprised during the inspection when an officer was transferred out of the overworked political section and assigned to .

. . outreach programs" in the press office, the team of inspectors wrote in a report that was issued in May. "This was done even though the press and public affairs section already has 12 employees, several of whom specialize in public outreach.

"The move does not make sense organizationally, because it created a duplication in outreach responsibilities. There is also the question of the impact of the move on the already overstretched political section."

During his testimony before the Senate committee, Mr. Richardson said there was "no relationship whatsoever" between creation of a public outreach job in the U. N. 's press section and his decision to offer that job to Miss Lewinsky.

"It was an existing slot," Mr. Richardson testified. "It was not created for anybody."

He added: "This position was created way before I established my tenure at the United Nations, so it was with prior ambassadors to the United Nations. It was an existing slot."

en. Frank H. Murkowski, chairman of the committee, said: "Who, if -. one, now holds that particular position?"

"The position is held by Paul Aronsohn," Mr. Richardson said. "And he was offered the position after Ms. Lewinsky? ' the Alaska Republican said.

"Yes," Mr. Richardson said. "He was offered the position in January. And he assumed the position. '

Mr. Richardson did not explain why the job was not offered to Mr. Aronsohn until three months after it was offered to Miss Lewinsky. Nor did he attempt to reconcile his assertion that the slot existed before October with the OIG's assertion that the slot was not transferred from the political office to the press office until February.

'A FUNGIBLE SLOT' Miss Cooper and Mr. Mitchell gave complex, convoluted explanations of the Lewinsky job offer, often contradicting themselves and each other. For example, at one point during a lengthy interview, Miss Cooper said: 'The job that I wanted to fill was one that never existed." At other times she insisted Mr. Richardson was correct when he testified the job had previously existed.

-It's a fungible slot, ' Miss Cooper said. 'You can trace a slot, __ you can't say this person held that particular position because

position has evolved. ' Nonetheless, Miss Cooper offered the following explanation: Miss Lewinsky was actually not offered the slot now held by Mr.

2460

Page 4

'i'onsohn, Miss Cooper said. She was actually offered a separate slot the media wing that had been occupied by a secretary named Regina ,_ lego, who departed around the time Miss Lewinsky was interviewed.

Miss Cooper said she split Miss Griego's job into two new slots - one to handle clerical duties, which included answering phones, and another to handle "public outreach" duties.

Miss Griego's clerical duties were taken over by a "contract secretary" who was moved from New York to Washington, Miss Cooper said. The slot for Miss Griego's "public outreach" duties remains unfilled to this day, Miss Cooper said.

When Mr. Aronsohn was transferred from the political section to the press section in February, his slot was also transferred, Miss Cooper said. Thus, he was able to take over Miss Griego's public outreach duties - which had been offered to Miss Lewinsky - without actually filling the slot that had been designated for that purpose.

In essence, according to Miss Cooper, the position that Miss Griego vacated was the same position that Mr. Aronsohn filled - and the same one that was offered to Miss Lewinsky. Still, she acknowledged the job descriptions for Miss Griego and Mr. Aronsohn, which she refused to disclose, are as dissimilar as "apples and oranges."

Uked why this was not explained by Mr. Richardson to the Senate mittee, Miss Cooper said: "It's such a nuance. What the senators -e focused on - I mean, I gotta tell you . . . you're kind of

getting into things that are really splitting hairs." Government personnel experts scoffed at the notion that Miss Griego - who had enough clerical duties to keep the secretary who replaced her occupied on a full- time basis - was replaced by the far- more- experienced Mr. Aronsohn.

"It was a low- level position that paid around $30,000," said Mr. Richardson, who added later in the hearing: "Again, it was a low- level position."

Still later, he emphasized: "This was a position that was not a very high- level position."

Miss Cooper said "Paul Aronsohn makes much more" than what Miss Lewinsky was offered, and was recently given a significant pay raise. She also said he gets other compensation that Mr. Richardson was not able to offer Miss Lewinsky, but refused to be more specific.

Mr. Mitchell, while acknowledging Mr. Aronsohn's salary is a matter of public record, refused to disclose it to The Washington

Times. Mr. Aronsohn also refused to tell a reporter how much he makes.

?aul Aronsohn's now feeling a little bit down because he feels l_-. e everyone now perceives him as the guy who got the job Monica

ned down," Miss Cooper said. "Well, Paul has far more experience .n that and he shouldn't view himself that way. People who held this job previously shouldn't regard themselves as the people who held the Monica slot. The job has evolved."

2461

-4 NEW YORK SLOT during his hearing, Mr. Richardson took pains to emphasize the importance of keeping the job in question in New York, even after it was shifted from the political section to the press section. The job had been considered by Miss Lewinsky primarily because she wanted to move from Washington to New York.

Mr. Richardson went so far as to contradict Mr. Murkowski when the senator suggested the ambassador had "transferred an employee out of the political section in New York to assist'your chief of staff in

Washington, D. C. with outreach programs. Is this the case?" "That is not correct," Mr. Richardson said. "An employee was taken out of the political section in New York - this was a political appointee - and placed under the supervision of my chief of staff in New York. So the position was moved to a New York position for purposes of outreach.

"The purpose of this position was to build constituency groups and business support for our efforts. But the position was in New York. The position was held - is held by an individual by the name of Paul Aronsohn, who is a very good employee who is doing the work."

Later in the hearing, Mr. Richardson said his desire for a New York- based outreach employee predated his meeting with Miss Lewinsky.

'We wanted it way before we even thought of her," Mr. Richardson d. "Move it to New York, because that's where most of the iness and constituency groups are. And we stand behind our aecision - we filled the position."

But according to Miss Cooper, Mr. Richardson had transferred Mr. Aronsohn from New York to Washington in early July. She said the ambassador would have explained this to the senators "had they followed up on it. It's really splitting hairs at this point. I mean, I think I would have been annoyed if I were a committee member and Ambassador Richardson digressed into: 'Well, right now he's in Washington because he didn't want to sign a year lease [in New York] and his wife is looking to move here." '

She added: "The job description you can do from just about anywhere, as long as you have instant lines of communication."

JOBS FOR SILENCE? Mr. Richardson's re- emergence in the Lewinsky scandal refocuses attention on one of the central aspects of the case - whether Mr. Clinton and his associates tried to buy her silence through the promise of jobs. After turning down Mr. Richardson's offer, Miss Lewinsky was offered a job at Revlon in New York, thanks to the intercession of presidential friend Vernon E. Jordan Jr., who is on Revlon's board of directors.

-- lthough Miss Lewinsky was interviewed for a job in the White se press office in May 1977, me oriented toward New York. most efforts at finding her a job

According to Lucianne Goldberg, who has listened to tapes of Miss Lewinsky talking with mutual friend Linda R. Tripp, the former White House intern was under the impression that Mr. Clinton wanted her in New York, not Washington,

2462

as to be farther away from any investigation of their ationsiiip.

Summing up the controversy over Miss Lewinsky's job offer at the U. N., Miss Cooper said: "All the allegations that people try to suggest, for example, that we created the job just for Monica, that doesn't hold up. Because regardless of Monica and prior to me ever knowing that Monica Lewinsky was ever going to ever be anyone in the newspaper, I continued to have that need and I filled it."

TABULAR OR GRAPHIC MATERIAL SET FORTH IN THIS DOCUMENT IS NOT DISPLAYABLE Photos (A& B, color), A) Private entrance: Monica Lewinsky prepares to enter the courthouse with reporters kept at a distance.; B) U. N. Ambassador Bill Richardson; C) U. N. Ambassador Bill Richardson testifies last month at his Senate confirmation hearings for the energy secretary post., A) By Karen Ballard/ The Washington Times; B) NO CREDIT; C) By Kenneth Lambert/ The Washington Times

---- INDEX REFERENCES ---- EDITION: 2 Word Count: 2315 E/ 7/ 98 WATIMES Al END OF DOCUMENT

Copr. (C) West 1998 No Claim to Orig. U. S. Govt. Works

2463

2464

2465

stakeouts. Questid h& by a

Mmdlylawyer~- so5ce.. then bytheproaeaaors,~ tpDred~

fourandab& hours. Bytbenextmomiq, thetwosidesbadadaal.

Stan% teambadsomeem3levmgeto makesureLe+ L+ waswillingtotelltba whole huth. Some& last winter, Lewin- skyhadgiventhedresstohmnotber,~ ciaLewi! i. forspfelreeping. TlutlImdeLew- isapossibletargetofStan’sproba, am& ty tbatwasbmgbtbometohwhensbewas summonedbaforethegrandjurylast Fe&

q- andcollapsedunderqae&& g. un derlastweek’sdeal, I.. ewisisalsoimmune frompluwmtion.

The bard- liners on Stan3 tmm bad bembEsitanttoofferpmmisesofimmwli- ty to Lewimky without very specilic promises of testimony in rehm. They felt badlyb4medbyfomlerasswate general Webster Hubbell. who s tclgivetestimolIyiatheWbitewnterimns- tigationinrehmti3rsta.+ shelpinsecm ing a lighter sentence after Hubbell plead-

edgUilt)- tOOk- dilhghiSLaWCli~ t5iIl

1f# 4.= T’bepmemtombelievetbatHubbell basically pulled a bait- and- r& sing tosaymucbofanythiugoncebehada deal. Stan’s team was determined not to make the same mistake with Lewimky.

In addition to the dress. twinsky

tlmledovatapesofseveralvoice- lMil messagesplkgecnyleftbgclintoeTbe pI& ddSddidUOtWrmreBlaqt suggestive-- Hey. it’s me; he l- qmidy

bisvoia3onan dange. rousaretbegit3sthatImvi+ tamed over to the President’s seaamy

Intlxtape. rewrdiqofaammsat& bctwamLewiprlryaudTripplastDecalr berthatN RvrwEKWaspermittedtohPr, Lew& kywasaagertogetxidofanyia& n- inating pmsents. She referred to an 05cia. l WbiteHousephotogqhandwoniadthat theimaip& nfmmClintonwassopemm- altbatlawyemforJoneswould~ useitag& ut ber. SbetoldTCppthatshebadtriedtc. call Betty curlie. the president’s sem& uy. to askforacleancopyofthepichrnsotbatshe might have ooe to give Jones’s lawyers. But wtbetape. shemmplainsthatCmiewas Lmavajlsble. Tbercmay& beanotherp~ to of interest to the pxmecators. According to coldbmg. Iminsky was photographed standing beside the president in the Oval

lftbe~ s& incmthedresshaasout tobetlleprerident’s-( thelabtests

maytaJcedwaLs), clintcQkasmim-

mecliDtepUjUTypl& ll% I.& Jnnlrnyhe d& XluMierosthiDbiSJmS~ thathehadewrhad’scmaltAtims” wltb Lewinslry. LylDgabouta%? Xllal& tiUAip inadqo& ioniPacivilcmaynotbepm ceivedasa reriousoffellse. LyingbefolEtlE grandjmyinaaimiual& es@ timis mongrave. Itwmldsumlyb~ anindicuble offaueinammalaiminalpmbe. Lessar tainiswbetberitisaniugmdAle, offense illCODgEss. WhiChWill+ X% blySem~ Clinton’sjudgeandjury.

TbeultimwfawobStsrr’ScaSeismt &ZS. bUt~ of@ tiCe. UndertbG imrmmitgdsnlVA&? dontbChVUllSUrr and ws lawyam desaaxl to Nmmnmbyaimoarledgeablesoume, Lewin& vwiIlt~ thatsheandtbepraai- dmtd& ussed- storiesdesignedto kaaptbeirallegedmlatiomhipprivate. Lewimky qmtedly will say that at a meelingattheWbiteIiouseinlateDecem- kr. she told the president her wmies abouttbembpocmdgiftr, whidl~ abroochandabookofpoetry. Tbepresi- dmtdidnotdimtlytellhertolie, sbesays. Rather. he spoke hypothetically. Ifyou don’t have the gifts, be allegedly said. you can’ttumthemmm. Su& aveiledmgges- tion would hardly be the kind of evidence a

Regardless of what happens in the courts or Congress, 47% think the president owes the country an explanation of the Monica matter; 49% say he doesn’t

!a NEWSWEEK *“ GUST LO. 1998

Tab 67

2468

2469

Offke of the Independent Counsel 1001 Penmyiwnia Avenue. N. It! Satire 49~ North Washington. Q. C. 20004 (202) 514- 8688 Far 002) 5 14- 8802

August 11, 1998 The Honorable Eric H. Holder, Jr. Deputy Attorney General of the United States United States Department of Justice 10th St. & Constitution Ave., NW Washington, D. C. 20530 I

Dear Deputy Attorney General Holder: Rule 6( e) of the Federal Rules of Criminal Procedure binds all attorneys for the government, including those employed by the Department of Justice who are privy to information regarding "matters occurring before the grand jury." And, as Chief Judge Johnson has recently written, Rule 6( e) protects against the disclosure not merely of the actual testimony of grand jury witnesses before the grand jury but also of the substance of their testimony as conveyed to government attorneys and agents in anticipation of their grand jury appearance.

The enclosed article from Newsweek magazine recounts in detail what Officers Muskett and Byrne told "Secret Service and Justice Department lawyers." The article identifies its source as these "government lawyers" and makes out a potential & facie case that attorneys for the Department of Justice (and possibly Secret Service) involved in the litigation have violated Rule 6( e). Please advise me at your earliest convenience of the steps you are taking to identify the source of these disclosures and prevent future violations of Rule 6( e) so that 1. may take appropriate action.

Kenneth W. Starr Independent Counsel

Enclosure

2470

Monica On The 8

2471

NATIONAL AFFAIRS

to the grand jury, the how to fight back- in part,

former intern’s credibility.

DANIEL -MAN,

KAREN BRESLAU ANTI MrcwL ISIKOFF

AVID KENDALL DI. DttT WASTE

tim. WhWltlE- bmLchtS hstmwththatM~~ D . skyhsdBdlyunack~~ u-

Bilyde8lwitllKaasedlsbur, & &. ggjggy&_ jh&~ itudghgfu~ alMnnrmedDnvid Bhss, whosaidhehdmtoryahout~ skytlmtKendanmight~ toiwar. xmdallqulckly~ himMrthuddD#

BliU~&? lldillgthc% p& CQla’~ lial’outofthebhe.‘ xendau6dbralup WithapboncMUtOBl&, haViOg8sOIiCi- uwmnosge-~~ Play+ pD; NB- onhisamwaing - thiukit’silnpoml1tbatwegettDgether ~andvumgm~~ x decide bow to p= ed”

WbatdidBlissbaveonImiwkytbat wassotlultabzingtothcpnsident’s lawycr7Bliss, admma- depmmeatabop foremanatLewisbClarkCoIlege. told KcndalltbatwbmLewi& wprazl- year- old student tbens in 1995, she had folgedaktterinbis- onschoolsta- tiottety. hpparmly Lmvimky was tlying tobeJpoutAndyBleila. nmm+ eddxama coacbwitbwbomsbewasau~ baving ~aft% BBleil~ wnSoUtofworLaUdUD- broilediuacustodybattle. l% efolgedkt- tn- apuprtedj& o& r6wnBbssto Bleiler-- war mpposed to help Bkiler’s case. Buttbescbemewentbadwbenthe letter- w& b Bleiler says be never knew about- was rehmed to Bliss’s mailbox ps tmdebverablc. Bliss immdiately suqxt- edsEMasky. wbobadban~ him re~ to~ warkforBkiler. Gm- hted with the letter, she prIxb& d herself ‘humiliated.” and begged foq% ness. But Bliss wasn’t the forgiving kind. HetookbisstorytoKa& lL( hhwyerfor Le& skydeclinedtommment.).

l’be president’s lawyer was ail ears. Now that Lewimky bas become a iidlyim& mn nized witness for the pmecmm. islookingfordetailstbatmigbtamblebim to undermine Monica’s cmiibiity. last weekl. m& skyspcntsixboursbefomthe grand jury in Washington. l% ere. mdcr

rently undergoing testing at tbt FBI lab. DoesitcontainPNhmidence% Iwt+ mt bIbIMyhavePkeadyColt+& ompktedinitkltcctE. Buttbeendresubs- andwbetiuStsrrwill asktbepmidentforaDNAsampk- are baingtigbtlybeldmbetests- wpos- itive, andtbemsultsnrtiinkedtot3iutm, mytb& Km& llmi& thpndqpptodis- meditLewinskymigbtbeluldaedimk vant. ButXemldldoem’tbavetbe~ of bmwingwhattbosetestswillrwe! alIbc bcltheCUI& irprcpnrcbisaW- Mldbis client- andgetrmdyfortbeworst.

Meambile, S~ s~ ismoviBg~ lytoWlItp~ eteits+ lUtdnUyUlbUIita pouiblcnpon~~ bysafpscP tember. rrzonmyto~ tionsthatSmr

cwuldpremtevidenceafabroadpattem of obsmction of justice. NW hr learnedtbanportwiuioeusonlymtbe Lewimkymatterandotberaue@ ms oowingcmtoftbePaalaJonucase. MtEr fouryaarsand- tbanS@~ tim indapmdentcounselbarwonaltrisgaf Wbitewateraimimloavi& msaadstill hsstWUiUdiCtUlelltspmdiDkBUt~ evidmceStamhssdmeIopdagairutthe

-_ 2472 I prr& mt dating to Whi-- and otherIOXlttt? DSUCh~ tbClhtd-~ .~ fairandtheFBI& lescandal-- myit

iswtstToDgalougbtobein& dedin~ impl! a& mentrrport.? he~ could potentially cut both ways. The nanuw scopeoftbereportwillallowwhlteHouse spiunerstodenigmteStan%~ probe asltttle-& UlarenulnrquicritioaBrd nw& focu= drcpoacouldP== tprob- lems for the White House- laying art the luridLewiu& yc& geshstmkaxlrimpL laaguqetbatmaybediEadttodispute..

Kendall’s~~ imZcop

&ed to Monica’s Lewis 6 Clark days. He isaJsointerestedinthestoryofaDCm( r a-& c activist h- am Indianapolis named John Sullivan. who recalled meet&? Lt winsky at an October 19% fund- raiser in Wasbiqton. AS he waited along the rope line to shake Clinton’s band Sullivan says he wa5 polled aside by an event orgmizr. She told him that the woman standing next to him was named Monica and that Moni- ca was infatuated wjtb the presidmt and may have fantasized about having a rcla- tionship with him. Would Sullivan keep an eye on her? The incident came to light last

week when an Indianapolis TV rqorter saw a tape of the event and reqn& d Sul- livan- who then told his story to the re- porter. Sullivan told N~ wnnac Kendall

adledhimlmtweekmxlmked huttheevenLsuIhnuystite smoothbwyer. bimselfmIndi-

urptlUiVC, phyedUphiSHOOSkT

motstoaytowiusullivnnLtru&

tktumkayer. Butheisaterr-

ciasmdaa& vIit@ tmwitha

l- epummfortyiughisoppcaentr

Jolwon’sdecUonwasnbIowto theindqndentcolm4aud givesnew- unitiontotbe WhiteHousespinteamtbatStan * . 1cLnltotaxmoL

Iupuhlic. tbepistrying

toriseabovechelegdimbrogbo.

Utertbeembaqbombingsb A& a last Friday, Clinton solenmlyvowedtoblingtbettrmristato justiL% Tbis we& as the aa& aped c& nsnrrnebome. tbepres~ twlllbsve lJtib3TappommitiestoeZllpharizestateeraft overscandal. ButtbosewbosawClinton

htWGGknfterhoun& SCIi~ hiUl8SbLR-

dened and withdrawn. nbbing his eyes mdstsAngabse+ imospace.

It’s up to Kendall to take his dispbited client and transform bi& into a ampelJ&

The First Firm: A Very Small Circle

They’re the whitest of wbitr shoe lawyers. and their brief- resolving the Lewinsky crisis for the Fist Client -couldn’t be more important. or more difficult. But thefoursttorneys helping tbe president provide more than just legal counsel. Thev are now the only people in 8. a Clinton’s life with whom he enjoys protected. privileged conversation be pond tbe reach of Kenneth Starr’s subpoenas.

Dauid Kmdan

He didn’t lmow Bill andHillaryatYale. But now David xImdanisootbeip side. Hismildman- nerbeliesbisfierce ltgalinstincts.. 4 parwratwilliams 6 Connolly, the vditecollar defense kwfiml. Kendallis a cowzoom tiger just like the MS founder. F& ard BennatWillkUos.

telegenic and credible witness. He’s done it before. wbm Clinton gave videotaped tcs- timonyinpnviouswbitewater~, ju- rorssaidtbey-% cguiled’bytbepresi-

dent’s performance. Butayingto+ m .allcgeda& irisatf& rordcr. Kendallisleg- e& ryfor& ustivepqalatioosessions inwbicbbegrlllsbisclientsoverandover. dpyafta& y, llUkiQgtbCUlrrpepttb& Ur -. Inacasetbiscompll?& witbsomaay

Review- is- s p& utneratW~ &ctnmollymdak ldWou-=~ herOWUlight_ ShC

helped craft Oliver North’s defense. A tiiend and lawyer to John Kennedy’s kids, she’s said to bsvc tbe complete con6dmce oftbe Fiit I& y.

32 NEWSWEEK *“ GUST 17. ‘998

_ 2473 I possible hidden traps. tbat means the presi-

dent and his lawyer will be spending plenty of quality time- and billable bows- to- getherthisweek. Tbedrillhsalreadybe- gun. Intbemomings- andsometimesagain in tbe evening- Kendall and his partner Nicole Seligmau slip into the White House. Tbey use the East J% txance to the pxivate quarters, avoiding tba cameras along the West Wing driveway. There, in Clinton’s

I wbnia” r tnlu Plato cachelil

&I?~ Q~ hCOb stein, the

IrmyersguidingLwinsky

through the uur betwsn Chin-

ton andstarr

inforthepreaident, butClintondidn’trr spend. hhskctt amidn’t locate the presi- dent. Spotting Harold Ickes. Muakett asked the then deputy chief of stafffor belp. They knockedwtbedoortotbeOvalO5ce., but gotnomsponse. l% 9thalwenttotbcdoor of tbe president’s aevby private study. Tb9knocked~ thaloFeneclttIedoor.

Wbatbappmcdnutisamaaerof& Jme mntroversy. Muskett later told Secret

tl& two decades he’s been a trusted politi- cal adviser to the Clintons- cbaihng their ‘92 campaign andsewingasU. s. trade rep and CLXD- melKe- tary. The 6rm’s best pal.

mickey Kantor

He first met tbe Clinton. 5 in tbe 70s

wbenbeandHillay worked at the de good Legal Services Corp. And for more

Sewice and Justice De& em la- tbat he merely saw Lewinsky emerge hm~ the mom Clinton was in. But a fellow St set Service 05jcer. Gaty B_ yrne- who wasn’t present that day- told the g- ment la- a d& rent version. He Ad Muskatt bad told him tbat when thel\

qmedtbedoor. Lewimlry’sbeadwmim Clinton’s lap. Muskets has denied B_ mb -t.~ dIckesaaysbedoesn’treaIl auyaspectoftbestory. But- adl Newwzsxitwaslikelythisincidenttht pmmpedBymetowarnaaniorChm aideEve~ LiebmMuthat~ ra hngingannmdtheovalof& e. and~ beapOtGMialpl& h. Shortlyphcrarpd Lhnskywzotzmafen- edoutoftbeWwe HousetoajobatthePentngon. NaF. N~~~~~ haskamad. Star~‘ spmsear tors. mhtedwitbcbe~ ctotyr- wunts. want Just& wt o& As totallthemwiwth9- toldintth iataviewswitbMtnkattandBynte. Jm- tiamigktagreetodoaoasaaliyas* we&( Nei& rMt& ettwrByrncw& d cummentmN~)

With~ WWktogO, t2btlXlPider~& ir& eirbesttoamductBusinus UUd TbiSamkClhtt% lWiUASSUUSthe- tryxaisingmmqbr~~ uatsandpresi~ over~ whiDt House “message events” wbawu Air Force One touches dawn- touting pda

horites like tbe patiatts’ bill of rig& clean- water laws and gun mntml

But Clinton’s mind may be ehewhe LpstweektkepresidentsndFirstLadyin- vitedagroupofyo& 4Aew mzydiu. uerintbeBlueR~~~ Haue. l% erehyhashedonrthelatcst mcialtbe& sabaltjmnnik- aim vention. Acmrdhg to some guests, Z ton_ wbomrmallymvelsin~ wonkseasioG. seemcdattina? sdetpEhcd mdweary. Hefadedinandoutoftbeaa wsati~ andwasd& xdttoengaga. Mn caintoncs& edthediunerforbothaftban. sbaaal7erlvtookmtesanduawarairhc

HMary clintun Shearpsowtd

oneofthetoploo lawyersinAmaica

hdforgoad-~

thehlegxadand czerIz5 ‘5

Firmbasatop& 1cgalatiMLshe guides tbe First Firm but also defers to KendallmdMig- man. Tbayknow wllite- collarl% mhal defense. She doesn’t.

assembkd ’ ‘.“ andr& giousk! aderswitbdetalkd

~$ pe~~ E guests bad depated and the

FirstLadyhadgonaupatah ClintonlingamdwitbHaruald prof- hrnalwestanda fewotbers. Howcaayoumain- tainyourhitbhtbcsystml wben7ight~ gpngrtersia ties”- intentontaaring~ down? Weata& dtbeprai- dent.~ vebeenatntafor. long time.” Clinton lqomied “I’m prepwed.” David KendalI cerhinly hopes so.

With Drmnr. Rosrwmucd MA” X Hormhu.

A” G” ST I,. ‘998 NEWSWEEK 33

2474

2475

Tab 68

2476

2477 UNDER SEAL

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MORANDUM m

Id4NCV MAYER~ WHIllINCTON, US DlSTRlCl COURT

Lanny Breuer, SpeciaI Counsel to the President of the United States, has refused to

answer certain questions before a grand jury, asserting both the governmental attorney- client privilege and executive privilege. At a hearing on August 4,1998, the OfIke of Independent Counsel (“ OIC”) orally moved to compel Mr. Breuer’s testimony! The Court then ordered the OIC to submit materials that show its need for the evidence claimed to be covered by the executive privilege.

Preliminarily, the Court finds that the doctrine of collateral estoppel does not prevent Mr. Breuer and the Office of the President (“‘ the White House”) from asserting executive privilege. It is true that Bruce Lindsey asserted executive privilege -in a previous matter beforethis Court a; ld that the Court found that the executive privilege applied but was overcome by the OIC’s showing of need. While choosing not to appeal that ruling, the White House now seeks to litigate some of the same issues again, including the OIC’s need for privileged information. Although the legal issues remain much the same, the importance and sensitivity of this matter require a case- by- case determination of whether the executive privilege applies and whether it has been overcome by a proper showing of need. The factual issue of whether the OIC needs the particular information

;’ The Court resolved the motion to compel pertaining to the governmental attorney- client privilege in its Order of August 7, 1998.

2478

apparently possessed by Mr. Breuer is sufficiently different from the issue involving ML Lindsey to convince the Court that Mr. Breuer is not barred fi- om asserting privilege in these

Circumstances. In its Order of August $1998, the Court found that the communications to which Mr. Breuer has asserted the executive privilege are presumptively privileged. Executive privilege, also known in this context as the presidential umummications privilege, is a governmental privilege intended to promote candid communications between the President and his advisors concerning the exercise of his Article II duties. Unitsd 418 U. S. 683,705,708, 711 (1974); Ined a, 121 F. 3d 729,744 (D. C. Cir. 1997). In accordance with binding precedent on the issue, this Court must treat the subpoenaed testimony of Mr. Breuer as presumptively privileged. 2

The executive privilege is limited to ‘communications authored or solicited and received by those members of an immediate White House adviser’s staff who have broad arid significani responsibility for investigating and formulating the advice to be given to the Preside& on- the :

* See Nixoq, 4 18 U. S. at 7 13 (holding that when the President of the United States claims executive privilege, the district court has a ‘duty to _ . . treat the subpoenaed material as presumptively privileged”); In re Sealed Case 121 F. 3d at 744 (“ The President can invoke the privilege when asked to produce documents dr other materials that reflect presidential decision- making and deliberations and that the President believes should remain confidential. If the President does so, the documents become presumptively privileged.“); see also wte Select

on Presidential CamDaign v. Nixon, 498 F. 2d 725,730 (D. C. Cir. 1974) (“ Presidential conversations are ‘presumptively privileged, ’ even from the limited intrusion represented by in camera examination of the conversations by a Court.“); Nixon v. Sirica, 487 F. 2d 700,717 (D. C. Cir. 1973) (“ We.. . agree with the District Court that such conversations are presumptively privileged.“).

2479

pattioular matter to which the connnunieations relate.” Ld. at 752. Communications that do not relate to presidential decision- making are not included within the scope of the executive

. . . privilege. & m Nixon of W Sm 433 U. S. 425,449 (1977) (noting% at the privilege is ‘limited to communications ‘in performance of [a President’s] responsibilities, ’ ‘of his office, ’ and made ‘in the process of shaping policies and making decisions.“‘); In, 121 F. 3d at 752 (‘ Of course, the privilege only applies to communications that these advisers and their stafT author or solicit and receive in the course of performing theii function of advising the President on official government matters.‘).

While finding the other communications at issue to be “presumptively privilegw the Court holds that Mr. Breuer’s communications with persons in the Office of Legislative Affairs do not fall within the scope of the presumptive executive privilege. Mr. Breuer testified that he was asked by the head of the Legislative Affairs Office, where Monica Lewinsky had worked, to speak to a group of individuals in that Office who were fearful of beiig called by the press or the OIC. Mr. Breuer states that he provided legal advice to those individuals. This conversation does not appear to have been in the course of Mr. Breuer’s advising- the President on- official- government matters and thus cannot be covered by the executive privilege.

. . The Standard Reauired to Overcome the Pnv& ge The executive privilege is not absolute. Sj&, 487 F. 2d at 716. In order to overcome this privilege, the OIC must make a sufficient showing of need as defined by the D. C. Circuit in In re Sealed Case, 121 F. 3d at 754. In re Sealed Case directs that the OIC must show with specificity “first, that each discrete group of the subpoenaed materials [or testimony] likely contains important evidence; and second, that this evidence is not available with due diligence

2480

elsewhere.” Id. The information sought need not be “critical to an accurate judicial determination.” fi

The White House asserts that the recent decision of the Court of Appeals in In, No. 98z3660 (DC. Cir. July 27,1998), has heightened the required showing of need for materials allegedly covered by the executive privilege in the context of this case. According to the White House, it should be more di& uIt for the OIC to obtain these materials because the President anticipates impeachment pmceedings and that fact should alter the relevant need analysis. In b && q& y, the Court of Appeals states: “mnformation gathered in pmpamtion for impeachment proceedings and conversations regarding stmtegy are presumably covered by executive, not attomeyclienf privilege. While the need for secrecy might arguably be greater under these circumstances, the district court’s ruling on executive privilege is not before us.” I&, slip op. at 24.

The Court rejects the White House’s argument that the possibility of impeachment changes the need analysis set forth in In re Sealed Case. First, the Court of Appeals did not change the need analysis in its n opinion. The issue ofexecutiveprivilegewas not before the Court of Appeals and its suggestion that the need for confidentiality could be heightened under certain circumstances was clearly dictum. In addition, the Court of Appeals’ supposition that “the need for secrecy mipht arrmablv be greater” in the face of potential impeachment, In re Lindsey, slip op. at 24 (emphasis added), does not lead this Court to conclude, as the White House contends, that the D. C. Circuit “made clear that the analysis of any assertion of the presidential communications privilege is different where the OIC investigation arises under the specter of impeachment proceedings.” White House’s Response to the OIC’s I_ n

2481

w Submission at 4. Second, this Court declines to hold that the executive privilege need analysis changes when White House advisors are preparing for possible impeachment pmceedings. In essence, the

.- White %use argues as follows: (1) The President may withhold privileged communications

f. kom Congress even when the same communications would be discoverable in judicial proceedings? (2) the OIC will likely submit an impeachment report to Congress; and (3) therefore, the White House should not be compelled to turn over information to the grand jury because that information might be given to Congress. However, the subpoena before the Court is a grand jury subpoena, not a congressional subpoena, and the Court must treat it as such even assum@ that the OIC will prepare and submit a report to Congress. It is not known whether the information sought here by the grand jury will be included in any such report. Thus, the contention that information sought by the grand jury could at some time be given to Congress is not ripe for review.

The Court agrees that the President and his senior advisors have a significant ncedfor confidentiality when discussing possible impeachment proceedings. Nevertheless, they have the same need when discussing all other hinds of presidential decisions and strategies. When it

_ forn& ited the executive privilege need standard in Ir, re Sealed CW, the D. C. Circuit explicitly

recognized the “‘ great public interest’ in preserving ‘the confidentiality of conversations that take place in the President’s performance of his offkial duties.“ ’ 121 F. 3d at 742 (quoting Sirica, 487

3 Comnare Senate Select Committee, 498 F. 2d at 732- 33 (holding that the President need not produce materials in response to a subpoena from a legislative committee) with, u, Sirica, 487 F. 2d at 7 17 (holding that the President must produce materials in response to a grand jury subpoena).

2482

F. 2d at 7 17). The Court of Appeals also understood that such a privilege was “necessary to guarantee the candor of presidential advisers and to provide ‘[ a] President and those who assist him. . . [with] f& e[ dom] to explore alternatives in the process of shaping policies and making decisic%& d to do so in a way many would be unwilling to express except privately.“‘ Ig, at 743 (quoting Nixon. 418 U. S. at 708). The same interests apply in the impeachment context and there is simply no authority for having the rigor of the executive privilege analysis depend upon the subject matter discussed.

In concluding itsla re S& xi C* opinion, the D. C. Circuit statedz

In holding that the privilege extends to communications authored by or solicited and received by presidential advisers and that a specified demonstration ofneedmustbemadeeveninregardtoagrandjurysubpoena, weareever mindful of the dangers involved in cloaking governmental operations in secrecy and in placing obstacles in’the path of the grand jury in its investigatory mission. There is a powerful counterweight to these concerns, however, namely the public and constitutional interest in preserving the efficacy and quality of presidential dccisionmaking. We believe that the principles we have outlined in this opinion achieve a delicate and appropriate balance between openness and informed presidential deliberation.

u at 762. The concerns raised by the White House have been amply considered by the D. C. Circuit. This Court cannot and will not disturb the “delicate and appropriate balance” so carefully struck by the Court of Appeals.

Thus, the Court will turn to this Circuit’s interpretation of the needstandard. The first requirement - “that each discrete group of the subpoenaed materials [or testimony] likely contains important evidence” - charges that the evidence sought must be “directly relevant to the issues that are expected to be central to the trial.” Id. As the D. C. Circuit noted, this requirement will ordinarily have limited impact because Federal Rule of Criminal Procedure

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17( c) already restricts the reach of a subpoena to relevant information. Ig, at 754. With respect to the second. requirement - that “this evidence is not available with due diligence elsewhere” - the party seeking to overcome the privilege should first attempt to deter&& whether sufficient evidence could be obtained elsewhere. Id at 755. The issuer of the subpoena “should be prepared to detail these efforts and explain why evidence covered by the presidential privilege is still needed,” Id The D. C. Circuit noted:

there will be instances where such privileged evidence will be particularly useful, . . . as when, unlike the situation here, w& white ad- or IS beau . . . . i . In such situations, the subpoena proponent will be able & to explain why there is m to evidence likely contained in the subpoenaed matekls.

Id (emphases added). That court also explained that “a grand jury will often be able to specify its need for withheld evidence in reasonable detail based on information obtained from other

sources.” Id at 757. Finally, if the grand jury has diaculty obtaining evidence from other sources, “this fact in and of itselfwill go far toward satisfying the need requirement.” fi

Lastly, if a “demonstrated, specific need” is shown, then the subpoenaed testimony shall be given to the grand jury ;mless there is “no reasonable possibility that the category of materials the Government seeks will produce information relevant to the general subject of the grand jury’s investigation.” United States v. R. Fm, 498 U. S. 292,300 (1991).

3. 9 e OIC s Sho wine of Need The OIC has made an extensive ex parte submission to the Court regarding its need for this evidence, which the Court has carefully reviewed in camera. This submission incorporates and updates the OIC’s previous need submission in connection with Bruce Lindsey’s invocation of executive privilege as well as two other prior in camera need submissions from the OIC. The

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OIC’s current need submission describes fifteen categories of information that it seeks from Mr. Breuer and explains how each category meets them need standard. Because the Court has reviewed the OIC’s submission incamera it is unable to describe in any detail the basis f& &s findings. & Ined w, 121 F. 3d at 740.

As for the first requirement the Court finds that the testimony the OIC seeks likely contains important evidence that would be directly relevant to central issues in the grand jury’s investigation. The OIC has been authorized to investigate whether Monica Lewinsky “or others” suborned perjury, obstructed justice, or tampered with witnesses, Order of the Special Division, Jan. 16,1998, and the testimony tithheld on the basis of executive privilege is likely to shed light on that inquiry.

Regarding the second requirement, the Court finds that the OIC has shown with sufikient specificity that the evidence it seeks is not available with due diligence elsewhere. & a at 754. First, as this Court has noted before, “the crimes being investigated by the grand jury arc inherently crimes of conversation and such conversations are unlikely to be recorded on paper.” Order of May 4, 1998, at 12. TheD. C._ Ci@ thasdeclared thatif a crime king investigated by the grand jury relates to “the content of certain conversations,” then the grand jury’s need for the

I exact text of those conversations is ‘- iable. Obviously, this evidence is not available

elsewhere; even if. . . counsel offered to provide the grand jury with every statement that was made to the White House, the grand jury would need to review the evidence in the White House files to confirm that no statements were omitted.” Ih, at 761 (quoting Senate Select, 498 U. S. at 732) (emphasis added). The OIC “may also bc able to demonstrate a need for information that it currently possesses, but which it has been unable to confirm or disprove.” Ih: There is no

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indication that the conversations at issue here were recorded; the only sources of information regarding those conversations arc the participants themselves.

Even if the grand jury possesses testimony of one party to a conversation, it may still need the tesGony of other parties to the conversation to confirm or disprove the veracity of the prior testimony. The Court is well aware that two parties to a conversation may testify quite differently. As the D. C. Circuit recognized, even if a witness agrees to testify, the grand jury would still need to review further evidence to determine if it has the complete story. u In this instance, even if one witness has testified regarding a specific conversation, the grand jury may still need to subpoena other participants in that conversation to obtain the full picture. The evidence sought here is Mr. Breuer’s version of certain conversations; such evidence can be obtained only from Mr. Breuer.

Second, the OIC has provided the Court with detailed information about its unsuccessful efforts to obtain this evidence through other sources. As the Court found significant in its previous executive privilege opinion, the OIC has diligently pursued other alternatives in seeking this information. The OIC has issued 23 subpoenas duces tecum tc the White House since the beginning of its investigation and has issued one to President Clinton individually. Declaration

- of Julie A. Corcoran 14. In addition, the OK interviewed eighty current or former White House

employ. ees during its investigation and thirty- five current or former White House employees have testified before the grand jury. Declaration of Patrick F. Fallon, Jr. 17 4- 5.

The D. C. Circuit found that, in practical terms, “the primary effect of [the unavailability] standard will be to require a grand jury to delay subpoenaing evidence covered by presidential privilege until it has assured itself that the evidence sought from the President or his advisers is

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both important to its investigation and practically unavailable elsewhere.” In&,& dG~ ealed, 121 F. 3d at 75647. The fact that the OIC has not called Mr. Breuer until this time is consistent with

the OIC’s having unsuccessfully attempted to obtain the evidence elsewhere and having -ic -z determmed the evidence to be necessary to the grand jury’s investigation.

The White House contends that the OIC has many alternative sources for the information sought from Mr. Breuer, including Secret Service agents, Monica Lewinsky, and others. On the basis of the in submission, including declarations submitted by the OIC, the Court finds that these sources have not provided the grand jury with the information withheld by Mr. Breuer under the executive privilege. Moreover, it is not clear at this time how much information President Clinton will provide to the grand jury at his deposition. ’ He may not remember certain events about which the grand jury seeks information.

The OIC has made a significant factual showing to the Court and has fully demonstrated its need for Mr. Breuer’s testimony. The Court also fmds that the communications covered by the presumptive privilege likely- contain evidence important to the .grand jury’s investigation and cannot bc obtained elsewhere with due diligence. The Court will therefore grant the OIC’s motion to compel the testimony of Mr. Breuer insofar as he has asserted the executive privilege.

Accordingly, upon consideration of the OIC’s in need submissions and the White House’s response to that submission, it is this //,& day of August 1998,

’ As the OIC points out, if the President intends to testify about his communications with Mr. Breuer, it is strange that Mr. Breuer is asserting executive privilege with respect to those very communications.

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ORDERED that the Office of Independent Qwnsel’s motion to compel the testimony of Lanny Breuer be, and hereby is, granted as to testimony covered by the executive privilege.

&lIEF JUDGE vv

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I .ation Found Document Rank 5'6 of 71 L3/ 98 NYT- ABS 18

8/ 13/ 98 N. Y. Times Abstracts 18 1998 WL 5422549

Thursday, August 13, 1998 Section A

Page 5 Aide Implies President Will Not Dodge Queries

BENNET, JAMES President Clinton will answer every question put to him when he testifies on Monday in the grand jury investigation into his relationship with Monica S. Lewinsky, a White House spokesman indicated today./ Some television commentators and essayists have speculated that Mr. Clinton might choose to invoke constitutional protections against compelled self- incrimination or invasion of privacy to prevent prosecutors from asking specific questions about

relationship with Ms. Lewinsky, a former White House intern. Database

NYT- ABS NAMED PERSON: KEY WORDS: NEWS SUBJECT: NEWS CATEGORY: Word Count: 73 8/ 13/ 98 NYT- ABS END OF DOCUMENT

---- INDEX REFERENCES ---- CLINTON, BILL; LEWINSKY, MONICA SCANDALS; TESTIMONY; INVESTIGATIONS; ADULTERY; GRAND JURIES Lifestyle; Law Enforcement (LIF LEN) NEWS

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Thursday, August 13, 1998 NEWS White House suggests Clinton plans to answer all questions

Judy Keen; Gary Fields WASHINGTON

WASHINGTON -- The White House moved Wednesday to quell speculation that President Clinton might refuse to answer some questions when he testifies about Monica Lewinsky next week.

White House spokesman Joe Lockhart reiterated at the daily news briefing that Clinton intends to testify "completely and truthfully." Asked whether that means Clinton will not decline to

- swer certain questions, Lockhart said, "That's what it suggests to yes."

Clinton is scheduled to testify Monday under oath via closed- circuit TV from the White House. There has been speculation that he might assert his Fifth Amendment right not to incriminate himself or his Fourth Amendment right to privacy to avoid answering some questions about his relationship with the former White House intern.

Independent counsel Ken Starr is investigating whether Clinton .had a sexual relationship with Lewinsky, lied about it under oath and asked others to conceal it. Clinton has denied the allegations.

Lewinsky testified last week to the grand jury that she did have an affair with Clinton and that they discussed ways to keep it secret, but that he did not directly ask her to lie, according to people with knowledge of her testimony.

Speculation is also mounting about a potentially critical piece of evidence: the dress being tested for DNA evidence. Lewinsky gave prosecutors the dark blue dress after she was given immunity from prosecution July 28.

4ockhart said Wednesday that he's not aware of any request -from rr for DNA samples from the president. Asked whether Clinton . . 4 aid like to know the results of the FBI tests, Lockhart said, " I

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Page 11 "'13/ 98 USATD 04A .b

.l't know." Other developments: Justice Department lawyers are working with Starr's office to clear up an apparent discrepancy in the testimony of two Secret Service uniformed officers.

At issue are the recollections of officers John Muskett and Gary Byrne, people with knowledge of the matter said.

Those people say Muskett. has told Justice Department lawyers that he and Harold Ickes, then deputy chief of staff, opened the door of the president's private study in early 1996 and saw Lewinsky leave the room. They also say Byrne has told the government lawyers that Muskett told him that he and Ickes saw Clinton and Lewinsky in an intimate situation.

Byrne and Muskett were unavailable for comment Wednesday. Ickes has said he never saw any sexual encounters between Clinton and Lewinsky.

Byrne and Muskett were among the first Secret Service personnel to appear before the grand jury after Supreme Court Justice William F nquist cleared the way last month for Secret Service officers and L-- nts to be called.

Starr's office is preparing a report for Congress that may focus on evidence developed in the Lewinsky investigation.

Under the independent counsel act, Starr must report to Congress if he finds evidence of impeachable offenses by the president.

Other matters Starr has been reviewing, including the firing of travel office employees and the White House's acquisition of secret FBI background files, are not likely to produce evidence of impeachable offenses, people with knowledge of Starr's inquiry said.

Starr's report could be sent as early as next month, those people said, but no final decisions on its scope or findings have been made.

TABULAR OR GRAPHIC MATERIAL SET FORTH IN THIS DOCUMENT IS NOT DISPLAYABLE PHOTO, b/ w, AFP

---- INDEX REFERENCES ---- KI WORDS: INVESTIGATION; PRESIDENCY; SCANDAL; WITNESS _ ERNMENT: Executive (EXE)

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Thursday, August 13, 1998 A Section White House Rejects Suggestion Clinton Might Limit Testimony

Peter Baker Washington Post Staff Writer

With unsolicited advice cascading in from all sides, the White House tried to stamp out speculation yesterday that President Clinton might not answer certain questions about Monica S. Lewinsky during his grand jury testimony Monday.

Despite Clinton's pledge to testify "completely and t- uthfully," some former advisers and legal analysts have suggested in _zent days that he could limit his testimony, either by refusing to

'icuss his sex life or by giving a carefully worded statement on his

_ .lationship with Lewinsky without answering further questions. But none of those scenarios comport with the president's pledge, according to aides who insisted they knew of no plans to follow such recommendations. Asked during the daily news briefing yesterday if Clinton was saying he would answer all questions when he vowed to testify "completely," White House deputy press secretary Joe Lockhart said, "That's what it suggests to me, yes."

Another senior official who did not want to be named said resisting some questions was not known to be under consideration, unless the president has discussed it with his personal attorney, David E. Kendall.

Clinton returned to Washington from a fund- raising trip early yesterday morning for what will be several days of intensive preparations with his lawyers, sessions that will extend into the weekend leading up to Monday's encounter with independent counsel Kenneth W. Starr at the White House.

Lockhart said that he could not say whether Clinton agreed with P" lary Rodham Clinton's comment this week attributing much of their r\ Jblems to prejudice against Arkansas, but added that the president

lpathized with the view. "The president has heard that when he has %,; le home and I think he understands that," Lockhart said. Friends

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?3/ 98 WASHPOST A04 ..~ ,rn there "feel like they were singled out because they were from Little Rock or they were from Arkansas."

Page 14 The notion of restricting Clinton's testimony has some appeal among advisers who believe it could minimize his legal exposure in a way that could be politically defensible if couched in terms of privacy concerns. And yet while they publicly explore such options, nearly all of them have been kept out of the loop as Clinton limits his consultations to his private attorneys and the first lady -- virtually the only people he can talk with who would not be subject to subpoenas by Starr.

As a result, numerous suggestions offered during television appearances or in newspapers are not based on a full knowledge of the facts. "It's all just the inevitable chattering in this kind of pre- testimony buildup," said James E. Kennedy, of the White House counsel's office.

Much of the speculation appears based on confusion or disagreement about the definition of sex used in the Paula Jones case, in part because the publicly released portion of Clinton's deposition transcript does not include a full account of how the lawyers involved , .e to define the term. The definition is key to whether Clinton can ._ accused of perjury.

At the beginning of the Jan. 17 deposition, Jones's lawyers asked U. S. District Judge Susan Webber Wright to allow them to use a section of federal law to define the term "sexual relations" whenever it came up during the questioning. This was done for two reasons: to avoid having to ask the president salacious questions in explicit detail and to make clear to everyone exactly what was meant by the term llsexual relations."

The definition presented by Jones's lawyers included three parts: "For the purposes of this deposition, 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; (2) contact between any part of the person's body or an dbject and the genitals or anus of another person; or (3) contact between the genitals or anus of the person and any part of another person's body. 'Contact' means intentional touching, either directly or through clothing."

Wright declined to accept the whole definition, deeming it too brqad. Instead, according to an authoritative account, she limited it t \, :he first point and excluded points two and three.

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,3/ 98 WASHPOST A04 Page 15 avoid confusion or ambiguity, Jones's attorney referred to the definition approved by the judge. Clinton lawyer Robert S. Bennett objected, saying he was not sure that the president could remember the definition.

"Well, it's real short," Wright responded. "I will permit the question and you may show the witness definition number one."

Shown that definition, Clinton then answered, "I have never had sexual relations with Monica Lewinsky. I've never had an affair with her."

---- INDEX REFERENCES ---- KEY WORDS: NATIONAL EDITION: FINAL Word Count: 778 8/ 13/ 98 WASHE'OST A04 END OF DOCUMENT

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Page 7 tation Found Document 13/ 98 WATIMES Al 8/ 13/ 98 Wash. Times (D. C.) Al 1998 WL 3455718

Rank 2 of 79 The Washington Times

A Clinton won't dodge questions about his sex life

Paul Bedard THE WASHINGTON TIMES

President Clinton won't dodge questions about his sex life when he testifies to the Monica Lewinsky grand jury Monday, the White House said yesterday.

But his spokesman complained that the president's privacy has been violated.

"He plans to testify completely and truthfully," said deputy press :retary Joe Lockhart.

Asked whether Mr. Clinton will "answer every question" put to him by independent counsel Kenneth W. Starr and his deputies, Mr. Lockhart said, "Yes."

He said the president would not invoke his rights under the Fourth and Fifth Amendments to the Constitution, which protect citizens against unreasonable searches or self- incrimination.

"The president told you he'll answer truthfully and completely. I think that answers that question."

Speculation had blossomed that Mr. Clinton would refuse to answer questions about his sex life when he testifies from the White House via closed- circuit. He can expect to get questions about whether he engaged in oral and telephone sex with Miss Lewinsky and then discussed with her ways to avoid admitting it.

Mr. Lockhart said that the president would repeat his denial that he had sexual relations with the 25- year- old former White House intern and also that he never asked her to lie.

‘\ The spokesman dampened speculation that the president would 'ress the nation after giving his testimony. "I think his main b& iority right now is to go in and testify completely and

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'13/ 98 WATIMES Al lthfully."

Rage 8 Mr. Lockhart said the White House hopes the contents of his testimony aren't leaked. "If the rule of law is followed and the president decides not to discuss his testimony, then there shouldn't be any leaks."

Several Democrats have called on the president to reveal his testimony in a public address, but his advisers have pressed the president not to do that.

The topic has dominated many White House meetings on the subject, but there has been no decision on a post- testimony address to the nation or short statement by the president to the press.

One aide joked that the president could quell the controversy and end his nonstop fund- raising campaign planned for the fall by "putting his testimony on pay per view. How about $39.95?"

Mr. Clinton returned home early yesterday from a two- day campaign fund- raising trip and began preparing for his testimony, slated to last from shortly after 9 a. m. Monday to late afternoon. He is

petted to leave Monday night for a two- week vacation in Martha's 'jeyard, an island off the Massachusetts coast.

While the White House refused to detail his preparations or preview his testimony, his spokesman expanded on the first lady's attacks on Mr. Starr by claiming the prosecutor is digging too deeply into the first family's privacy.

"One of the negatives is a loss of privacy and privacy within your family," said Mr. Lockhart. "I would find it hard to believe, having watched the last few months, that he wouldn't believe that there were

new inroads to that privacy." The president and first lady have often complained about their loss of privacy, and have expressed concerns about intrusions by reporters and especially photographers who have taken pictures of the two in private vacation moments.

But Mr. Lockhart said that those concerns won't prompt the president to duck sensitive questions about his private life if asked by Mr. Starr and his team.

The White House endorsed Hillary Rodham Clinton's remarkable charge that Mr. Starr harbors a bias against Arkansas. Mr. Lockhart

_d the president thinks Mr. Starr dislikes the Clintons and that investigation is driven by an anti- Clinton bias.

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'13/ 98 WATIMES Al Page 9 'It's impossible for me . . . to separate the two. I am sure that there are some people who feel like they are treated unfairly because of their connection, or their friendship or their relationship, with the president. I am sure that there are others who feel that it's their connection to - whether the fact that they live in Little Rock or they're from Arkansas."

The first lady on Monday complained to the Arkansas Democrat Gazette of Little Rock that Mr. Starr's inquiry is driven by a "prejudice against our state . . . they wouldn't do this if we were from some other state."

Mr. Lockhart agreed, saying: "There have been a number of people who have little or no dealing with some of the matters that the independent counsel has looked at who've had their lives turned upside down and have run up legal bills. So I think there is a sentiment among some people back in Arkansas that they've been treated unfairly."

Mr. Starr, whose Whitewater investigation was set off by accusations by Arkansans, including the Clintons' former business partner, offered no comment yesterday.

.lonsiderable time between today and Monday have been set aside for

* Clinton to huddle with his lawyers and Harry Thomason, a Hollywood TV producer, in preparation for his testimony.

Mrs. Clinton also plans to provide advice. "She has some involvement," said the spokesman.

But Mr. Lockhart said only the president's lawyers - David Kendall, Nicole Seligman and Mickey Kantor - and his wife know what the president plans to say in his testimony.

"There is no loop," explained Lisa Caputo, Mrs. Clinton's former spokeswoman.

The White House is working to complete arrangements for the testimony. Previously taped Clinton depositions have taken place in the Map Room, the ground- floor room in the residence used by President Roosevelt for war councils during World War II.

---- INDEX REFERENCES ---- EDITION:

\ d Count: 895 L- 3/ 98 WATIMES Al ~.. 3 OF DOCUMENT

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Page 1 tation 17/ 98 NEWSWEEK 30 8/ 17/ 98 Newsweek 30 1998 WL 17010289

Monday, August 17, 1998 Vol. 132, No. 7, ISSN: 0028- 9604 Monica On The Stand.( Monica Lewinsky's grand jury testimony)

Michael Isikoff Daniel Klaidman Karen Breslau As Lewinsky tells her story to the grand jury, the president's team ponders how to fight back-- in part, perhaps, by attacking the former intern's credibility. How ugly could it get?

David Kendall didn't waste time. When the news broke late last month that Monica Lewinsky had finally struck an immunity deal with Kenneth Starr, the president's lawyer began working the phones. He'd received -7 intriguing fax from a man named David Bliss, who said he had a story

out Lewinsky that Kendall might want to hear. Kendall quickly faxed Q back, thanking Bliss for sending the "very welcome" material "out

_ the blue." Kendall followed up with a phone call to Bliss, leaving a solicitous message -- which Bliss played for Newsweek-- on his answering machine. "I think it's important that we get together and, you know, decide how to proceed," Kendall said.

What did Bliss have on Lewinsky that was so tantalizing to the president's lawyer? Bliss, a drama- department shop foreman at Lewis C Clark College, told Kendall that when Lewinsky was a 21- year- old student there in 1995, she had forged a letter in his name on school stationery. Apparently Lewinsky was trying to help out Andy Bleiler, a married drama coach with whom she was allegedly having an affair. Bleiler was out of work, and embroiled in a custody battle. The forged letter-- a purported job offer from Bliss to Bleiler-- was supposed to help Bleiler's case. But the scheme went bad when the letter-- which Bleiler says he never knew about -- was returned to Bliss's mailbox as undeliverable. Bliss immediately suspected Lewinsky, who had been pestering him relentlessly to find work for Bleiler. Confronted with the letter, she proclaimed herself "humiliated," and begged forgiveness. But Bliss wasn't the forgiving kind. He took his story to Kendall. (A lawyer for Lewinsky declined to comment.)

The president's lawyer was all ears. Now that Lewinsky has become a lly immunized witness for the prosecution, Kendall is looking for .ails that might enable him to undermine Monica's'credibility. Last h< ek Lewinsky spent six hours before the grand jury in Washington.

Database NEWSWEEK

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17/ 98 NEWSWEEK 30 Page 2 2re, under oath, she apparently contradicted the president's denials -- both in his Paula Jones deposition and to the country-- that the two had a sexual affair. The basics of Lewinsky's testimony began leaking to the press soon after she left the courthouse. The former intern reportedly admitted to more than a dozen sexual encounters with the president -- and said that she and Clinton discussed how to conceal their relationship. But on the question of whether Clinton explicitly asked her to lie under oath, Lewinsky refused to testify that the president instructed her to perjure herself.

As Kendall prepares his legal counteroffensive-- and with Clinton's Aug. 17 testimony just a week away -- there are obstacles everywhere. Any lawyer's biggest fear is a surprise question that leaves his client befuddled and in danger of falling into a perjury trap. This is exactly what Kendall is up against. The biggest unknown, and one that could conceivably wreck all of Kendall's careful preparation, is the blue dress currently undergoing testing at the FBI lab. Does it contain "DNA evidence"? The crime lab may have already completed initial tests. But the end results -- and whether Starr will ask the president for a DNA sample -- are being tightly held. If the tests come back positive, and the results are linked to Clinton, anything Kendall might have dug up t- discredit Lewinsky might be rendered irrelevant. But Kendall doesn't

e the luxury of knowing what those tests will reveal. The best he

I do is prepare his case-- and his client-- and get ready for the hrrrst.

Meanwhile, Starr's staff is moving rapidly to complete its probe and may submit a possible report to Congress by early September. Contrary to expectations that Starr would present evidence of a broad pattern of obstruction of justice, Newsweek has learned the report will focus only on the Lewinsky matter and other allegations flowing out of the Paula Jones case. After four years and more than $40 million, the independent counsel has won a string of Whitewater criminal convictions and still has two indictments pending. But whatever evidence Starr has developed against the president relating to Whitewater-- and other matters such as the Travel Office affair and the FBI file scandal-- sources say it is not strong enough to be included in an impeachment report. The findings could potentially cut both ways. The narrow scope of the report will allow White House spinners to denigrate Starr's entire probe as little more than a sexual inquisition. But a tightly focused report could present problems for the White House-- laying out the lurid Lewinsky charges in stark and simple language that may be difficult to dispute.

No matter what Starr's report reveals, Kendall's immediate problem remains the same: how to make Clinton appear more credible than I. insky. One option: do "oppo" research on the chief accuser. Before l'Li. nsky reached an agreement with Starr, Kendall tread lightly on her

t to avoid pushing her into the independent counsel's camp. Since sne's cut her deal, however, Kendall is no longer restrained. For now,

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17/ 98 NEWSWEEK 30 Page 3 2 lawyer is keeping potentially damaging stories in his briefcase. But they could prove useful to him during possible impeachment hearings, where Democrats loyal to the president would get the chance to interrogate the former intern.

Kendall's Lewinsky digging isn't confined to Monica's Lewis c Clark days. He is also interested in the story of a Democratic activist from Indianapolis named John Sullivan, who recalled meeting Lewinsky at an October 1996 fund- raiser in Washington. As he waited along the rope line to shake Clinton's hand, Sullivan says he was pulled aside by an event organizer. She told him that the woman standing next to him was named Monica, and that Monica was infatuated with the president and may have fantasized about having a relationship with him. Would Sullivan keep an eye on her ? The incident came to light last week when an Indianapolis TV reporter saw a tape of the event and recognized Sullivan -- who then told his story to the reporter. Sullivan told Newsweek Kendall called him last week and asked about the event. Sullivan says the smooth lawyer, himself an Indiana native, played up his Hoosier roots to try to win Sullivan's trust.

Soft- spoken and camera averse, Kendall has a reputation as a flentleman lawyer. But he is a tenacious and crafty litigator with a

2utation for tying his opponents in knots. Starr has already gotten a ;te of Kendall's tactics. When the president's lawyer petitioned the ,, urts to investigate the independent counsel's alleged grand- jury leaks to the press, it was seen as a somewhat desperate publicity stunt. But last week it was revealed that Judge Norma Holloway Johnson came down on Kendall's side-- ruling that there probably were illegal leaks, and ordering Starr to prove his office wasn't the source. Last week a federal appeals court handed Starr one minor victory on the matter: it denied Kendall the opportunity to interrogate Starr's prosecutors about the leaks. Still, Johnson's decision was a blow to the independent counsel, and gives new ammunition to the White House spin team that Starr is out of control.

In public, the president is trying to rise above the legal imbroglio. After the embassy bombings in Africa last Friday, Clinton solemnly vowed to bring the terrorists to justice. This week, as the flag- draped coffins arrive home, the president will have other opportunities to emphasize statecraft over scandal. But those who saw Clinton last week after hours described him as burdened and withdrawn, rubbing his eyes and staring absently into space.

It's up to Kendall to take his dispirited client and transform him into a compelling, telegenic and credible witness. He's done it before.

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7, '98 NEWSWEEK 30 Page 4 Aents over and over, day after day, making them repeat their answers. In a case this complex, with so many possible hidden traps, that means the president and his lawyer will be spending plenty of quality time-- and billable hours-- together this week. The drill has already begun. In the mornings -- and sometimes again in the evening-- Kendall and his partner Nicole Seligman slip into the White House. They use the East Entrance to the private quarters, avoiding the cameras along the West Wing driveway. There, in Clinton's second- floor office overlooking the South Lawn, Kendall methodically runs through the evidence, asking the president to explain everything from Lewinsky's White House visits to her high- powered job search. There are usually only two others allowed in the room: Hillary Clinton and Mickey Kantor, another private lawyer.

No matter how thoroughly Kendall preps his client, however, he can't anticipate every question the special prosecutor might ask. Even Starr doesn't have all the answers. For months, for example, there have been numerous hazy press reports that a uniformed Secret Service officer witnessed an alleged encounter between Clinton and Lewinsky. The story has changed over time, and the details remained sketchy. A Newsweek reconstruction of the events may shed some light on the incident. On E-- ter Sunday 1996, according to government lawyers, officer John

kett was stationed outside the Oval Office. A phone call came in for president, but Clinton didn't respond. Muskett couldn't locate the k, zsident. Spotting Harold Ickes, Muskett asked the then deputy chief of staff for help. They knocked on the door to the Oval Office, but got no response. They then went to the door of the president's nearby private study. They knocked again, then opened the door.

What happened next is a matter of some controversy. Muskett later told Secret Service and Justice Department lawyers that he merely saw Lewinsky emerge from the room Clinton was in. But a fellow Secret Service officer, Gary Byrne -- who wasn't present that day-- told the government lawyers a different version. He said Muskett had told him that when they opened the door, Lewinsky's head was in Clinton's lap. Muskett has denied Byrne's account. And Ickes says he doesn't recall any aspect of the story. But sources tell Newsweek it was likely this incident that prompted Byrne to warn senior Clinton aide Evelyn Lieberman that Lewinsky was hanging around the Oval Office, and might be a potential problem. Shortly afterward, Lewinsky was transferred out of the White House to a job at the Pentagon. Now, Newsweek has learned, Starr's prosecutors, confronted with the contradictory accounts, want Justice Department officials to tell them what they were told in their interviews with Muskett and Byrne. Justice might agree to do so as early as this week. (Neither Muskett nor Byrne would comment to N 7week. f

ith a week to go, Clinton aides are doing their best to conduct business as Usual. This week Clinton will crisscross the country

Copr. 0 West 1998 No Claim- to Orig. U. S. Govt. Works

2515

P/ 17/ 98 NEWSWEEK 30 Page 5 Asing money for congressional Democrats and presiding over official White House "message events" wherever Air Force One touches down-- touting voter favorites like the patients' bill of rights, clean- water laws and gun control.

But Clinton's mind may be elsewhere. Last week the president and First Lady invited a group of youth- violence experts to a cozy dinner in the Blue Room of the White House. 'There they hashed over the latest social theories about juvenile- crime prevention. According to some guests, Clinton, who normally revels in after- hours wonk sessions, seemed at times detached and weary. He faded in and out of the conversation, and was difficult to engage. Mrs. Clinton carried the dinner for both of them. She eagerly took notes and peppered the assembled academics and religious leaders with detailed questions. At the end of the evening, after most of the guests had departed and the First Lady had gone upstairs, Clinton lingered with Harvard professor Cornel West and a few others. How can you maintain your faith in the system when "right- wing gangsters in ties" seem intent on tearing you down? West asked the president. "They've been at me for a long time," Clinton responded. "I'm prepared." David Kendall certainly hopes so.

With Debra Rosenberg and Mark Hosenball ---- INDEX REFERENCES ---- NAMED PERSON: MONICA LEWINSKY KEY WORDS: OBSTRUCTION OF JUSTICE SCANDALS Word Count: 2009 8/ 17/ 98 NEWSWEEK 30 END OF DOCUMENT

Copr. 0 West 1998 No Claim to Orig. U. S. Govt. Works

2519

FEDERAL BUREAU OF INVESTIGATION WASHINGTON, D. C. 20535

Date: August 17, 1998

To: Mr. Kenneth W. Starr Office of the Independent Counsel 1001 Pennsylvania Avenue, N. W. Suite 490- North FBIF& zNo. 29D- OIC- LR- 35063 Washington, D. C. 20004

Lab No. 980730002 S BO 980803100 S BO

Reference: Communication dated July 30, 1998 and evidence submitted August 3, 1998

Your No. 29D- OIC- LR- 35063

RC: MOZARK; MC 106

Specimens received: July 30, 1998 and August 3, 1998 Specimens:

This report supplements two FBI Laboratory reports dated August 3, 1998 and August 6, 1998 and contains the results of the DNA- RFLP examinations.

This completes the requested examinations. The submitted items and the probed DNA membranes will be retained until retrieved by a representative of your organization. In addition to the evidence in the case, any remaining processed DNA from specimens examined by DNA analysis is also being returned to you. The processed DNA can be found in a package marked PROCESSED DNA SAMPLES: SHOULD BE REFRIGERATED/ FROZEN. It is recommended that these samples be stored in a refrigerator/ freezer and isolated from evidence that has not been examined.

This Report Is Furnished For Official Use Only

2520

FEDERAL BUREAU OF INVESTIGATION WASH~ GTON, D. C. 20535

Report of Examination

DatC: 08/ 17/ 98 Unit: DNA Analysis 1 Wont No.: 202- 324- 4409 FBI File No.: 29D- OIC- LR- 35063 Iab No.: 980730002 S BO

980803100 S BO ResultsofExaminations:

Deoxyribonucleic acid (DNA) profiles for the genetic loci D2S44, D17S79, DlS7, D4S139, DlOS28, D5SllO and D7S467 were developed from HaeIII- digested high molecular weight DNA extracted from specimens K39 and Q3243- l( a semen stain removed from specimen 43243). Based on the results of these seven genetic loci, specimen K39 (CLINTON) is the source of the DNA obtained from specimen Q3243- 1,

scientific certainty. to & reasonable degree of No DNA- RFLP examinations were conducted on specimen Q3243- 2 (a semen stain removed from specimen Q3243).

DNAUl - Page 1 of 1 This Report Is Furnished For Offkial Use Only

2521

Tab 75

2522

2523

Rug 17 1990 .x: 52: 53 Via F& X -> Brian Smith Page 683 Of 883

Al? 12969 ri ----- US- Clinton- Text, 2 Takes. 02 12 08- 17 IO: 18p By The Associated Press

Text of President Bill Chton” s address to the nation, as transcribed by the Federal Document Cfearing mwse:

Good evening. This afternoon in this room, from this chair, I test& d before the Office of ~de~ endc~ t Caunsei and the grand jury.

1 answered their questions t~ t~~~ y, ~~ o~~ di~~ questions about my private iife, questions no American citizen would ever want to answer.

Still. I must take complete r~~~ on~~ bi~~ ty far alI my actions, both public and private. And that is why I am spe& in~ to you tonight-

As you know, in a deposition in January, I was asked questions about my relatianship with Monica Lewinslcy. While my answers were &gaily accurate, I did not volunteer ~~ fo~ a~ j~ n~

Indeed, r did have a re~ at~ o~ s~~ with Ms. L& n& y that was nat appropriate. In fact, it was wrang. It co~ a~ j~ u~ ed a critica! lapse in judgment and a personal failure on my part for which X am solely and ~~~ Iet~ ly responsible.

._. But I told the grand jury today and I say ta you naw thar at no time did I ask anyone to lie, to

hide tx destroy evidence or to take any other u~~~~ action. X know that my public Wnments and my sifence about this matter gave a false impression. I misled people, including even my wife. T deeply regret that.

I can only tdl you I was ~~~ iva~~ d by many factors, First, by a desire to proten ~~ s~~~ fr~~

the ~rn~~~~~~ rn~ n~ of my own conduct. I was also vety concerned about protecting my family. The fact that these quesCians were being asked in a politically inspired lawsuit, which has since been dismissed, w8. s a consideration, too.

In addition, f had real and serious concerns about an independent counsel investigation that began with private business dealings 20 years ago, dealings, I might add, about which an independent federal agenoy found no evidence of any wr~~ gd~ j~ g by me or my wife over two years ago.

The i~ de~ e~ denr counsel ~vest~ gat~ o~ moved on to my staff and friends, then into my private life. And naw the ~~ vesti~ atio~ itself is under iRve~~~ ga~~ on.

This has gone on too tong, cost too much and hurt too many iranocent people. Nuw, this matter is b& ween me, the two people I Iove most - my wife and our daughter - and our God. I must put it right, and 1 am prepared to do whatever if takes to do so.

~ot~~~~ g is mare imponant ta me persona&. But it is private, and I intend to rec! aim my family tife for my famity. Ws nobody’s business but ours.

Even presidents have private lives. It is time ta stop the pursuit of personal destp> ction and the prying into private lives and get on with our nationa! life.

Our country hai; been distracted by this matter for too long, and I take my res~ o~ s~ b~~~ ty for my par-~ itt ait of this. That is all I can do,

Now it is time - in fact, it is past time - to move on. We have impenant wark to do - real op~~~ u~~ t~~ s to seize, ieat problems ta s& e, rest security matters to f& x.

And 93 tanigtxt, I ask you to twfi &way from the spectacle of the past seven n~ onths, to repair the fabric of~ ur national discourse, and to return our attention to all the challenges and all the promise af the tlext American century

Thank yuu for watching, And goad night.

2524

2525

Tab 76

lMti~ d~- people. . . . I Deeply Regret That’

FoUocoingmPresidrntClM’JmMnkrlarlp~ tonhk

grand jwy tsiimmry and fhe inuutigation by mdepd+ counsel Kenndh W. Stan:

G oodevening. Thisaftemooninthisroom,

fKUlltt+ d&, Ite& Sfd~ theoffice ofIndependentCounselandthe~ jufy. Iansweredtip~, i& xtingqu~ abartmyprivateH~ questioasno Arnericaudtizen~ evetwanttQanswer.

!! Gti& 1musttakecrmpleterespaasibilityf0raamy a& ms, bothpublicandprivate. AndthatiswhyIm speakhgtoyc+ ltD~ t.

Asyaxbw, inadepositioninJsmary~ Iwasasked qll& iOMal. JOUt~ mY~ withMoUi~ r_ ehsky. Whilemyanswers we=& Pb- e, I didnotvolunteeri

. Indeed, IdidixavearelationshipwithMissIewih thatwasI. DtappqhtCIn~~ itwaswrong. It am& htedacxiticallapseinjudgmentandapersonal ~~~ partforwhichIamsolelysndcomplete! y

ButItddthe@ ndjurybdayandIsaytoyounow thatatnotimedidIaskanyxnxtolie, tohideor ~hzviviq~ xe3ke any other unlawhl action.

’ commmtsandmysilence aboutthismattergaveafalsehpression. Imisled people, inclu~ evenmywife. Ideepiyrrgretthat. ’ IcanonlytellyguIwasnlo~ tedbymanyfactors. Fiibyadesifetoprdectmyseiffrom6romthe embarrassmentofmyowncondu& Iwasalsovery ~about~ myfanrsI. The~ ct~ t thesequestionswerebehgaskedina@ ticaUy inspiilawsu& whichhassincebixndismisAwasa consideration. too.

Illadditim, I_~~~~ concanSaboUtaIl ~auasel~ thatbeganwitb phtebrrniness~~ ye; asaga,~ I nlightaddabout~ anindependeotfederal~ formd~ evidence0f~~ oh&$ y~ ormywife -twv==% B ‘J3e~ taxmsel~ movedonto

my& dbdf% iend& thellintomypr+ teIife. Andnow the~ onitselfisunder~

ll. liYhas~ rntookm& casttoomuchaQdhurt toomany hmocentpeople.

Now, thismatterisbetweenme, thetwopeopleI lovemost-+ q+. feaadourdau& tef- andoufGcd. I nlll@ ltitigil~ aIldIalllpRpaRdtodolVhateVe& hkt? StOdoSO. Nothillgis~~ tome pers& ly. Butitisptivate, andIiutendtoredaimmy fam3ylifeformyfamily. It% nobody’sbusincsAut DUlXEVenprrsidentsb; rveprivatetives

Itistimetostopthepof~- sndthepryhgiutoplivatetivt? sandget~ withour nati~ life

ourunmtlyhasbeen~ bythismatterfor tilolgalYldItakelXly~~ mypiTtiUaIl ofthi~ ThatisallIcmdoo. Nowitis~~ itis pastb+ tomwecaL

Wehaveiqxntantworktda- realoppo~ to&, realpto~~ realsecmitymattersto face.

Andsotonigh~ Iaskyoutotumawayfromthe sp& adeofthepastsevenmonths, torepairthfabric ofournationaldbxrse, andtoretumourattentionto aUthechallengesandalthepromiseofthenext Amelicancentury.

Thank ~013 for witching. And good night.

2528

2529

Tab 77

2530

T% is ltttcr seta forth the tmns of agreement betwaa the Department of Justice @paitmcnt). the socrct servi~, and the Of& e of Endcpcndcnt c! mmscI (OK) regarding the OIC’s desire to obtain ix& maim fiam Secret Snvice pasonnel that is rekvant to its Monica I.. awinsky- related bveStigati0n. ThiSagrermcntisdesignedtDfaEilta~~ OIC’sinformation- gatheringproass~ atthcsamttimc, toaLsunthatthcDepartMntandthesccretsrrviu: dischargiq their law ulforWmuIt respomdbtfities ill ZKl approprkte manner.

* from Secret Stivicc Person& Not Previou& Examm cd by the

1. The OIC agree8 to limit the guestiorring of additional Secret &vice persoax4cl by seeking information only &urn those agents and 0ffic0rs who served in a protcctivccapacityiatbcvicinityof~ eovalofficeonsix~~ datts, drping spcc% d timss. T& t Sttrtt Strvict has identified 87 current and 2 retired agats and office; who served in such a qacity. ’ The OIC agrees not to seek information h agents and officers who served in a protective capacity on

&f& rent dates. L& SS, in the future, it receives new -on that provides probable cause to believe that evidence of a crime would be obtained by increasing the number of dates above six or speaking to additional Secret Sentice employees about events that occurred on datw other than the original sir rpccffied dates. The OK agrees that prior to increasing the number of dates above six or speaking to additional Secret Service employees about events that occurred on dates other than the original six specified data, the OK! will provide its basis for doing so, consistent with its obligations under Rule 6( e) of the Federal Rules of Criminal Procedure, to the Attorney Chcral and Director Merleti, who, along with Kenneth W. Starr (and such 0th personnel es each may designate), will enter into good faith discussions on the aetd to iatretse the number of datts. If agreement cannot be reached on the need to increase the number of dates, the dispute will be presented to Chitf Judge Johnson for resolution.

’ To select such personnel, the Secret Service idcntificd: (i) from offkial raxrds the Uniformed Division personnel who were listed as occupying the posts: spccificd by the OIC for thr six spccifkd time periodsV (ii) from Protective Operations Activity and Pcrsonntl reports the Presidential Protcxthe Division person1101 who, for the six specified time periods, were listed as being assigned to the immediate shift pmtccting the Fresiht; and (iii) in an effort to be over inclusive rather than under inclusive, from Protective Operations Activity and Personnel reports the Presidential Protective Division personnel who, for the six specified time periods, were listed as being assigned to a specific Secret Service command center or were Wed as participating in orientation.[ dcletion]

2533

2. 3.

4. 5.

2537

Print your full m. Doyourezalleverspe& ingwithMonicaLNvinsky? Yes No

If your answer to this question is “Yes,” but your conversations with Mop’” Lcwix& wcrr~~ tothccx~ ofcasualgnetingswidlechit- chatabo~ mmatterssuchas the weather. please describe those conversations on a separate page.

Do you recall, prior to January 21,1998, ever observing Monica hwinsky via a Secret Service video camera or closed- circuit monitoring device?

Yes No Do you recall, prior to January 21,1998. ever obsaving Monica Lewinsky and President Clinton together7

Yes No If your snswcr to this question is “Yes,” but your observations with Monica Lewinsky and the President were limited to those at widely- attended events, please describe those obser& ons on a separate page.

Do you recall, prior to Jzinuary 21,1998, ever observing Monica Lewinsky inside, or in the vicinity, of the Oval Of& e suite of offices?

Yes No If your answer to this question is “Yes,” but your observations with Monica Lcwinsky and the President were limited to those at widely- attended events, please describe those observations on a separate page.

Do you recall, prior to January 21,1998, ever braring the President, any current or former White House or Secret Service employee, or any advisor or visitor to the White House

- 2538

(excluding P= dent Cldon's p+ atc am), speak about 01 discuss my one 0f tb

fobvkg five topics: (i) a r~ btkship bctwcm Mania bwbsky and the Prcsidcnt; (ii) Monica LewiDsky being alone with President Clinton at any location; (ii) Monica Lcwinsky b& g inside, or in the Vicinity, of the Oval O& c suite of offices; (iv) Linda Tripp; ~~(~)~ m~ erralatcd~ prtsi~ crinton, MonieaLewinsky, Linda Tripp, or Katbka~ Willey being deposed, submitting a& hits, being a witness in, or otherwise beiag connected with the Paula Jones v. Warn Jeff& on Clrnmpr litigation?

YCS No

1 de& l= under penalty ofperjw, P ImNant to 28 U. S. C. Section 1746. thflt the. foregoiIlg istrucaIldcoIrcct.

Signature P*

2539

Tab 78

2540

2541 Memorandum Office of the Independent Counsel

To. File Due: g/ 27/ 98

Fmm: =_ slsbj~*: Lewinsky interview on 8/ 13/ 98

During the 8113198 interview of Monica S. Lewinsky, Lewinsky asked if she could discuss a particular matter outside the presence of male investigators/ attorneys. Associate Independent Counsel (AK) Karin Irnmergut obliged Lewinsky, and the two left the interview room. After a few minutes, the two returned and the interview resumed. The contents of the interview of 8/ l 3/ 98 are documented in an FD- 302, transcribed on 8/ 14/ 98 by writer.

After the interview, AK Immergut advised writer as to the details of what Lewinsb discussed outside the presence of investigators. Immergut advised that Lewinsky stated that during her November 13,1997 meeting with Clinton, Lewinslq showed Clinton an e- mail. The e- mail described the Lewinsky also brought some Altoids with her and was eating them when she met with Clinton. Clinton told Lewinsky they did not have enough time for oral sex. Lewinslcy told Clinton to at least put his tongue on hers and he obliged.

2542

2543

Tab 79

2544

2545

DAVID E. KENDALL (202) 434- 5145

LAWOFFICES WILLIAMS 6 CONNOLLY

725 TWELFTH STREET, N. W. WASHINGTON, D. C. 20005- 5901 LDt! cmLD e+ ENNE- rTwILLIAMs (, 2) 20-, 9el) 8, PP." L R CONNOLLY 0022., 9, a,

(202) 434- 5000 FAX (202) 434- 5029

August 31, 1998 CONFIDENTIAL RULE 6( e), F. R. CR1M. P. GRAND JURY SUBMISSION

Robert J. Bittman, Esq. Deputy Independent Counsel Office of the Independent Counsel 1001 Pennsylvania Avenue, N. W. Suite 490- North Washington, D. C. 20004

BY Hand Dear Bob:

This will acknowledge your letter dated August 26, 1998. I believe that the President has complied with grand jury subpoenas nos. VO02 and D1415. I will not repeat the comments of my letter to you dated April 13, 1998. As I have previously told you, the President receives a large number of gifts from a great many people. We have done our very best to comply with the grand jury subpoenas. I want to repeat, however, that if you have information concerning gifts or other objects which you think may be responsive to these subpoenas, and if you will give me a description of what those gifts or other objects might be, we will be happy to undertake a search for them, as we have in the past.

Sin rely, ,.: 6, i

\ /’ -, F. I ’ I . c I

David E. K/ zndall

2546

Tab 80

2561

Surfacing Lyrics I’ve crossed the last line From where I can’t return Where every step I took in faith Betrayed me And led me from my home

Sweet surrender Is all that I have to give

You take me in No questions asked You strip away the ugliness That surrounds me Are you an angel Am I already that gone I only hope that I won’t disappoint you When I’m down here on My knees

Sweet surrender Is all that I have to give Sweet surrender Is all that I have to give

And I don’t understand By the touch of your hand I would be the one to fall

I miss the little things Oh I miss everything About you It doesn’t mean much It doesn’t mean anvthing at all The life I left behind me Is a cold room

Sweet surrender Is all that I have to give Sweet surrender Is all that I have to give

Adia

(Sarah McLachlanPierre Marchand) Adia, I do believe I failed you Adia, I know I’ve let you down Don’t you know I tried so hard To love you in my way It’s easy let it go

Adia, I’m empty since you left me Trying to find a way to carry on I search myself and everyone To see where we went wrong

There’s no one left to finger There’s no one here to blame

http:// www. pitt. edul- knrsGisurfacing. html

Surfacing Lyrics There’s no one left to talk to honey And there ain’t no one to buy our innocence

‘Cause we are born innocent Believe me Adia, we are still innocent It’s easy, we all falter Does it matter?

Adia I thought that we could make it But 1 know I can’t change the way you feel I leave you with your misery A friend who won’t betray I pull you from your tower I take away your pain And show you all the beauty you possess If you’d only let yourself believe that

We are born innocent Believe me Adia, we are still innocent It’s easy, we all falter, does it matter? Believe me Adia, we are still innocent ‘Cause we are born innocent Adia we are still It’s easy, we all falter But does it matter?

Do What You Have to Do (Sarah McLachlanKoleen Wolstenholme)

What ravages of spirit Conjured this temptuous rage Created you a monster Broken by the rules of love And fate has lead you through it You do what you have to do And fate has led you through it You do what you have to do

And I have the sense to recognize that I don’t know how to let you go Every moment marked With apparitions of your soul I’m ever swiftly moving Trying to escape this desire The yearning to be near you

I do what I have to do The yearning to be near you I do what I have to do

But I have the sense to recognize That I don’t know how To let you go I don’t know how To let you go

A glowing ember Burning hot

2562

http:// www. pitt. edul- knrst3/ surfacing. html

2563

Surfacing Lyrics Burning slow Deep within I’m shaken by the violence Of existing for only you

I know I can’t be with you I do what I have to do I know I can’t be with you I do what I have to do And I have sense to recognize but I don’t know how to let you go I don’t know how to let you go I don’t know how to let you go

Nitness (Sarah McLachlan/ Pierre Marchand)

Make me a witness Take me out Out of darkness Out of doubt

I won’t weigh you down With good intention Won’t make fire out of clay Or other inventions

Will we bum in heaven Like we do down here Will the change come While we’re waiting Everyone is waiting

And when we’re done Soul searching And we carried the weight And died for a cause Is misery Made beautiful Right before our eyes Will mercy be revealed Or blind us where we stand

Will we bum in heaven Like we do down here Will the change come While we’re waiting Everyone is waiting

Angel

Spend all your time waiting For that second chance For a break that would make it okay There’s always one reason To feel not good enough And it’s hard at the end of the day I need some distraction

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91219%

2564

Surfacing Lyrics Oh beautiful release Memories seep from my veins Let me be empty And weightless and maybe I’ll find some peace tomght

In the arms of an angel Fly away from here From this dark cold hotel room And the endlessness that you fear You are pulled from the wreckage Of your silent reverie You’re in the arms of the angel May you find some comfort here

So tired of the straight line And everywhere you turn There’s vultures and thieves at your back The storm keeps on twisting You keep on building the lies That you make up for all that you lack It don’t make no difference Escaping one last time It’s easier to believe In this sweet madness Oh this glorious sadness That brings me to my knees

In the amrs of an angel Fly away from here From this dark cold hotel room And the endlessness that you fear You are pulled from the wreckage Of your silent reverie You’re in the arms of the angel May you find some comfort here You’re in the arms of the angel May you find some comfort here

Black and White

Unravel me A distant cord On the outside is forgotten A constant need to get along And the animal awakens And all I feel is black and white

The road is long The memory slides To the whole of my undoing I put aside I put away I push it back to get through each day And all I feel is black and white And I’m wound up small and tight

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912198

2565

Surfacing Lyrics And I don’t know who I am Everybody loves you when you’re easy Everybody hates when you’re a bore Everyone is vvaiting for your entrance so Don’t disappoint them

Unravel me Untie this chord The very center of our union Is caving in I can’t endure I am the archive of our failure And all I feel is black and white And I’m wound up small and tight And I don’t know who I am

Everybody loves you when you’re easy Everybody hates when you’re a bore Everyone is waiting for your entrance so Don’t disappoint them

Everybody loves you when you’re easy so Don’t disappoint them

Don’t disappoint them

Full of Grace

The winter here’s cold And bitter It’s chilled us to the bone We haven’t seen the sun for weeks Too long too far from home I feel just like I’m sinking And I claw for solid ground I’m pulled down by the undertow I never thought I could feel so low And oh the darkness I feel like letting go

If all of the strength and all of the courage Come and lift me from this place I know I could love you much better than this Full of grace my love

It’s better this way, I said Having seen this place before Where everything we say and do Hurts us all the more It’s just that we stay too long In the same old sickly skin I’m pulled down by the undertow I never thought I could feel so low And Oh the darkness I feel like letting go

If all of the strength and all of the courage Come and lift me from this place

http:// www. pitt. edu/- knrst3/ surfacing. html 912198

I 2566

Surfacing Lyrics I know I could love you much better than this Full of grace, full of grace, my love

Page 8 of 8 Back to lyrics

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2567

Tab 83

2568 / i

2569 3 2246.. D& lli& f* rchapter

hi ,;

-P+% however slighL of the anal or genital opening of another by any object, with an intent to abwe, humiliat~, harrsq gratifytbesexualdesireofmypemm; or iiomd tmxhing, not thmugb the clothing, of the genitalia of

who haa not attained the age of 16 years with an intent to :, hnnss, degrade, orvouseor~~ thesexund~, of~ y

ml W& ct” means the intentional tonching, either directly or

ofthegenitalia, annnos, gmkbreasfinnerthigb,~~~ f k. enttoabuse, h& liate, h. ms, dqrade, orm’= eorgRtify

nffmm nmim thi. .- hanlpr --_ -_- _ __.

2571

Bates- Numbered Documents

h# lLpILuIILtM CALIFORNIA, U. S.- A. _

2574 L* w OFFICES

JANIS. SCHUELKE & WECHSLER ,728 HASSAC~ USETTS AVENUE. NW

WASHINGTON. D. C. 20036

KARL N. METZNER

ND DJZIYERY

Kenneth W. Starr, Esq. January 23, 1998

Office of the Independent Counsel 1001 Pennsylvania Avenue, N. W., Suite 490- N Washington, D. C. 20004

Re: Subpoena Duces Tecum to Betty W. Currie, Grand Jury # 97- 3

Dear Mr. Starr: In response to the above- referenced subpoena duces tecum to Ms. Betty W. Currie, enclosed please find the following:

One copy of the State of the Union address dated January 23, 1996, in a brown envelope. One autographed photograph of President Clinton, held between two cardboard panels. One green dress with a “Black Dog” logo, size L. One turquoise T- shirt with a “Black Dog” logo, size L. One white T- shirt with a “Seal of the Black Dog of Martha’s Vineyard” on the front, size L.

One blue baseball cap with a “Black Dog” logo. One three- page facsimile message. Two twenty- page newspaper inserts from the Washington Post, February 14, 1997. One jewelry pin in “Casual Comer” box. One hatpin with a globe- like base in a black box with gold stars on it.

824- DC- 00000001

2575

Kenneth W. Starr, Esq. January 23, 1998 Page 2

One framed signed picture of President Clinton and Monica Lewinsky. One bottle, in its box, of Tiffany Spa Moisturizing Hand Cream. One bottle, in its box, of Tiffany Spa Refreshing Body Mist. One sympathy card, with envelope. One card with joke re snowman and carrot, with envelope. One thank- you card dated September 17, 1997, with envelope. Four pages of handwritten notes.

Sincerely, .’ /‘-- <---~ - - :‘./ t , :,/

Karl Metzner” Enclosures

824- DC- 00000002

2576

THE WASHINGTON POST WEEKENDFRIDAY Februarv 14.1997

AAA

2578 U. S. Secret Service uare Or iep” ri

Epass Access Control Reporf oi123t98

Search Criteria: LEWINSKI. MONICA Search Dates: 01/ 01/ 97 to 12l31197

Date Time Name Badge Type Post status _.-_-_ 08/ 01/ 97 10: 46: 17 LEWINSKI, MONICA 34 t. 5v3 c A4 ENTERING

08/ 01/ 97 11: 40: 27 LEWINSKI, MONICA 34F3D3 C D2 EXIYING 08/ 01/ 97 12: 19: 27 LEWINSKI, MONICA 34~ 346 c A4 ENTERING

827- DC- ooooooo2

page: 1

2579

Search Criteria: LEWlNSKY. MONtCA Search Dates: 01101l95 to 12l31l95

Date Tim. 2 Name Badge rype Post status

07/ 10/ 95 13: 18: G2 LEWINSKY, MONICA 34EA68 - D2 ENTERING 07/ 10/ 95 17: 04: 29 07/ 11/ 95 08: 51: 33 07/ 11/ 95 11: 52: 50 07/ 11/ 95 16: 57: 39 07/ 12/ 95 09: 00: 29 07/ 12/ 95 13: 20: 28 07/ 12/ 95 13: 30: 54 07/ 12/ 95 17: 21: 31 ~>/: j/ cj5 no-,*- d” “>.&“_. I

07/ 13/ 95 11: 11: 34 07/ 13/ 95 12: 03: 06 07/ 13/ 95 12: 36: 50 07/ 13/ 95 13: 23: 53 07/ 13/ 95 17: 46: 42 07/ 14/ 95 08: 35: 28 07/ 14/ 95 16: 33: 22 07/ 17/ 95 08: 21: 01 07/ 17/ 95 16: 59: 54 07/ 18/ 95 08: 08: 15 07/ 18/ 95 08: 08: 22 07/ 18/ 95 12: 38: 05 07/ 18/ 95 14: 29: 41 07/ 18/ 95 18: 29: 46 07/ 19/ 95 07: 59: 12 07/ 19/ 95 14: 43: 32 07/ 20/ 95 08: 59: 17 07/ 20/ 95 12: 13: 27 07/ 20/ 95 12: 54: 15 07/ 20/ 95 17: 46: 05 07/ 21/ 95 08: 38: 13 07/ 21/ 95 12: 34: 55 07/ 21/ 95 13: 08: 16 07/ 24/ 95 08: 39: 09 07/ 24/ 95 12: 29: 17 d7/ 24/ 95 13: 36: 02 07/ 24/ 95 17: 31: 47 07/ 25/ 95 08: 28: 5? 07/ 25/ 95 11: 06: 23 07/ 25/ 95 11: 55: 19 ^_,^ r ,^ r _^ __ __ UI/ LS/ Y> lL:- l>: Jb

07/ 25/ 95 13: 49: 0! C7/ 25/ 95 20: 21: 37 07/ 25/ 95 20: 21: 41 07/ 25/ 95 20: 21: 44 07/ 26/ 95 09: 08: 17 07/ 26/ 95 09: 08: 30 07/ 26/ 95 11: 59: 49 07/ 26/ 95 12: 24: 43 01/ 23/ 98

LEWINSKY, UONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINS‘ KY, ‘k! DNICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA. LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA

LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA _-___..-.... ~~_~.__~ LBWINSKY, tlONICA

LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA CEWINSKY, MONICA

34EA68 34E9FF 34E9FF 34EC23 34E9F4 34E9F4 34EAll 34EAll >* CPnA d- sYb" x

34EC04 34EAl8 34EA18 34EAl2 34EA12 34EA54 34EA54 34EA54 34EA54 34EC21 34EC21 34EC21 34EAlE 34EAlE 34E9F5 34E9F5 34EC04 34EC04 34E9C6 34E9C6 34EOB9 34EOB9 34EC23 346948 34E948

34E9Dl 34E9Dl

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34E9DC 34E9BB 34D9BA 34D9BA

ZbZ8 3 34D9BA 34D9BA

34EA2F

827- DCMx)( Moo3 34D9BA 34EF. 2F

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I I I I I N

I I I I I I I I I I I I I I I I I I I I I I N A A

A N A

D2 EXITING D2 ENTERING D2 EXITING D2 EXITING 01 ENTERING D2 EXITING D2 ENTERING D2 EXITING D? ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING Dl ENTERING D2 EXITING ' D2 -ENTERING D2 EXITING 02 INACTIVE D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 EXITING 02 ENTERING D2 EXITING 02 ENTERING D2 . EXITING D2 ENTERING Al EXITING D2 -.- ENTERING D2 EXITING D2 ENTERING A4 INACTIVE A4 ENTERING A4 ENTERING A4 UNAUTH D2 INACTIVE D2 EXITING D2 FYTTTr. c 1I. L I *.. u

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Epass Access Control Report OIl23/ 98

Date Time 07/ 26/ 95 12: 33: 05 07/ 26/ 95 12: 33: 34 07/ 26/ 95 12: 39: 00 07/ 26/ 95 13: 05: 49 07/ 26/ 95 13: 38: 27 07/ 26/ 95 18: 01: 06 07/ 27/ 95 11: 35: 51 07/ 27/ 95 11: 35: 58 O- t/ 27/ 95 11: 36: 16 07/ 27/ 95 12: 15: 22 07/ 27/ 95 13: 14: 52

07/ 2- l/ 95 11: 09: 44 07/ 28/ 95 09: 04: 11 07/ 28/ 95 10: 11: 12 07/ 28/ 95 12: 20: 22 07/ 28/ 95 16: 47: 56 07/ 31/ 95 10: 00: 37 07/ 31/ 95 13: 03: 57 07/ 31/ 95 13: 57: 22 08/ 01/ 95 11: 00: 02 08/ 01/ 95 12: 49: 55 08/ 01/ 95 13: 39: 33 08/ 01/ 95 18: 31: 16 08/ 02/ 95 08: 19: 20 08/ 02/ 95 12: 02: 42 O&/ 02/ 95 12: 39: 58 06/ 02/ 95 17: 5e: 33 08/ 03/ 95 08: 14: 07 OE/ O3/ 95 10: 18: 21 08/ 03/ 95 14: 06: 35 33/ 03/ 95 17: 12: 58 Ci?/ O4/ 95 08: 55: 22 33/ 0:/ 95 13: 55: 34 38/ 04/ 95 17: 22: 12 08/ 07/ 95 09: 07: 46 oa. f07/ 95 09: 31 :i3 08/ 07/ 95 09: 49: 53 08/ 07/ 95 12: 50: 36 08/ 07/ 95 13: 58: 17 Oti/ 07/ 95 17: 27: 48 08/ 08/ 95 08: 58: 27 06/ 08/ 95 12: 57: 57 03/ 08/ 95 13: 54: 45 08/ 08/ 95 17: 01.35 08/ 08/ 95 17: 15: 28 08/ 06/ 95 17: 15: 45 06/ 08/ 95 17: 17: 25 oe/ o9/ 95 07: 39: 34 09/ 09/ 95 12: 33: 41 01/ 23/ 98

Seat- d Criteria: LEWINSKY. MONICA

Search Dates: 01lO1195 to 12l31195

Badge Type Post status 34EB79 D2 INACTIVE LEWINSKY, MONICA

LEWINSKY, HONICA LEWINSKY. MONICA LEWINSKY, MONICA LEWINSKY, HDNICA LEWINSKY, WONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MDNICA LEWINSKY, MONICA LEWINSKY, MDNICA LEWINSKY, MONICA

LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MDNICA LEWINSKY, MONICA LEWINSKY, UONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MNICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, HONICA LEWJNSKY, HONICA LEWINSKY, UONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA

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34EB7A 34EB7A

I I I I N N

I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I

I I I I I N

I I

D2 INACTIVE D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING Dl INACTIVE Dl INACTIVE Dl ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING D2. EXITING D2 ENTERING D2 EXITING D2 ENTERING Dl ENTERING D2 EXITING Dl ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING Dl EXITING D2 ENTERING D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING 02 EXITING D2 ENTERING - -- 02 EXITING

02 ENTERING 02 EXITING D2 ENTERING 02 EXITING D2 INACTIVE D2 ENTERING D2 EXITING D2 ENTERING D2 EXITING.

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2581 u. QF; L. IGL 3GI VIbG EpasYs'Access Control Repoti

Search Criteria: LEWINSW. MONICA Search Dates: OlJO1195 to 12/ 31/ 95

0C3lQ8

Date Time Name bdse Type Post status 08/ 09/ 95 14: 16: 18 34EASB 02 ENTERING

08/ 09/ 95 l-/: 17: 39 08/ 10, '95 09: 12: 12 08/ 10/ 95 12: 24: 33 08, '10/ 95 13: 30: 28 08/ 10/ 95 18: 47: 58 08/ 11/ 95 09: 07: 36 08/ 11/ 95 12: 12: 55 08/ 11/ 95 12: 35: 58 08/ 11/ 95 17: 04: 24 08/ 14/ 95 08: 50: 18 08/ 14/ 95 12: 01: 36 08/ 14/ 95 13: 01: 13 08, '14/ 95 17: 59: 53 08/ 15/ 95 09: 14: 27 08/ 15/ 95 13: 50: 00 08/ 15/ 95 14: 01: 48 08/ 15/ 95 18: 28: 56 08/ 16/ 95 09: 24: 08 08/ 16/ 95 12: 03: 29 08/ 16/ 95 13: 01: 57 08/ 16/ 95 15: 44: 27 08/ 17/ 95 09: 12: 33 08/ 17/ 95 17: 03: 10 08/ 18/ 95 08: 53: 24 08/ 18/ 95 12: 34: 32 08/ 18/ 95 13: 35: 25 08/ 18/ '95 16: 16: 18 08/ 21/ 95 08: 56: 08 08/ 21/ 9: 09: 21: 43 08/ 21/ 95 09: 31: 54 08/ 21/ 95 12: 24: 34 08/ 21/ 95 13: 15: 18 08/ 21/ 95 16: 58: 43 08122195 09; 05: 25 08/ 22/ 95 12: 39: 17 08/ 23195 09: 09: 20 08/ 23/ 95 12: 21: 36 08/ 23/ '95 13: 42: 42 00/ 23/ 95 16~ 34~ 46 00/ 23/ 95 16: 45: 37 08/ 23/ 95 16: 45: 44 08/ 23/ 95 17: 27: 32 08/ 24/ 95 08: 53: 10 08/ 24/ 95 11: 17: 58 08/ 24/ 95 11: 45: 50 00/ 24/ 95 12: 53: 44 08/ 24/ 95 14: 19: 33 08/ 25/ 95 08: 56: 28 01/ 23/ 98

LEWINSKY, MONICA

LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA

LEWINSKY, MONICA LEWINSKY, MONICA

LEWINSKY, MONICA

LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA

LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY. MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY; MONICA LEWINSKY. MONICA LEWXNSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LZWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA

827~ DcMxx> ooo5

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34E94E 34EA66 3444781

I I I I I I I I I I I I I I I I I I I I I

I I I I I I I I I

I I I I I

I I I I I N

I I I I I I I

I 02 EXITING

02 ENTERING 02 EXITING 02 ENTERING 02 EXITING 02 ENTERING 03 EXITING 02 ENTERING 02 EXITING 02 ENTERING Dl .EXITING 02 ENTERING D2 EXITING 02 ENTERING D2 EXITING 02 ENTERING 02 EXITING 02 ENTERING Dl EXITING 01 ENTERING 02 EXITING 02 ENTERING 03 EXITING 02 ENTERING 03 EXITING 01 ENTERING 02 EXITING 02 ENTERING D3 EXITING 02 ENTERING 01 EXITING

01 ENTERING

02 EXITING

02 ENTERING

D2 EXITING

02 ENTERING

01 EXITING

02 ENTERING

02 EXITING

02 INACTIVE

D2 ENTERING

D2 EXITING

02 ENTERING

D2 EXITING

02 ENTERING

D2 EXITING

01 ENTERING

D2 ENTERING

2582 __ A. atbIt& 3Gd w4- I;

Epass Access Control Report 01/ 23/ 98 Date

Search Criteria: LEWlNSK’t’. MONICA Search Dates: 01101195 to 12l31195

Time Name Badge Type Post status 34A781 D2 EXITIt;: 08/ 25/ 95 12: 14: 36 08/ 25/ 95 14: 01: 31 08/ 25/ 95 15: 25: 39 08/ 28/ 95 09: 17: 53 08/ 28/ 95 12: 34: 14 08/ 28/ 95 13: 15: 34 08/ 28/ 95 17~ 23~ 37 08/ 30/ 95 10: 04: 25 08/ 30/ 95 12: 15: 11 09/ 01/ 95 13: 27: 22 09/ 01/ 95 15: 04: 14 09/ 01/ 95 15: 38: 51 09/ 05/ 95 08: 47: 29 09/ 05/ 95 12: 57: 14 09, '05/ 95 13: 44: 06 09/ 05/ 95 13: 44: 09 09/ 05/ 95 18: 37: 47 09/ 06/ 95 07: 59: 41 09/ 06/ 95 12: 12: 43 09/ 06/ 95 13: 26x42 09/ 06/ 95 16: 00: 00 09/ 11/ 95 08: 52: 21 09/ 11/ 95 12: 08: 06 09/ 11'/ 95 13: 43: 48 09/ 11/ 95 18: CO: 13 09/ 12/ 95 10: 23: 21 ^..,.^ ,^,. UY/ IL/ Y~ i2: 24: 04

09/ 12/ 95 15: 10: 54 09/ 12/ 95 17: 08: 20 09/ 13/ 95 09: 58: 16 09/ 13/ 95 10: 14: 02 09/ 13/ 95 12: 15: 30 09/ 13/ 95 12: 24: 00 09/ 14/ 95 11: 34: 16 09/ 14/ 95 12: 39: 37 09/ 14/ 95 13: 15: 46 09/ 14/ 95 18: 04: 48 09/ 15/ 95 11: 46: 52 09/ 15/ 95 13: 11: 23 09/? 5/ 95 17- 74.31 Le.<...__

09/ 15/ 9> 17: 08: 03 09/ 18/ 95 09: 56: 11 09/ 18/ '95 13: 00: 34 09/ 18/ 95 13: 38: 45 09/ 18/ 95 18: 36: 35 09/ 19/ 95 09: 52: 57 09/ 19/ 95 12: 00: 13 09/ 19/ 95 13: 38: 59 09/ 19/ 95 16: 42: 35 01/ 23/ 90

l. FWTN’= ZKY MnNTrll -_..*.._.._, .<_.._“.,

LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA

34EA70 34EA70 34EA55 34EA55 34EA3B 34EA3B 34EA24 34EA24 34EA60 34EA4F 34EA4P 34E9BB 34E9BB 34E9BO 34E9BO 34E9BO 34C3D3 34C3D3 34E9FO 34E9FO 34EAOl 34EAOl 34EA6F 34EA6F 34EB86 _.__^_ J4EBUb

34EC07 34EC07 34EC07 34EC07 34EC07 34ECO7 34EB92 34E092 34EB8D 34EB8D 34E9C9 34E9C9 TAFPcl< _- IY""_

34EB05 34E9D2 34E9D2

34EB76

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I I I I I I I I I I I I I I I A A

I I I I I I I 1 I I I I I I I I I I I I I I I I I I I I I I

D2 D2 D2 D2 D2 D2 D2 02 D2 D2 D2 D2 D2 D2 D2 D2 D2 02 n2 D2 D2 D2 D2 D2 D2 DZ 02 D2 D2 D2 D2 D2 D2 Dl D2 D2 D2 D2 D? D2 D2 D2 Dl D2 D2 D2 D2 DZ

ENTER;! iG EXITIE;; ENTERING EXITIE- .s ENTERING EXITING ENTERING EXITING EXITING ENTERING EXITING ENTERING EXITING ENTERIh'G MOLT EtsT EXITING ENTERI);" b EXITING

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2583 “. QCGI CL 3G& VlClC

Foa& Access Control R-- W

Search Criteria: LEWINSKY. MONICA Search Dates: 01101195 to 12n1l95

01mJ98

Date Time Name Badge rype Post status 09/ 20/ 95 09: 10: 26 LEWINSKY, MONICA 34EB71 T ' ENTFRTMc _..__..*.. Y

09/ 20/ 95 12: ll: OS 09/ 20/ 95 13: 23: 18 09/ 20/ 95 15: 21: 59 09/ 29/ 95 10: 39: 34 09/ 29/ 95 11: 33: 28 09/ 29/ 95 12: 54: 12 09/ 29/ 95 ?6: 24:: 0 10/ 02/ 95 13: 29: 44 10/ 02/ 95 17: 36: 20 10/ 04/ 95 09: 34: 58 10/ 04/ 95 13: 26: 30 10/ 04/ 95 14: 56: 04 lo/ lo/ 95 09: 16: 18 10/ 10/ 95 12: 55: 46 10/ 11/ 95 09: 14: 40 10/ 11/ 95 12: 11: 43 10/ 13/ 95 12: 22: 43 10/ 13/ 95 14: 12: 27 10/ 16/ 95 1O: OO: lO 10/ 16/ 95 13: 09: 37 10/ 16/ 95 13: 58: 43 10/ 16/ 95 16: 21: 36 lO/ i7/ 95 10: 11: 05 lOii7/ 95 14: 14: 42 10/ 17/ 95 14: 33: 03 10/? 7/ 95 15: 29: 02 :!- j/: 7/ 95 :9. EO." C ._ lo.- ic_ l

lO/ i7/ 95 20~ 43~ 47 lO/ iB/ 55 09: 29: 35 10/: 8/ 95 12: Ol: SO 10/ 18/ 95 12: 40: 27 10/ 18/ 95 15: 54: 30 10/ 19/ 95 12: 24: 37 10/ 19/ 95 12: 59: 20 10/ 20/ 95 08: 49: 45 10/ 20/ 95 12: 06: 14 10/ 20/ 95 18: 56: 17 10/ 20/ 95 18: 59: 54 11/ 06/ 95 09: 10: 39 1:/ 06/ 95 12: 23: 50 11/ 06/ 95 13: 05: 35 11/ 06/ 95 i3: 05: 46 11106195 16: 26: 48 11/ 06/ 95 16: 32: 55 11/ 06/ 95 16: 35: 52 11/ 07/ 95 10: 52: 47 1l, 'C7/? 5 12: 36: 11 liiC7/ 45 13: 17: 49 01/ 23/ 98

LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA 1 CWTLlCY" U,?\ LITPII Yfi" LL. cl‘\ l, L‘ I" I.. L~~

LEWINSKY, MONICA LEWINSKY, MONICA LEWIN'SKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEHI f& SKY i_ iONICA LEWINSKY: MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY. MONICA

34EB71 34F26C 34F26C 34E9BF 34E9BF 34EA40 -s. l-. m. r\ J9Lfi. I"

34C698 34C698 34EABD 34EC06 34EC06 34F24C 34F24C 34EA64 34EA64 34F263 34F263 34E9D3 34E9D3 34F24C 34F24C 34EAD3 34EAD3 34EA21 34EA21 _Il_-.,._ _( 4VlrL

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34BDF9 34BDF9

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34E952 34A3C4

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I I I I I I I I I I I I I I I I I I I A A

I I I I I I I I I I I I N

I I I I I I I

D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 D2 Dl Dl D2 A4 A4

Dl D2 D2 D2 D2 Dl

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EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING INACTIVE ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING

2584

~. a. secfe~ 3efwce Epass Access Control Reporf Oll23i98

Search Criteria: LEWINSKY. MONICA Search Dates: 01101195 to 12i31195

Date Time Name Badge Type Post status i:/ o7/ 95 14: 46: 13 LEWINSKY, MONICA 34A3C4 D2

:1/ 07/ 95 16: 05: 05

1;/ 07/ 95 19: 39: 56

l?/ O8/ 95 08: 54: 24 11/ 08/ 95 11: 14: 43 11/ 08/ 95 12: 26: 29 ll/ O8/ 95 13: 07: 45 ll, 'O8/ 95 18: 29: 02 11/ 09/ 95 09: 22: 03 11/ 09/ 95 12: 48: 14 1l/ O9/ 95 13: 48: 15 l1/ 09/ 95 18: 05: 26 ll/ 13/ 95 09: 29: 13 11/ 13/ 95 11: 31: 52 11/ 13/ 95 13: 32: 08 11/ 13/ 95 21: 35: 26 11/ 14/ 95 08: 50: 42 11/ 14/ 95 08: 50: 53 1?/ 14/ 95 20: 11: 54 11/ 15/ 95 13: 30: 07 11/ 15/ 95 17: 07: 20 1!/ 16/ 95 0O: lE: Ol 1:, '16/ 95 09: 01: 46 11/ 16/ 95 12: 27: 45 11/ 16/ 95 14:; 7: 52 11/ 17/ 95 08: 15: 50 11/ 17/ 95 20: 55: 36 11/ 17/ 95 21: 37: 36 1x/ 17/ 95 22: 38: 33 11/ 18/ 95 09: 04:. 49 11/ 20/ 95 09: 05: 38 11/ 20/ 95 12: 48: 37 11/ 20/ 95 15: 23: 26 11/ 20/ 95 17: 55: 37 11/ 20/ 95 18: 16: 58 11; 20/ 95 20: 23r05 1!/ 21/ 95 09: 16: 35 !;/ 21/ 95 16: 23: 50 11/ 22/ 95 08: 59: 39 11/ 22/ 95 14: 45: 32 11/ 24/ 95 13: 41: 20 11/ 24/ 95 17: 47: 43 11/ 2- J/ 95 07: 44: 10 11/ 27/ 95 08: 55: 59 1 l/ 27/ 95 10: 42: 58 llr’27/ 95 1!: 01: 20 li: 27/ 95 20: 36: 42 11: 23/ 95 0?: 46: 58 11: 79/ 95 07: 5!: 46 01/ 23/ 98

LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA

LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY. MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA

34A3C4 34A3C4 34F289 34A092 34A092 34EA26 34EA26 34EA08 34EA08 34AE80 34AE80 34F253 34f253 34EA63 34EA63 34EC08 34EC08 34EC08 34DAF5 34D944 34D944 34DAEC 34DAEC 34E31B 34DA03 34DA03 34D9A3 34D9A3 34C5lD 34F263 34F263 34EA38 34EA38 34E9EA 34E9EA 34E9EF 34E9EF 34CCEE 34CCEE 34E9C3 34E9C3

ZS2<& 3 34EC21 34C91B

34c910

827- Dc- ooooooo8 34~~ 88 34EC88 34ECC4 34ECC5

I I I I I I I I I I I I I I I I I I I A A A A

A A A A A A A

I I I I

I I I I I I I

I I A A

D D D D

02 D2 D2 D2 D2 D2 B4 02 D2 D2 D2 Dl D2 D2 B4

D2 D2 D2 A4 A4

B4 A4 A4 A4 A4

84 B4 B4 A4

D2 84 02 Dl Dl D2 D2 D2 02 D2 D2

02 D2 Kl

Kl D2 02 D2 D2

EXITING ENTERING EXITING ENTERING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING MULT ENT EXITING ENTERING ENTERING EXITING ENTERING EXITING ENTEG< NG ENTERING EXITING ENTERING EXITING ENTERING ENTERING EXITING ENTERING EXITING ENTERING EXITING' ENTERING EXITING ENTERTUG EXITING ENTERING EXITING ENTERING ENTERING EXITING ENTERING EXITING ENTERING ENTERING

2585 u_ ~Gsu‘ C& WC8 V# bC

Epa& Access Control Report 01123196 Search Criteria: LEWlNSKY. MONICA Search Dates: 01/ 01/ 95 to 12lw95

Date Time Name Badge rype Post status 11/ 29/ 95 iO: 23: 21 LEWINSKY, MONICA 34ECC5 Al MULT f!: T

11/ 29/ 95 ?3: 21: 36 11/ 29/ 95 13: 33: 25 11/ 29/ 95 14: 08: 45 11/ 29/ 95 16: 36: 51 11/ 29/ 95 17: 01: 46 11/ 3o/ 95 07: 39: 56 11/ 30/ 95 09: 21: 45 11/ 30/ 95 09: 44: 55 11/ 30/ 95 09: 51: 43 11/ 30/ 95 10: 03: 17 11/ 30/ 95 14: 30: 41 11/ 30/ 95 15: 09: 56 11/ 30/ 95 20: 00: 41 12/ 01/ 95 07: 53: 12 12/ 01/ 95 19: Sl: Ol 12/ 04/ 95 08: 11: 04 12/ 04/ 95 08: 43: 52 12/ 04/ 95 08: 54: 17 12/ 04/ 95 12: 27: 26 12/ 04/ 95 12: 42: 28 12/ 04/ 95 19: 37: 05 12/ 05/ 95 07: 39: 45 12/ 05/ 95 12: 01: 22 12/ 05/ 95 12: 27: 31 12/ 05/ 95 17: 09: 29 12/ 05/ 95 19: 13: 18 12/ 06/ 95 07: 40: 59 12/ 06/ 95 10: 05: 34 12/ 06/ 95 16: 43: 58 12106195 16~ 45~ 37 12/ 06/ 95 19: 13: 57 12/ 07/ 95 00: 12: 23 12/ 07/ 95 15: 26: 46 12/ 07/ 95 16: 19: 08 i2/ 08/ 95 07: 43: 38 12/ 08/ 95 13: 40: 24 12/ 08/ 95 14: 20: 39 12/ 08/ 95 15: 57: 46 12/ 08/ 95 17: 50: 34 12/ 08/ 95 21: 19: 26 12/ 11/ 95 07: 43: 56 12/ 11/ 95 19: 35: 10 12/ 12/ 95 08: 10: 12 12/ 12/ 95 17: 59: 09 12/ 12/ 95 18: 12: 32 12/ 12/ 95 21: 25: 57 :2/ 13/ 95 07: 48: 37 12/ 13/ 95 13:! 2: 35 01/ 23/ 98

LEWINSKY, MDNICA S LEWINSKY, MDNICA S LEWINSKY, MDNICA S LEWINSKY, MONICA S LEWINSKY, b! ONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MDNICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY. MONICA S

34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629

P P P P P

P P

P P P P P P P P P P P P P P P P P P P P P P P P P P P P P

P P

P P P P P P

P P

ACB ENTERIYG Al EXITIt:; Al ENTER": G _. Al EXITIt:;; Al ENTERING D2 ENTERZNG A5 EXITIE;; Kl ENTERING Kl EXITIKS D2 ENTERING Al EXITING Al ENTERING Al EXITING D2 ENTERING D2 EXITING D2 ENTERING A5 -EXITING 02 ENTERIN' u Al EXITING Al ENTERIfZ A5 EXITING D2 ENTERIt:; A5 EXITING Al ENTERM'; A5 EXITING D2 ENTERIN; D2 ENTERING A5 EXITING Al ENTERItiZ Al EXITING Al ENTERING Al EXITING A5 EXITING Al EXITING D2 ENTERIN; Al EXITING Al ENTERING Al EXITING Al ENTERING A5 EXITING D2 ENTERING D2 EXITING D2 ENTERING Al EXITING Al ENTERING A5 EXITING D2 ENTERING Al ENTERING

2586 v. d. 3cclr CL &CA VILC

Epass Access Control Report

Search Criteria: LEWINSKY. MONICA Search Dates: 01101195 to 12/ 31/ 95

OlR3l98

Date Time Name Badge Type Post status

34A629 Al EXITING 12/ 13/ 95 19: 39: 58 12/ 14/ 95 07: 58: 02 12/ 14/ 95 12: 48: 55 12/ 14/ 95 20: 21: 49 12/ 15/ 95 07: 54: 04 12/ 15/ 95 11: 13: 27 12/ 15/ 95 19: 40: 09 12/ 16/ 95 12: 01: 40 12/ 16/ 95 13: 31: 50 12/ 16/ 95 13: 32: 14 12/ 16/ 95 14: 27: 54 12/ 17/ 95 13: 23: 04 12/ 18/ 95 07: 56: 49 12/ 18/ 95 11: 04: 21 12/ 18/ 95 11: 16: 33 12/ 18/ 95 12: 36: 08 12/ 18/ 95 19: 59: 49 12/ 19/ 95 08: 35: 47 12/ 19/ 95 11: 27: 22 12/ 19/ 95 11: 36: 20 12/ 19/ 95 12: 40: 52 12/ 19/ 95 12: 58: 48 12/ 19/ 95 12: 59: 00 12/ 19/ 95 20: 17: 46 12/ 20/ 95 07: 54: 21 12/ 20/ 95 08: 08: 44 12/ 20/ 95 08: lS: ll 12/ 20/ 95 12: 31: 15 12/ 20/ 95 12: 45: 53 12/ 20/ 95 18: 05: 09 i2/ 21/ 95 1O: lO: OO 12/ 21/ 95 13: 03: 22 12/ 21/ 95 20: 18: 04 12/ 22/ 95 08: 00: 29 12/ 22/ 95 15: 07: 43 12/ 22/ 95 15: 24: 10 12/ 22/ 95 18: 19: 44 iZ/ 26/ 95 16: 36: 18 12/ 26/ 95 18: 16: 51 12/ 26/ 95 19: 06: 48 12/ 26/ 95 19: 58: 24 12/ 28/ 95 07: 58: 28 12/ 28/ 95 08: 31: 49 !2/ 28/ 95 08: 39: 36 12/ 28/ 95 11: 56: 47 12/ 2B/ 95 15: 09: 27 12/ 28/ 95 15: 24: 38 12i28/ 95 20: 20: 53 12/ 29/ 95 08: 17: 07 01/ 23/ 98

LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA- S LEWINSXY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINS: KY, MONICA S LEWINSKY, MONICA S LEWINSKY, 'MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSXV, MONICA S

34A629 34A629

827~ DC- oooooo10 34A629 34A629 34A629

P P P P P P P P P P P P P P e P P P

P P P P P P P P

P P P P

P P P

P P P P P P

P P P

P D2 ENTERING

D2 EXITING A5 EXITING D2 ENTERING A5 EXITING A5 EXITING A5 EXITING D2 EXITING D2 ENTERING A5 EXITING A5 EXITING D2 ENTERING A5 EXITING 02 ENTERING Al- EXITING D2 EXITING D2 ENTERING D2 EXITING D2 ENTERING Al EXITING Al BAD PIN Al ENTERING D2 EXITING D2 ENTEKING 02 EXITING D2 ENTERING A5 EXITING D2 ENTERING A5 EXITING D2 ENTERING Al EXITING D2 EXITING D2 ENTERING Al EXITING Al ENTERING A5 EXITING D2 ENTERING D2 EXITING D2 ENTERING 02 EXITING D2 ENTERING D2 EXITING D2 ENTERING Al ENTERING Al EXITING Al ENTERING 02 EXITING D2 ENTERING

2587 u. 3. 3GLl GL 3t= l VlGtif

Epass Access Control Reporf

Search Criteria: LEWlNSKY. MONICA Search Dates: Ol/ Olt95 to 12/ 31/ 95

Oll23/ 98

Date Time Name bdse rype Post status 12/ 29/ 95 12: 13: 04 LEWINSKY, MONICA S 34A629 P Al EXITING 12/ 29/ 95 16: 35: 13 LEWINSKY, MONICA S 34A629 P Al EXITING 12/ 29/ 95 16: 47: 53 LEWINSKY, MONICA S 34A629 P Al ENTERING 12/ 29/ 95 19: 35: 49 LEWINSKY, MONICA S 34A629 P D2 EXITING 12/ 29/ 95 21: 09: 40 LEWINSKY, MONICA S 34A629 P AS EXITING 12/ 31/ 95 13: 15: 44 LEWINSKY, MONICA S 34A629 P A5 EXITING

827~ Dc- oooooO11

01/ 23/ 90

2588 V. “b”. Gr UC1 I*- w

Ep&‘ Access Control Report 01123l98 Search Criteria: LEWlNSKY, MONICA Search Dates: 01101196 to 12/ 31/ 96

Date Time Name Badge Type Post status 01/ 02/ 96 08: 13: 05 LEWINSKY, MONICA S 34A629 P 01/ 02/ 96 14: 18: 09 01/ 02/ 96 20: 46: 55 01/ 03/ 96 08: 11: 20 01/ 03/ 96 13: 46: 34 01/ 03/ 96 13: 54: 07 01/ 03/ 96 19: 42: 08 01/ 04/ 96 08: 15: 43 01/ 04/ 96 12: 27: 12 01/ 04/ 96 12: 47: 25 01/ 04/ 96 19: 23: 36 01/ 05/ 96 08: 11: 57 01/ 05/ 96 14: 28: 35 01/ 05/ 96 19: 51: 21 01/ 06/ 96 13: 00: 17 01/ 06/ 96 15: 22: 42 01/ 09/ 96 11: 51: 45 01/ 09/ 96 12: 02: 03 01/ 09/ 96 19: 44: 48 01/ 09/ 96 19: 46: 06 01/ 09/ 96 20: 02: 11 01/ 10/ 96 08: 36: 45 01/ 10/ 96 15: 32: 24 01/ 10'/ 96 17: 25: 15 01/ 11/ 96 08: 34: 09 01/ 11/ 96 11: 44: 54 01/ 11/ 96 11: 55: 34 01/ 11/ 96 19: 29: 10 01/ 12/ 96 08: 39: 11 01/ 12/ 96 08: 42: 54 01/ 12/ 96 08: 55: 20 01/ 12/ 96 16: 42: 45 01/ 15/ 96 19: Ol: Sl 01/ 16/ 96 08: 23: 30 01/ 16/ 96 16: 16: 53 01/ 16/ 96 16: 22: 09 01/ 16/ 96 18: 39: 20 01/ 17/ 96 07: 58: 33 01/ 17/ 96 15: 49: 29 01/ 17/ 96 !5: 56: 26 01/ 17/ 96 22: 29: 15 01/ 18/ 9$ 07: 51: 05 01/ 18/ 96 15: 37: 16 01/ 18/ 96 ?5: 46: 53 01/ 18/ 96 20: 55: 28 01/ 19/ 96 08: 05: 59 01/ 19/ 96 10: 29: 29 01/ 19/ 96 12: 36: 18 01/ 19/ 96 12: 56: 19 01/ 23/ 98

LEWINSKY, MONICA S

LEWINSKY, KONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA i LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S

34A629 ENTERING 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629

;; zL;) 2 34A629 34A629 34A629

827- DC- OWOOO12 34A629

34A629 34A629 34A629 34A629

P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P P

P P P P P

P P P P P P P P P P P

D2 Al A5

02 D2 D2 A5

D2 Al Al A5 .D2

Al D2 D2 D2 D2 D2 D2 D2 D2 D2 Al

A5 D2 D2 D2 02 D2 D2 D2

D2 A5

D2 D2 D2 A5

02 D2 D2 A5

D2 D2 D2 A5

D2 D2 Al Al

ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING ENTERING EXITING EXITING EXITING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING EXITING ENTERsiJG EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING ENTERING EXITING ENTERING

2589

Epass Access Control Report 01123198

Search Criteria: LEWINSIW. MONICA Search Dates: 01101196 to 1201196

Date Time Name Badge Type Post status 01/ 19/ 96 20: 30: 04 LEWINSKY, MONICA S 34A629 EXITING 01/ 21/ 96 15: 56: 01 01/ 22/ 96 07: 52: 30 01/ 22/ 96 15: 16: 03 01/ 22/ 96 17: 18: 04 01/ 22/ 96 19: 53: 43 01/ 22/ 96 20: 15: 37 01/ 22/ 96 23: 28: 02 01/ 23/ 96 07: 20: 11 01/ 23/ 96 13: 17: 20 01/ 23/ 96 13: 32: 04 01/ 23/ 96 15: 38: 08 01/ 23/ 96 20: 10: 14 01/ 23/ 96 20: 27: 25 01/ 23/ 96 22: 41: 34 01/ 24/ 96 18: 48: 25 01/ 25/ 96 08: 21: 59 01/ 25/ 96 16: 38: 54 01/ 25/ 96 16: 48: 58 01/ 25/ 96 19: 38: 54 01/ 26/ 96 10: 03: 25 01/ 26/ 96 15: 20: 41 01/ 26/ 96 15: 23: 42 01/ 26/ 96 15: 27: 58 01/ 26/ 96 15: 30: 14 01/ 26/ 96 18: 16: 48 01/ 30/ 96 08: 07: 25 01/ 30/ 96 13: 08: 19 01/ 30/ 96 13: 28: 05 01/ 30/ 96 20: 44: 31 01/ 31/ 96 07: 49: 23 01/ 31/ 96 16: OO: OS 01/ 31/ 96 16: 06: 46 01/ 31/ 96 18: 46: 32 02/ 01/ 96 08: 02: 52 02/ Oi/ 96 14: 09: 03 02/ 01/ 96 14: 19: 50 02/ 01/ 96 21: 05: 07 02/ 02/ 96 07: 50: 56 02/ 02/ 96 10: 36: 16 02/ 02/ 96 10: 45: 16 02/ 02/ 96 12: 48: 36 02/ 02/ 96 13: OS: ll 02/ 02/ 96 18: 46: 53 02/ 05/ 96 08: 03: 01 02/ 05/ 96 19: 53: 49 32/ 06/ 96 08: 21: 36 32/ 06/ 96 18: 30: 58 32/ 07/ 96 07: 54: 30 01/ 23/ 98

LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MO& CA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S

P P P P P P P P P P P P P P P P P P P P P

P P P P P P P P P P P P P P P P P P P P P P P P P P P

D2 A5

D2 D2 D2 D2 04 84 D2 D2 D2 A5

D2 D2 A5

D2 D2 D2 D2 A5

D2 A5

Kl Kl D2 D2 D2 D2 D2 D2 D2 A5

D2 D2 02 A5

D2 A5

D2 D2 D2 Al Al

D2 D2 D2 D2 D2 D2

EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING EXITING ENTERING EXITING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITI- NG ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING

2590 _. YIY. w. “b, . rh- L Epas~ 'Access Control Report 01123198

Search Criteria: LEWINSKY. MONICA Search Dates: OlIO1196 to 1213ll96

Date Time Name Badge Type Post status 02/ 07/ 96 15: 45: 32 LEWINSKY, MONICA S 34A629 P EXITING 02/ 07/ 96 15: 51: 51 02/ 07/ 96 19: 21: 05 02/ 00/ 96 19: 52: 35 02/ 09/ 96 07: 55: 40 02/ 09/ 96 07: 55: 51 02/ 09/ 96 12~ 49~ 33 02/ 09/ 96 12: 56: 56 02/ 09/ 96 19: 21: 03 02/ 12/ 96 08: 05: 17 02/ 12/ 96 17: 27: 12 02/ 12/ 96 17: 39: 26 02/ 12/ 96 19: 25: 37 02/ 13/ 96 oa: lo: 38 02/ 13/ 96 17: 12: 52 02/ 13/ 96 17: 19: 36 02/ 13/ 96 19: 10: 02 02/ 14/ 96 08: 04: 02 02/ 14/ 96 12: 58: 46 02/ 14/ 96 18: 47: 25 02/ 15/ 96 oa: oo: 47 02/ 15/ 96 16: 48: 53 02/ 16/ 96 08: 24: 57 02/ 16/ 96 18: 54: 29 02/ 20/ 96 08: 05: 10 02/ 20/ 96 19: 51: 48 02/ 21/ 96 08: 07: 35 02/ 21/ 96 17: 18: 39 02/ 21/ 96 17: 30: 10 02/ 21/ 96 21: 36: 11 02/ 22/ 96 08: 18: 16 02/ 22/ 96 14:; 4: 10 02/ 22/ 96 14: 43: 35 02/ 22/ 96 19: 10: 32 02/ 23/ 96 08: 21: 12 02123196 20: 24: 44 02/ 24/ 96 09: 41: 57 02124196 10: 13: 34 02/ 24/ 96 16: 31: 37 02/ 24/ 96 17: 26: 31 02/ 26/ 96 08: 04: 5a 02/ 26/ 96 19: 28: 47 02/ 27/ 96 0a: oz: lo 02/ 2- J/ 96 19: 13: 44 02/ 28/ 96 08: 23: 36 02/ 28/ 96 08: 55: 57 02/ 28/ 96 22: 29: 21 02/ 29/ 96 08: 38: 01 02/ 29/ 96 19: 57: 12 01/ 23/ 98

34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34~ 629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629

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34A629 34A629

827- DC- oooooO14 34~ 629

34A629 34A629 34A629 34A629

P P P P P P

P P P P

P P P P P P P P

P P P

P P P P P P P P P P P P

P P P P P P

P P P P P P P

P P

02 D2 D2 D2 D2 D2 D2

D2 D2 D2 D2 D2 D2

D2 D2 D2

D2 D2 Al

D2 D2 D2

DZ D2 D2

D2 D2 D2

D2 A5

D2 D2 D2 A5

02 D2 D2

D2 D2 D2

D2 Al

Al A5

D2 DZ

ENTERING EXITING EXITING BAD PIN ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING ENTERING EXITING EXITING ENTERING EXITING

2591

Search Criteria: LRMNSKY. MOfWA Search Dates: OlIO1196 to 12/ 31/ 96

Date Time Name Badge T- YE= Post status 03/ 01/ 96 09: 25: 01 LEWINSKY, MONICA S 34A629 D2 ENTERING 03/ 01/ 96 12: 07: 12 03/ 01/ 96 12: 20: 21 03/ 01/ 96 l- 7: 36: 49 03/ 04/ 96 07: 57: 49 03/ 04/ 96 07: 57: 58 o3/ 05/ 96 Oa: O2: 52 o3/ 05/ 96 19: 23: 27 03/ 05/ 96 19: 23: 33 03/ 05/ 96 20: 56: 11 o3/ 06/ 96 Oa: O3: 23 03/ 06/ 96 20: 20: 26 03/ 06/ 96 20~ 22~ 16 03/ 06/ 96 20: 33: 23 03/ 07/ 96 08: 01: 49 03/ 07/ 96 20: 11: 23 03/ 08/ 96 08: 35: 55 03/ 08/ 96 la: 40: 01 03/ 10/ 96 14: 39: 52 03/ 11/ 96 07: 29: 59 03/ 11/ 96 11: 46: 54 03/ 11/ 96 12: 02: 50 03/ 11/ 96 16: 28: 48 03/ 12/ 96 07: 49: 31 03/ 12/ 96 19: 04: 42 03/ 13/ 96 07: 56: 08 03/ 13/ 96 la: 57: 21 03/ 14/ 96 Oa: O8: 33 03/ 14/ 96 12: 19: 49 03/ 14/ 96 12: 34: 28 03/ 14/ 96 19: 28: 23 03/ 15/ 96 07: 52: 5a 03/ 15/ 96 17: 54: 41 03/ 16/ 96 15: 39: 49 03/ 16/ 96 15: 52: 27 03/ 17/ 96 16: 43: 33 03/ 18/ 96 oa: D2: 43 03/ 18/ 96 12: 50: 09 03/ 18/ 96 13: 26: 12 03/ 18/ 96 21: 31: 08 03/ 19/ 96 oa: lo: 39 03/ 19/ 96 21: 04: 33 03/ 19/ 96 23: 57: 20 03/ 20/ 96 08: 13: 03 03/ 20/ 96 19: 57: 07 03/ 21/ 96 oa: 22: 30 03/ 21/ 96 20: 09: 29 03122196 07: 54: 28 03/ 22/ 96 10: 53: 32 01/ 23/ 98

LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY. MONICA S LEWLNSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY. MONICA S

34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A623 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 34A629 '34A629

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2592 U. 0G- r s; c 3GA VAcrC

Ep& Access Control Reporf 01/ 23/ 98 Search Criteria: LEWNSKY. MONICA Search Dates: 01/ 01/ 96 to 12l31/ 96

Date Time Name Badge rype Post status 03/ 22/ 96 11: 48: 26 LEWINSKY, MONICA S

03/ 23/ 96 09: 01: 46

03/ 23/ 96 09: 01: 53 03/ 23/ 96 10: 21: 43 03/ 23/ 96 10: 25: 00 03/ 23/ 96 10: 25: 05 03/ 23/ 96 14: 11: 45 03/ 24/ 96 10: 47: 46 03/ 24/ 96 11: 13: 10 03/ 24/ 96 11: 13: 14 03, '24/ 96 21: 29: 48 03/ 25/ 96 07: 42: 24 03/ 25/ 96 12: 31: 03 03/ 25/ 96 12: 35: 52 03/ 26/ 96 07: 53: 43 03/ 26/ 96 12: 10: 33 03/ 26/ 96 12: 22: 15 03/ 26/ 96 19: 45: 21 03/ 27/ 96 08: 05: 19 03/ 27/ 96 11: 29: 57 03/ 27/ 96 11: 49: 47 03/ 27/ 96 19: 07: 40 03/ 27/ 96 21: 16: 58 03/ 28/ 96 08: 12: 17 03/ 28/ 96 17: 57: 38 03/ 28/ 96 18: 12: 20 03/ 29/ 96 08: 04: 11 03/ 29/ 96 08: 04: 17 03/ 29/ 96 20: 55: 41 03/ 31/ 96 10: 20: 40 03/ 31/ 96 16: 27: 13 04/ Cl/ 96 12: 31: 59 04/ 01/ 96 18: 50: 51 04/ 02/ 96 07: 53: 01 04/ 03/ 96 07: 58: 13 04/ 03/ 96 18: 48: 19 04/ 04/ 96 08: 04: 50 04/ 04/ 96 18: 32: 37 04/ 05/ 96 08: 05: 09 04/ 05/ 96 13: 13: 03 04/ 05/ 96 13: 13: 03 04/ 05/ 96 13: 42: 17 04/ 05/ 96 18: 20: 57 04/ 07/ 96 10: 47: 52 04/ 07/ 96 14: 51: 05 04/ 07/ 96 16: 56: 44 04/ 07/ 96 17: 28: 39 04/ 09/ 96 11355335 06/ 07/ 96 12: 50: 54 01/ 23/ 98

LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S

LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA LEWINSKY, MONICA

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Epass Access Control Report

Search Criteria: LEVVlNSKY. MONICA Search Dates: 01/ 01197 to 12f31l97

ov23t98

Date Time Name Badge Type Post status

O2/ 24/ 97 09: 38: 25 LEWINSKY, MONICA 34 DBD7 ENTERIcG o2/ 24/ 97 10: 32: 24 02128197 17: 48: 21 02/ 28/ 97 19: 07: 08 03/ 13/ 97 10: 01: 22 o3/ 13/ 97 10: 15: 27 03/ 13/ 97 21: 21: 24 03/ 13/ 97 21: 48: 33 o3/ 29/ 91 14: 02: 57 o3/ 29/ 97 15: 16: 10 04/ 16/ 97 09: 48: 36 04/ 16/ 97 09: 55: 38 05/ 01/ 97 17: 42: 48 05/ 02/ 91 19: 57: 03 05/ 02/ 97 20: 21: 08 05/ 24/? 7 12: 20: 39 o5/ 24/ 97 13: 5x: 30 05/ 30/ 97 15: 32: 18 o5/ 30/ 97 16: 01: 29 06/ 11/ 97 10: 57: 54 06/ 11/ 97 12: 04: 04 06/ 16/ 97 14: 47: 23 06/ 16/ 97 16: 10: 45 06/ 24/ 97 18: 59: 02 06/ 24/ 97 19: 18: 42 07/ 04/ 97 08: 51: 20 o7/ 14/ 97 21: 33: 40 o7/ 14/ 97 23: 22: 3o o7/ 16/ 97 10: 45: 36 o7/ 16/ 97 11: 41: 51 o7/ 24/ 97 18: 04: 29

07/ 24/ 97 18: 26: 48 08/ 16/ 97 09: 01: 53 08/ 16/ 97 10: 20: 04 09/ 11/ 97 18: 58: 35 09/ 11/ 97 19: 05: 42 09/ 12/ 97 19: 40: 54 09112197 20: 22: 23 09/ 22/ 97 19: 11: 24 09/ 22/ 97 19: 25: 02 10/ 11/ 97 09: 36: 45 10/ 11/ P+ 10: 54: 24 11/ 13/. 97 18: 20: 43 12/ 06/ 97 12: 52: 09

LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA S LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY. MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA LEWINSKY, MONICA zz- I~ 0 LEWINSKY, MONICA LEWINSKY, MONICA 12/ 06/ 97 13: 36: 02 LEWINSKY, MONICA 12/ 15/ 97 11: 31: 12 LEWINSKY, MONICA 8274X- 00000018

12/ 15; 97 12: 38: 52 LEWINSKY, MONICA 12/ 28/ 97 08: 16: 26 LEWINSKY, MONICA

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01/ 23/ 9e

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06117197 05123197 05123197

1 O/ 24/ 97 1 O/ 29/ 97 10129l97 1 o/ 30/ 97 11103197 11105/ 97 11 /17/ 97

1 li2OJS7 1 li18/ 97

11105/ 97 1 l/ l 3197 11114197 11123197 1 l/ l 7/ 97

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ROOM 212A 12: 48 6.3

ROOM 212A 12: 34 1.6

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10: 0& I 3.0 ROOM 720B

16: 37 0.0 ROOM 7208

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ROOM 212A 1558 0: 01: 06

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ROOM 215 14: 51 0: 05: 18

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ROOM 215 17: 14 0: 03: 00

UNATTACHED 16: 44 0: 06: 36

ROOM 212A 12: 30 0: 01: 18

ROOM 215 12! 22/ 97 IS: 16 o: oc: 2c

DESTINATIO WASZ 18 VA WASZ 16 VA WASZ 16 VA

WASZ 1B VA WASZ 18 VA

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l- 703- 697- 931 2 0. 4153 SPARE SPA

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EXEC 10121 I97 19: Ol 0: 05: 42

1 o/ 27/ 97 1 o/ 30/ 97

EXEC- C 17: 15

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828- DC-

2597

10/ 21/# 7 TL’E IS: 09 F. U 302 456 1210 DEB1 SCilIff @ou2

Manica S. Lewtneky

EdUCatiOn:

Lewis and Clark College Pw Ore& m Bachelor of tjcicnce in Paychdoff May 1995

Ekpcriena: Department of Dafense The hltapoA l% abiq@ n D. C.

~~ A# ir~ bLhc~ irLonl~~ ofDtfurnfbr~ lieAJfoitr Apa 1996 - prement . !kme M +& ml vlaistant to the Asaistunt Seuetaxy ofDefemc @SD) for Public AEairn in rapport of his dual role aa both DepPrtment of Defiaae spokermun xnd heed of Department ofDe6Enee Pub& AffEinl. Assist iz m- ,__ paring tk ASD tm bi- weekly preys briefinge. Interact with the rutitmal p& t and

broadc& media ml the ASV6 behalf Proti the ASD With ekncly Up& tea Of CurrSnt media 6t& es. Ad ae bison with the 05~ er of the Scuttazy, the Whita Houee, other Cabinet Secmtaries and the

National &curie CaunciL Provide rtrpport to the Secretpry of Defense and Atuietant Secrtwy on hplent in~ tiod travel which includes a contingent of traveling media. Handle the wr d& schedule and correspondence.

The ~bib House Wasbingtma D. C.

Scuff ~rristun~ LO Director of I+ dhtiw A#& Co~ p+ ncc, November 1995 - April1996

Wruta drafts and cmespondhce 6ca haffSea= etaxy’o qxwal and ultimately the Preeidea’n signature. &isb oftea required reaeeprch of various Administration ii; uee and pobziea. Coordinated mass XIX& g6 b Ccmgrcia &K the RaideAt and other senior Administration afkiah. Prarssed and vetted all incoming mail to the President kn Congxrs. Trained and eupctid new intarna on White

House procedure and preparation of White Rouse correspondence.

The White House Wa& ngku~ D- C.

Summer h& m ~f,+ icz Of the chi4Zf0fstoff. &dy - November 199s

Drafted form Iettere and indbidurl rmponaee fix the Chief of& Be rign~~. Acted a~ a’liakm &r Chief of ScafTo ofi& to other Whitd Hoooc ofEccr. Cabinet agencieo,. a. ad cOngresui& al o& es. Updated o& x manual SuperGad and cnordinated intern and volrtnt& sta8.

Metropolitan Public Dafendcrs Portland, Oregon

Altematiucr Sg, February - May 1995

Implemented new p~ j% bology expert n& renclc tcchniquen. A. sri& d attorncF in klinp viable alternatives to prison fix their clienta. D& ct. ed clients in rucceseful eearch for support, shelter, food and traneportation. Updated hlea on re~) urce materials.

Southeast Mend Health Network (Practicum) Portland. Oregon Socialization Sbff A. ubtamt, Jan- - June 1994

Aaaitted staff in teaching tialization skiIla to mentaUy il3 clienta to cane their integration back into rociety. Updared clienti’ confidential reporb. Coordinated fund raising to benefit extra- cm&& r theatre activities.

Additional Information: ~~- oooooo12

l ZSSCI Clenrance: Current

l Proficient in Mxintcmh for Microsoft Word 6.0. WordPerfect foi Windows 5.2. Quorum, nnd Lpfosla

2598

Monica S. Lewinsky rn~

3 November 1997 The Honorable Bill Richardson U, nited States Ambassador to the United Nations 799 United Nations Plaza New York, New York 10017

Dear Ambassador Richardson: It was a pleasure meeting with you last Friday morning. I know how very busy and demanding your schedule is; I particularly appreciated your taking the time to speak with me.

It was an honor to meet you. The US Mission to the United Nations is certainly in good hands with you at the helm.

Again, thank you for your time. Sincerely,

Monica Lewinslq

2599

5: 15 PM Principals meeting on Iraq, White House 8 A 7: 00 .PM Mike Parker 2445 RHOB (a_) OVERNIGHT WATERGATE

7: 30 AM a: 30 AM 9: oo AM 9: 30 AM 1o: oo AM 10: 30 AM 11: 15 AM 11: lS AM

11: 30 AM 12: 00 PM 12: 30 AM 1: 00 PM

2: 00 PM 3: 00 PM 3: 30 PM 4: 00 PM 6: 40 PM

FRIDAY, OCTOBER 31, 1997 (HALLOWEEN)

Meeting with Monica Lewinsky, Watergate

Ben Gilman 2449 RHOB q- 1 Xavier Becerra 1119 LHOB (q- b Nita Lowey 2421 RHOB 6) Bill Hefner 2470 RHOB (T- Al Ike Skelton 2227 RHOB (I_ Bob Clement 2229 RHOB (4- B) Ed Pastor 2465 RHOB ( a- 1 Please change to noon if Livingston cancels

Tom DeLay H- 107 Capitol (4- 1 Rod Grams Bob Matsui 2308 RHOB tim- 1 Speaking Engagement - Earthkind, National Press Club (Luncheon begins at Noon) . _.

Depart Washington Arrive New York Meeting of the P- 5 re Iraq, UN Room C- 209 Security Council Interview - CNN, Floor 461 E& th Avenue, 20th Q

828- DCUOOOOO23

2600

Monica Lewinsky

13January1998 \ AN 1. 4 1997 Ms. Jenna Sheldon Manager, Corporate StaEng REVLON 625 Madison Avenue New York, New York 10022 Bu fax:-

Dear Jenna: I am SO excited about joining the team at Revlon. I think it’s going to be great!

The following are two references from my employment at both the Pentagon and the White House. Please feel free to contact them Mr. Bacon is currently

traveling with Seaxtary Cohen in Asia and will return to the States on the 22nd of January. I would prefer you speak with him vice his deputy.

The Honorable Ken Bacon Assistant Seaetary of Defense

for Public Affairs - Please contact Colonel Ed Mr. Bacon.

The Honorable John Hi& y

Assistant to the President for Legislative Affairs

Please let me know if you need any more information Sincerely,

ToTa_ P. O1

2601

11 Deccmba 1997 Mk RichardE. HaIperin EvP& sp& alcoonscltothePr& cIIt Mac- & Forbes 35East62ndStrut E; cwYork, NcwYork 10021

DcarMr. Halpcrirx

I am F! dixlg at the suggstion of VaIlonJotdae, who ha! j $p& al wi& you onI!! ly kbalf:

Mbst recently, I bavE been working for the Honorable Ken &con, dx Atsistant SXIWIY of Dcfknsef~ E% lwc~, as~ primary- My responsibilities xaiqe. fkom’jnkmc& g wiyh the media an his b& 3& to providing #ldhhz& ve assist8ncc on the &tzrcay of Dcfcnse’s iz! cmai and txips, to assembling tirndy tqxUcs of cutwan media stories. My prior tscpak~ cc Was at the White House in bgklativt AfEiks and the Chiefof Stags Ofik. PIease. see the enclosed resume for further derail.

I am moving to New York and am socking empioymcnt to begin the first of the y& x. I am r& y and available to speak with w& ever in your office you tight deem qpropziatc. I will follow up

with a phone tail to your o& c on Mondrr/, Ikczmbcr IS+& .1997. Tlldc you for time.

Monica S. Leuinsky CC: Mr. Vernon Jo. xian

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15 2 W2 c 1lrW or- 16- W w: m 01- 01- m 1131175 VtUY UlCIKD. PLO CALL mn Rlcuf AUY.

1J 2 w2 c ii: os ol- u- ve m: oa ai- 01- m 1631175

Is ULL IID( llr acme- 13 2 002 c 07t45 01- 16- W Do: 00 01- 01- m ra5117s 4 CALL IUKI ASAP.

11 2 w2

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1. 2 w2 c 2D: lV Ol- 15PI 0o: oo Ol- 01- m 1631175 - AT wo( f.

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11 2 WI lEllRYllG YM CALL. c lada 01- 15- w 0o: oo 01- 01- 70 1~ 311~~

15, 2 902 .sE CALL UT ASAP. c IA: 22 01- 15- 98 DD: DD Ol- 01- m 1631175

13 2 w2 c lb: O? 0%. ii- OI 0o: oo 01- 01- m tat1n .D UPLW CALLED. PLEASE CALL w Al NOY I#&- Al IK.

11 2 w2 c 12: s 01- 15- w DoI 01- a- 70 lMl17s

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13 2 wt c 1D: lV 01- 15- W 0O: OO 01- 01- 70 15117S

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IS 2 W2 c 0722 Ol- 15- w 0o: oo 01- 01- 70 1511w ASE CALL FRAUCII CARTEX 0 v-

2 W2 C IT: 52 Ol- U- 9S oO: M 01- 01- 70 ‘La331175 &A. PLEASE GALL Ml 0 -

2 092 c 15: 18 m- 13- 811 m: oD Ol- 01.7u ws7l'zI LL Y UWLY VW CAM Al- DEBRA

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1s 2 992 c 1S: dJ Ol- 13- 9a DD: DD Ol- 01- m 1& sllR A, LE CALL UM YWEY Ial CAY.

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13 2 wi! c O?: IO 01- m- w, 0o: oo Ol- 08- 70 lrnlT75 ,( yIIs &# f PEBLE tar OoJn WI TO SEE buJflNG fca vat IY WE LuJlT. Kw

13 2 WY4 c 2O: Zl 01- 19- 911 0e: m 01- 01- 70 lrnollT1s

p‘ aa w‘ WII tlW1 AbUY, IF Yo1 IfE YlX Ill A IEETIYC. IT’ 5 IRtEWf. 13 2 w2 PLEASE CALL fun. c 1854 Ol- IV- 98 M: W 01- 01- 70 1831175

13 2 w2 c 17311 oi- iv- WJ mm 01- 01- m iluim ?‘ EAPL ULL Km.

11 2 wi?

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(3 2 c 1s: ss 01- 18- 96 DD: M 01- 01- m lull75 *Ire rIasLEDAY a op2 CALLED. PLEASE CALL WIB MCI AT Ym CWVE IIlEMCE.

13 2 w2 c ii: 44 oi- 19- 91~ Do: 00 oi- 01- 10 rssrt- rr

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13 2 wz c 10: 19 01- 19- 98 MroD OT- 01- w 1831175 RbYL m ULL K YWEY s* iE Qff WQY. Wlrx

13 2 w2 c 1o: w 01- 19- 98 0o: oo 01- 01- 70 laIJ115 PlUK U“ BILL GII# SWRG Ala-.

1s 2 w2 E 08: 45 01- 19- w 0a: oa 01- 01- 70 1& 5llrs IT IS ItIKE AGAfY. PLEASE IUStT W AU0 CALL ME.

13 2 wt c 08:¶ 6 01- 19- w oo: w 01- 01- 70 lJ!, slI~ lifts *IKE. I AM Croy. PLEASE CALL nEE.

1J 2 wt c M: l6 01- 19- 98 DO: 00 Rl- 01- 70 la1175 PLEASE CALL Y .KXDIY AT d- k

13 2 992 c 07:% Of- 19- w! 0o: m 01- 01- 70 llJ$ l175 PLEASE U‘ L HR. WDAY AI _-

13 2 w2 c 06: x? Ol- 19- 9e o& o0 01- 01- 70 la31175 I’ M m. PLEASE CAL‘ rrE. *JKE

13 2 Wi! c 05: 51 01- 19- 90 M: rn 01- 01- m la1175 Rft fliC# d KAY. PLEASE CALL, JJAvt: toQ) MEWS.

13 2 w2 c 05~ 44 Ol- 19- 90 m: oo 01- 01- m l& 31173 PLEASE CALL SAIL UL: FUlLI ERIQIKT.

15 2 WZ uv IS AT HmIE. PLEASE UlL c m: c1 01- 19- 96 0o: oo 01- 01- 70 111J11n

1J 2 w2 c OL: ST Ol- 19- VI3 0o: OP 01- 01- 70 1113’ 11% C‘ LA# CALL KAT AT WUIE. IT’ S A SOCIAL CALL. TMJ~ K IOJ

11 2 w2 c OS: 33 01-( 9- 911 0o: W oi- 01- m tmu1ln P‘ OAW ULL CAT 4T m.

1s 2 W2 c OS: 08 01- 19- 98 0o: w 01- 01- 70 lIu117s PLEASE CALL KAY.

13 2 w2 c a: 02 01- 19- 9~ 0o: oo 01- 01- 70 lJJlllT5 P‘ EAR C& L KAT AT IKW Al JJrM TNJS SQYIYC.

42 47 63 10 45 42 Y 27

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2604

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.- 11 UK 2m. c t2: w 01- w- a oo: oo 01- 01- m 1as1rlZ;

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13 2 w2 c a: 49 01- 03- a ALLI tS IME- PLEASE CALL-

13 2 w2 c a:% 01- 02- 96

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mm oi- 01- m 1011~

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0o: OO 01- 01- 70 lull75 akm 01- 01- m 1Ullrs

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13 2 w2 c 07: rl 12- 2&- V7 oO: oO 01- 01- 70 l& S1175 I Y AUUE. ULL *L.

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13 2 w2 c 1x: 17 12. zc- 1T 0O: w Ol- Ol- TO 18311n PLEASE ULi. na.

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2605

&N- 28- 98 WED 13 : 39 Retai I Saies

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c 13: 22 ll- 26v7 0o: oa 01- 01- m IIullA 13 2 992 c 12: OT 1*- 26- n Do: 00 Ql- w- m lllJll‘ r5

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13 2 w2 c lL: cs 11- b- W 0o: w 01- 01- m 1@ 3117s PLEA& E CALL MAWA.

3 1 992 c tw: z* 11- 25- w ODE00 01- 01- m 1Ullzi ,111 CAGE rem WC.

3 1 WL c or: sr 11- 24- w 0o: oo Ol- 01.? o lull? 5 LELOOY TO VOI MY ALWA w! SW IEIVXCE. tlu WUER IS-

f% NO. 6196549i30

_____.___._-.-.....-_________ 1__________........................................

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2606

Monica S. Lewinsky 6 November 1997 Mr. Vernon Jordan Akin. Gump, Strauss, Hauer & Feld 1333 New Hampshire, NW Washington, DC 20036

Dear Mr. Jordan: Itwas a real pleasure meeting with. you. I know how very busy and demanding your schedule is: I particularly appreciated your taking the time to speak with me.

I feel compelled to mention how overcome I was by your genuineness. While some people wear their heart on their sleeve; you appear to wear your soul. It made me happy to know that our friend has such a wonderful confidante in you.

I believe I may have neglected to mention that while my current position is administrative, I am seeking more substantive work in my next position.

Thanks again for your time, and I look forward to hearing from you upon your return.

Sincerely, Monica S. Lewinsky

2607

I* imIoc RIIIl weti Copv “- ,mH.- a* cw------..-- -.-_--_*--_----.---..-_---...----.--------*------.------ I-” C-__*.*_--

832- DC- oOOOOOO5

2608 SENi BY: XerOX ~eIe: opl~ y,!~, O21 ; A- 10- 98 ; 1: 07p~ ; 2122iiiYCL- .I LdL;; COuiJL*; -

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832- DC- 00000004

2609

24 June 1997 Dear Betty: Since I have not been able to get in touch with him, I am taking the unorthodox liberty of sharing my concerns with you. I would very much appreciate it if you could relay this information to him either verbally or by letting him read this note. If you’ re not comfortable doing either, I understand.

The intention of this note is not to ‘ tattle- tale”, but to clarify. My meeting with Marsha was not at all what I expected. While she was very pleasant, she questioned me endlessly about my situation. Despite the fact that she already knew why I had to leave, she asked me to tell her about it, asked if I had acted “inappropriately” and why I wanted to come back. She seemingly knew nothing about my current position. She didn’ t know of any openings and said she would check with the people in Communications. He said to me that he had told her I had gotten a bum deal, and I should get a good job in the West Wing. I was surprised that she would question his judgment and not just do what he asked of her. Is it possible that, in fact, he did not tell her that? Does he really not want me back in the complex ? He has not responded to my note, nor has he called me. Do you know what is going on ? If so, are you able to share it with me?

I did not cause any trouble when I had to leave last year because I knew how important the election was. He promised me then I could come back after the election, and I have been counting on him. I think I have been more than patient since it has now been eight months since the election, not to mention the seven months prior to November that I waited. Shall I continue to be patient?

Betty, I am very frustrated and sad. I especially don’ t understand this deafening silence, lack of response and complete distancing evidenced by him. Why is he ignoring me. 3 I have done nothing wrong. I would expect that behavior like this might be directed toward an “unfriendly”, but certainly not to me. I would netrer do anything to hurt him.

I am hoping to hear from either of you soon. I’ m at a loss, and I don’ t know what to do.

Best wishes.

2610

Tripp, Linda, , OSD/ PA From: lo: !Mect:

: Tripp, Linda, , OSD/ PA

Lewinsky, Monica, , OSD/ PA RE: hi, ya Wednesday, March 05, 7997 11: 34AM

Are you asking me if the tie if really pretty? It is positively gorgeous. l am knot (ha!) particularly into ties, but from my exposure to you, I am developing an interest. Yours was stupendous, no kidding, clean, crisp,

texture, color, pattern, bright, without being at all over the top..... a total hit. w- From: Lewinsky, Monica, , OSWPA To: Tripp, Linda, , OSDfpA

Subject: hi, ya Date: Wednesday, March 05, 1997 lO: D5AM Priority: High

Boy, 1 look so scary today. People might think that I thought it was Halloween. Oh, well- should (if Betty is niceJ get my tie today. I sure hope he like s it. make me feel better and tell me it’ s really pretty, o. k.? msl

833- DC- 0018! 57

Page 1

2611

Tripp, Linda, , OSD/ PA From: Tripp, Linda, , OSD/ PA To: Lewinsky, Monica, , OSD/ PA Subject: RE: where are you? Date: Monday, March 03, 1997 12: 48PM

Kate is faxing me a copy of the announcement -- she is planning to go see Marsha today. If someone in house wants it, there is a chance they will get it, but Kate seems confident that that won’ t happen. She said to have your resume ready. LRT _-- me--

From: Lewinsky, Monica, , OSD/ PA To: Tripp, Linda, , OSD/ PA Subject: where are you? Date: Monday, March 03, 1997 12: 21 PM Priority: High

Hello, where are you? I am sorry i was such a pain before but this is all very stressful for me. write back. i don’ t know what’ s goin on. msl

833- DC- O0001876 Page 1

2612

Tripp, Linda, , OSDlPA From: Tripp, Linda, , OSD/ PA To: Lewinsky, Monica, , OSD/ PA Subject: RE: ADVICE Date: Monday, February 24, 1997 11: 22AM

Eureka!?!? ---..*-----

From: Lewinsky, Monica, , OSD/ PA To: Tripp, Linda, , OSDlPA Subject: ADVICE Date: Monday, February 24, 1997 8: 31 AM

Hi, I hope you’ re feeling better ! I ‘ m trying to go over to the WH today to give Jodie these pictures. I also plan to stop by Betty’ s office to drop off these lame photos. Any advice/ suggestions what to do or say? write me back... msl

833~ Dc- oooo1906 Page 1

2613

Tripp, Linda, , OSDlPA From: Tripp, Linda, , OSD/ PA To: Lewinsky, Monica, , OSD/ PA Subject: RE: secret message Date: Wednesday, February 19, 1997 9: OlAM

WELCOME BACK!!! How was Jolly, Olde England? Well, here’ s the saga in a nutshell. On friday (of course), Howard County (the boondocks where I live) was totally and completely snowed and iced in, so I couldn’ t get up my hill, schools were closed, no one moved, believe it or not. I was in a panic about the papers..... by the time I could get up the hill late that night, all the Posts were gone, BUT I called work and had my Deputy save me what he could, which was one, and then I found another, so we have two. I can’ t believe it became that big a deal, but it did. CALL ME WHEN YOU GET IN. PS It read beautifully, placement was great, typeface totally effective, and text superlative..... good job. LRT ---- mm----

From: Lewinsky, Monica, , OSD/ PA To: Tripp, Linda, , OSDfPA Subject: RE: secret message Date: Thursday, February 13, 1997 1: 23PM

O. K. here is my fax in London 01144- l 71- 235- 4552 and phone, just in case, I don’ t know what, here is the phone number 011- 44- l 71- 235- 2000. I will also be checking my messages in the hopes that the creep will call and say” Thank you for my love note. I love you. Will you run away with me?” What do ya think the likelihood of that happening is? Also, please don’ t forget about the newspapers. I will bring you the S later.

thanx... xoxoxo... msl From: Tripp, Linda, , OSD/ PA To: Lewinsky, Monica, , OSDlPA Subject: RE: secret message Date: Thursday, February 13, 1997 1: 03PM

Ah, but that has already transpired, says my omnipotent crystal ball . . . . . . . . . . . . . . . . . . . . . . . . ___---_^_- From: Lewinsky, Monica, , OSD/ PA To: Tripp, Linda, , OSDlPA Subject: RE: secret message Date: Thursday, February 13, 1997 11: 05AM Priority: High

IF ONLY I COULD PURSUADE THE CREEP AS EASILY! l!!!!! -------**- From: Tripp, Linda, , OSDfPA To: Lewinsky, Monica, , OSD/ PA Subject: RE: secret message Date: Thursday, February 13, 1997 11: 03AM

OK OK OK. 12 at bridge.

833- DC- 00001934

From: Lewinsky, Monica, , OSD/ PA To: Tripp, Linda, , OSDlPA Subject: RE: secret message Date: Thursday, February 13, 1997 10: 18AM Priority: High

I’ LL PROBABLY GO GET LUNCH AT 12; 00 BECAUSE I’ M HUNGRY ALREADY!!! l DON’ T THINK I’ LL BE MORE THAN l/ 2 HOUR BECAUSE I’ M LEAVING EARLY. PLEASE ESCAPE WITH ME!!!!!! HOW CAN YOU RESIST ME?? DON’ T FORGET I’ LL BE GONE FOR AWHILE... MSL ----------

From: Tripp, Linda, , OSDlPA To: Lewinsky, Monica, , OSD/ PA Subject: RE: secret message

Page 1

2614

Tripp, Linda, , OSDlPA From: Tripp, Linda, , OSDlPA To: Lewinsky, Monica, , OSD/ PA Subject: RE: Afternoon Date: Tuesday, February 04, 1997 2: 55PM

None of the above, if you ask me. Because, none of it makes sense. Do not despair, there is most definitely light at the end of this tunnel. LRT

From: Lewinsky, Monica, , OSD/ PA To: Tripp, Linda, , OSD/ PA Subject: RE: Afternoon Date: Tuesday, February 04, 1997 2: 15PM Priority: High

Thank God for you! Oh Linda, i don’ t know what I am going to do. I just don’ t understand what went wrong, what happened? How could he do this to me? Why did he keep up contact with me for so long and now nothing, now when we could be together? Maybe it was the intrigue of wanting something he couldn’ t have (easily) with all that was going on then? Maybe he wanted to insure he could have variety and phone sex while he was on the road for those months? AAAAHHHHH!!!!! I am going to lose it! And, where is Betty’ s phone call? What’ s up with all this shit? oh, well. bye. msl

From: Tripp, Linda, , OSD/ PA To: Lewinsky, Monica, , OSDfPA Subject: Afternoon Date: Tuesday, February 04, 1997 2: 06PM Priority: High

Just checking in, it‘ s been a nutty day so I haven’ t had much chance to see you. I had to go up to the third floor and drop off some paperwork, so I actually walked the entire E- ring, which took I5 minutes, Guess I am kinda slow, huh? Oh well, next time I will go by myself so that I can keep my own pace. I feel as though I did SOMETHING anyway. I have had tons of water the past few days, and even more today, so watch and see, I’ ll have gained weight tonight, at this rate. I don’ t seem to be getting rid of the water, so it’ s hanging out somewhere!! Anyway, my real purpose in jotting off this e- mail is to see what’ s up with you, and how you’ re doing. I am so jealous that you are off to London soon, I love it so. I would spend tons of time in Harrod’ s, spend time on Fleet Street and down in the Silver Vaults, putter around Portebello Road, and shop til I dropped!! I would have high tea every day even if I had to skip real meals. I used to spend all my summers in Europe as a kid, and would sneak over to London whenever I could, always by myself, when I was about 16. Back then (I’ m dating myself!!!) you could buy the all time BEST fish and chips from these little holes in the wall, wrapped in newspaper !! It was one of the best things I had ever eaten. LRT

Page 1

2615

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51- 0100- 013 ARLINGTON VA \ SF- 8 ISSUED. ~= CXOOO2716 .SF- 2810 ISSUED. ‘ LUMP- SUM PAYMENT TO BE MADE FOR ANY UNUSED ANNUAL LEAVE. FORWARDING ADDRESS: -

.bALTR BENEFITS C0VRRM. Z IS EWRNDED FOR 31 DAYS DURI? JG U'liICE YOU ARE ELIGIld TO CtjNVQT b AN INDIVIDUAL POLICY (NONGROUP CONTRACT).

YODRFREBCOVRRAGRFORDP To 18tfONTRS. F

YOU ARE ALSO ELIGIBLE FOR TEXPORARY CONTINUATION SON FOR RESIGNATION: S& ICING EMPLOYMENT OPPORTUNITIES OUTSIDE THE GOVERNmaT.

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2616

Confidential Assistant to the Assistant Secretary of Defense for Public Affairs (GS- 301- 09)

This position is located in the Office of the Assistant Secretary of Defense for Public Affairs. The Assistant Secretary of Defense for Public Affairs (ASD (PA)) is the principal staff assistant and

advisor to the Secretary of Defense on all DOD public affairs programs and activities and on the internal information and related activities of the American Forces Information Service. He is

responsible for establishing and implementing policies and systems necessary for the effective and economical performance of DOD public affairs and internal information programs, including those of the military departments.

The incumbent of this Schedule C position will have access to highly confidential, sensitive and frequently politically controversial information and must be a person in whom the ASD( PA) -_ has complete trust and confidence. This close relationship is that

of a Confidential nature required for Schedule C exception. 833~ DGoo2880 As COnfidential Assistant, the incumbent provides secretarial and administrative support directly to the ASD( PA) in key areas of his ongoing official and administrative responsibilities.

On behalf of the ASD( PA), maintains contact at primary management levels within the DOD on personal and special taskings. This includes contacts with the office of the Secretary of Defense, the Organization of the Joint Chiefs of Staf, f, the Secretariats of the

military departments, defense agencies and similar DOD components. In addition, incumbent may represent the ASD( PA) in personal and confidential contacts with members of Congress and civilian industry executives.

Travels uith the ASD( PA) and Secretary of Defense, providing secretarial and administrative support to the ASD and other members of the Secretary's traveling group, as required

Participates in all ASD( PA) staff meetings and directors' meetings. Conducts fact- finding research and summarizes and arranges the data in formars preferred by the ASD( PA) . When background material is

2617

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= 33 BELGIUM FRANCS - m_ __ L 875 = I POUND

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DD FORM 13512, AUG 1997 IEG) SF 1012 12. fl. MAY BE USED “NTIL SUPPLY IS EXHAUSTED

2618

cargo handling equipment needed? Will the baggage be loose or palletized? How wilt the bags be marked - will there be some sort of uniform tag on each bag identifying its owner? How and when are the Civic Leaders leaving Eglin on May 8th - i. e. are they departing on military air?

Concerning the Ramada: 1 sort of doubt that the brochure from the Ramada will fax very well - how about if I mail one to you? Give me an address and I’ ll do just that.

Concerning Gifts: Is OSD paying us up to $25 per 60 JCOC participants for gifts?

Concerning JCOC participants: When can I expect to get a list of JCOC participants? On the list of participants, 1 need to know their SSNs for the MEGP letters (permission to fly on AF aircraft). Will there be any handicapped individuals? We would like to know of any special medical conditions such as history of motion sickness, asthma, cardiac, diabetes etc. Wit1 that kind of info be availabie?

In General: Do you expect full up dress rehearsals for each of your advance trips? Will the 10 OSD support personnel be going on the demos on May 7 & 8? Did you already get a representative base photo from us? If not, when do you need one? Do you need any bios from us now? Am I required to provide videographers for the visit?

I noticed the comment concerning the “Persian Gulf” vs the “Arabian Gulf”. Is that a problem for this trip, i. e. will there be any Arabians in the group?

V/ R, Hart Frankfin Tripp, Linda, , OSDlPA From: tewinsky, Monica, I OSD/ PA To: Tripp, Linda, , OSD/ PA Subject: I’ m back! Date: Wednesday, February 19, 1997 8: 09AM Priority: High

LRT--- Hi, I missed you!!!? I hope you enjoyed your few days of sanity with me gone because I’ m back and NOT in good spirits.

1. I have a small present for you. Everything was SO0000 expensive so I’ m sorry it’ s small. 2. Nice that the Big Creep didn’ t even try to call me on V- day and he didn’ t know. for sure that 1 was going to London.

3. He could have called last night and didn’ t. He was out of town. 4. Finally, the Babba went away and it was the same night he was gone. Fuck me!!!! HHHEEELLPPP!!!! Maybe we can have lunch or meet sometime today CUT I want to give you your present. Bye... msl

Page 62

2619 -

Befl Atlantic TEMPO MDR for 7036979312 per DTS- W Request dated 24 FEB 98 ORIG- TN DESTJN DURATION Start date- time ________ L_ -e-- w---------- ------..-- ---------------_---_----------~------- 7036979312 7036979312 7036979312 7036979312 7036979312

7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312

7036979312 7036979312 7036979312 7036979312 7036979312 7036979312

7036979312 7036979312 7036979312 7036979312 7036939312 7036979312 7036979312 7036979312 7036979312 7036979312

7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 -7036979312 Page: 9

000: 00: 13 21NOV97 20: 03: 09 000: 00: 33 22NOV97 12: 13: 18 000: 10: 38 22NOV97 12: 14: 20 000: 05: 09 22NOV97 13: 18: 43

000: 02: 31 22NOV97 14: 33: 48 000: 22: 22 22NOV97 14: 51: 32 000: 00: 19 22NOV97 15: 24: 37 000: 09: 14 24NOV97 07: 43: 33 000: 22: 08 24NOV97 07: 55: 02 000: 06: 44 24NOV97 10: 14: 17 OOO: OO:. lO 24NOV97 10: 18: 54 0OO: OO: ll 24NOV97 10: 19: 50 000: 27: 06 24NOV97 10: 25: 38 000: 02: 22 24NOV97 10: 57: 17

000: 00: 04 24NOV97 11: 01: 29 000: 43: 22 24NOV97 11: 58: 36 000: 08: 59 24NOV97 13: 13: 13 000: 00: 40 24NOV97 13: 21: 24 000: 00: 51 24NOV97 13: 23: 16 000: 00: 53 24NOV97 13: 25: 48 000: 08: 26 24NOV97 14: 03: 37 000: 03: 50 24NOV97 15: 01: 07 0OO: OO: lO 24NOV97 15: 13: 29 000: 02: 22 24NOV97 15: 20: 51 000: 00: 59 24NOV97 15: 56: 05 000: 00: 48 24NOV97 16: 51: 31 000: 18: 23 24NOV97 16: 58: 03 000: 02: 28 24NOV97 17: lO: Ol 000: 17: 37 24NOV97 17: 17: 24 0OO: OO: lS 24NOV97 17: 29: 22 000: 03: 23 24NOV97 17: 59: 54 000: 00: 07 24NOV97 19: 02: 02 000: 04: 10 24NOV97 19: 04: 52 000: 17: 10 24NOV97 19: 17: 55 000: 03: 21 24NOV97 19: 43: 38 000: 03: 46 24NOV97 20: 38: 49 000: 13: 33 25NOV97 07: 43: 30 000: 07: 32 25NOV97 07: 59: 38 000: 15: 23 25NOV97 08: 11: 09 000: 01: 58 25NOV97 08: 21: 03 000: 00: 44 25NOV97 08: 28: 13 000: 00: 43 25NOV97 08: 38: 03 000: 10: 16 2SNOV97 09: 11: 30 000: 00: 39 25NOV97 09: 34: 48 000: 00: 07 25NOV97 09: 48: 36 000: 01: 53 25NOV97 09: 48: 54 000: 00: 36 25NOV97 09: 50: 38 000: 03: 27 2SNOV97 09: 52: 47 000: 00: 06 25NOV97 09: 55: 35 000: 07: 02 25NOV97 09: 55: 56 000: 02: 04 2SNOV97 10: 47: 35 000: 00: 41 25NOV97 10: 51: 39 000: 00: 49 25NOV97 11: 38: 03 001: 17: 38 25NOV97 11: 58: 39 000: 00: 09 25NOV97 18: 52: 02 000: 13: 45 26NOV97 07: 42: 12 000: 05: 52 26NOV97 09: 00: 34 000: 04: 00 26NOV97 09: 18: 26 000: 39: 11 26NOV97 12: 27: 35 000: 07: 10 26NOV97 14: 32: 00

2620

Bell Atlan .tic TEMPO MDR UC- TN m---- e--- 336979312 /036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312

7036979312

7036979312 7036979312 7036979312

'36979312 r36979312 -136979312

336979312

7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312

7036979312

7036979312 7036979312

7036979312

7036979312 7036979312

7036979312 7036979312 7036979312 7036979312 7036979312

7036979312

7036979312 -‘ q36979312

36979312 - 36979312

36979312 8036979312 7036979312 Page: 5

DEST- TN for 7036979312 Per DTS- W Request

DURATION St .art date- time .-_ ----- SW-- -- s- 0 __----------___ 000: 02: 22 13NOV97 10: 37: 05 000: 01: 40 13NOV97 11: 06: 57 000: 00: 03 13NOV97 lf: 20: 19 000: 03: 20 13NOV97 11: 25: 46 000: 00: 09 13NOV97 11: 29: 43 000: 00: 17 13NOV97 11: 50: 49 000: 28: 20 13NOV97 11: 59: 25 000: 21: 52 13NOV97 12: 25: 17 OOO: OO: lO 13NOV97 13: 15: 50 000: 00: 23 13NOV97 13: 36: 43 000: 00: 14 13NOV97 14: 25: 19 000: 02: 30 13NOV97 14: 26: 56 000: 00: 42 13NOV97 14: 32: 00 000: 00: 08 13NOV97 14: 37: 31 000: 00: 18 13NOV97 14: 42: 12 000: 00: 44 13NOV97 14: 49: 37 000: 00: 30 13NOV97 14: 53: 59 000: 02: 39 13NOV97 15: 04: 13 000: 22: 04 13NOV97 15: 10: 25 000: 04: 17 13NOV97 16: 29: 31 000: 00: 40 13NOV97 16: 33: 07 000: 00: 14 13NOV97 16: 34: 18 000: 03: 44 13NOV97 16: 47: 04 0OO: OO: ll 13NOV97 17: 22: 43 OOO: Od: 09 13NOV97 17: 24: 05 000: 00: 05 13NOV97 17: 24: 32 000: 02: 26 13NOV97 17: 44: f2 000: 07: 04 13NOV97 18: 23: 35 000: 00: 08 13NOV97 18: 29: 39 000: 05: 42 13NOV97 18: 50: 34 000: 00: 21 13NOV97 19: 08: 42 0OO: OO: SO 13NOV97 19: 47: 46 000: 20: 08 14NOV97 07: 57: 24 000: 00: 29 14NOV97 08: 27: 55 000: 00: 15 14NOV97 08: 30: 24 000: 00: 05 14NOV97 08: 42: 40 000: 02: 19 14NOV97 08: 58: 15 000: 00: 16 14NOV97 OP: f2: 24 000: 00: 15 14NOV97 09: 52: 34 000: 00: 35 14NOV97 09: 53: 36 000: 05: 40 14NOV97 09: 58: 41 000: 12: 01 14NOV97 10: 03: 29 000: 02: 12 14NOV97 10: 21: 44 000: 02: 04 14NOV97 10: 23: 39 000: 02: 32 14NOV97 10: 25: 24 000: 05: 34 14NOV97 10: 43: 37 000: 00: 46 14NOV97 11: 25: 23 000: 00: 22 14NOV97 11: 26: 21 000: 06: 45 14NOV97 11: 27: 24 000: 00: 36 14NOV97 12: 06: 25 000: 00: 24 14NOV97 12: 41: 24 000: 00: 22 14NOV97 12: 53: 47 000: 02: 13 14NOV97 13: 31: 35

000: 00: 28 14NOV97 13: 57: 07 0OO: OO: lS 14NOV97 13: 59: 58 0OO: OO: SO 14NOV97 14: 00: 45 000: 00: 30 14NOV97 14: 16: 25 000: 00: 43 14NOV97 14: 22: 10

000: 01: 41 14NOV97 14: SO: ll 0OO: OO: lO 14NOV97 15: 02; 44 dated 24 FE :B 98

833- DC- 00017904

Bell Atlantic TEMPO MDR for 7036979312 per DTS- W Request dated 24 FEB 98 RIG- TN DEST- TN DURATION Start date- time _________ _____---------- a-------- ----------------- ---------__ -------------_ ‘- 036979312

1036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312

336979312 036979312 - 136979312

,036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 .7036979312.

7036979312 "336979312

136979312 ~- '36979312

.36979312 1036979312 7036979312 Page: 4

000: 00: 41 lONOV97 16: 33: 48 000: 05: 05 lONOV97 17: 00: 26 000: 00: 22 lONOV97 17: 04: 28 000: 05: 01 lONOV97 17: 09: 00 000: 08: 50 lONOV97 17: 17: 19 000: 00: 31 lONOV97 17: 27: 51 0OO: OO: lO lONOV97 17: 29: 09 000: 00: 39 lONOV97 17: 31: 32 000: 00: 39 lONOV97 17: 53: 47 000: 02: 01 lONOV97 17: 54: 37 000: 00: 12 lONOV97 17: 58: 51 000: 00: 04 lONOV97 18: 18: 14

000: 00: 45 lONOV97 18: 18: 33 000: 43: 31 lONOV97 18: 19: 56 000: 03: 41 lONOV97 18: 49: 56 000: 20: 00 lONOV97 18: 56: 58 000: 00: 26 lONOV97 19: 11: 44 0OO: OO: ll lONOV97 19: 28: 34 000: 00: 08 lONOV97 19: 32: 24 000: 03: 22 12NOV97 07: 58: 08 000: 15: 41 12NOV97 08: 00: 21 000: 00: 25 12NOV97 08: 19: 20 000: 00: 44 12NOV97 08: 28: 44

000: 00: 08 12NOV97 09: 05: 08 000: 00: 03 12NOV97 09: 23: 18 000: 00: 34 12NOV97 09: 53: 45

000: 03: 52 12NOV97 10: 21: 37 000: 03: 33 12NOV97 11: 06: 39 000: 00: 53 12NOV97 11: 16: 38 000: 00: 59 12NOV97 11: 36: 54 000: 01: 55 12NOV97 11: 56: 20 000: 39: 13 12NOV97 11: 58: 16

000: 00: 21 12NOV97 12: 30: 44 000: 00: 28 12NOV97 12: 32: 30 000: 05: 37 12NOV97 12: 51: 15 000: 00: 14 12NOV97 13: 01: 15

000: 01: 46 12NOV97 13: 36: 36 000: 08: 43 12NOV97 13: 38: 16 000: 00: 08 12NOV97 13: 44: 01 000: 00: 23 12NOV97 13: 58: 25 000: 00: 07 12NOV97 14: 05: 56 000: 00: 55 12NOV97 14: 06: 32 000: 25: 24 12NOV97 14: 30: 02

000: 05: 07 12NOV97 15: 34: 53 000: 01: 57 12NOV97 15: 39: 09 000: 00: 20 12NOV97 15: 48: 00 000: 00: 09 12NOV97 15: 53: 26 000: 02: 19 12NOV97 15: 55: 28 000: 01: 55 12NOV97 17: 26: 27 000: 00: 45 12NOV97 17: 35: 44 0OO: OO: ll 12NOV97 17: 37: 54 000: 15: 03 13NOV97 07: 56: 31

000: 02: 04 13NOV97 08: 12: 56 000: 00: 16 13NOV97 08: 23: 18 000: 00: 05 13NOV97 08: 33: 18

000: 00: 03 13NOV97 08: 38: 30 000: 00: 04 13NOV97 09:. 02: 32 000: 05: 02 13NOV97 09: 26: 56 000: 00: 31 13NOV97 09: 59: 21

000: 02: 03 13NOV97 10: 12: 28

833~ Dc- ooo17m

2622

Bell Atlantic TEMPO MDR for 7036979312 per DTS- W Request dated 12 MAR 98 O" G- TN DEST- TN DURATION Start date- time _______ -- w--------- m-- --------- _______--------------- ------------ -_-______ '- 6979312

979312 5u26979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7076979312

7 5979312 6979312 - 5979312

-26979312 $036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312

7f -979312 i979312 -L- i979312

6979312 70369? 9312 'age : 5

000: 00: 33 17DEC97 08: 23: 16 000: 40: 48 17DEC97 08: 46: 20 000: 00: 35 17DEC97 09: 19: 07 000: 01: 49 17DEC97 09: 20: 40

000: 00: 53 17DEC97 11: 18: 10 000: 03: 28 17DEC97 11: 24: 58 001: 24: 16 17DEC97 11: 58: 24

000: 00: 32 17DEC97 12: 54: 28 000: 00: 07 17DEC97 13: 21: 47 000: 06: 48 17DEC97 13: 22: 25 000: 00: 23 17DEC97 14: 34: 11

000: 45: 19 17DEC97 14: 44: 27 0OO: OO: lO 17DEC97 16: 37: 39 000: 00: 40 17DEC97 18: 17: 29 000: 00: 21 17DEC97 18: 25: 31 000: 05: 02 17DEC97 18: 32: 11 000: 05: 14 17DEC97 18: 36: 50 000: 00: 20 17DEC97 18: 58: 34 000: 00: 25 18DEC97 07: 31: 27 000: 00: 46 18DEC97 07: 48: 28 000: 21: 47 18DEC97 07: 54: 09 000: 00: 22 18DEC97 09: 17: 25 000: 00: 18 18DEC97 09: 25: 37

000: 00: 26 18DEC97 10: 59: 54 000: 13: 56 18DEC97 12: 23: 12 000: 20: 22 18DEC97 15: 05: 11 000: 20: 48 18DEC97 17: 15: 37 000: 00: 16 18DEC97 17: 28: 44 000: 00: 54 18DEC97 17: 29: 27

000: 15: 03 19DEC97 07: 59: 35 000: 00: 30 19DEC97 08: 27: 11 000: 15: 38 19DEC97 09: 07: 29 000: 00: 09 19DEC97 09: 19: 06 000: 00: 06 19DEC97 09: 19: 21 000: 02: 14 19DEC97 09: 22: 39 000: 02: 16 19DEC97 09: 25: 23 000: 00: 07 19DEC97 10: 15: 11 000: 00: 44 19DEC97 10: 17: 34 000: 00: 47 19DEC97 10: 33: 05 000: 25: 22 19DEC97 10: 52: 42 000: 00: 07 19DEC97 11: 11: 13 000: 00: 30 19DEC97 11: 12: 31 000: 05: 27 19DEC97 11: 20: 14 000: 00: 28 19DEC97 11: 39: 52 000: 08: 54 19DEC97 12: 36: 59 000: 07: 22 19DEC97 12: 54: 07 000: 00: 07 19DEC97 13: 01: 13 000: 11: 58 19DEC97 13: 02: 10 0OO: OO: ll 19DEC97 13: 26: 00 000: 00: 22 19DEC97 13: 35: 13' 000: 13: 47 19DEC97 13: 35: 52 000: 01: 50 19DEC97 13: 47: 32 000: 00: 04 19DEC97 13: 50: 56 000: 02: 31 19DEC97 13: 54: 06 000: 00: 35 19DEC97 13: 58: 41 000: 00: 32 19DEC97 13: 59: 37

000: 07: 16 19DEC97 14: 15: 58

000: 01: 56 19DEC97 16: 09: 21 0OO: OO: lO 19DEC97 18: 03: 59 000: 00: 24 19DEC97 18: 26: 46 833- DC- 00017890

, 2623 .

Bell Atlantic TEMPO MDR for 7036979312 per DTS- W Request dated 12 MAR 98 "PIG- TN DEST- TN DURATION Start date- time ----____ _______-____ a-- -- a------ -------------------------------- --------- me -: 36979312

36979312 '/ 036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312

16979312 16979312 '- J6979312

ru36979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312

7 5979312 * 6979312 L- 6979312

J6979312 %36979312

?age: 1 000: 12: 15 OlDEC97 07: 42: 18

000: 30: 06 OlDEC97 07: 59: 10 000: 32: 36 OlDEC97 11: 58: 03 000: 13: 25 02DEC97 07: 41: 34 0OO: OO: ll 02DEC97 07: 57: 39 000: 13: 41 02DEC97 07: 57: 58 000: 07: 37 02DEC97 11: 10: 34

000: 04: 08 02DEC97 11: 52: 42

000: 45: 46 02DEC97 11: 59: 08 000: 00: 12 02DEC97 18: 28: 45 000: 15: 23 03DEC97 07: 58: 03

000: 37: 28 03DEC97 12: 04: 02

000: 00: 45 03DEC97 15: 33: 48 000: 02: 14 03DEC97 15: 34: 55

000: 05: 08 04DEC97 07: 46: 53 000: 09: 02 04DEC97 07: 57: 46

000: 38: 26 04DEC97 12: 00: 16 000: 02: 16 04DEC97 15: 23: 01

000: 02: 02 04DEC97 15: 25: 04

000: 06: 40 04DEC97 16: 44: 07

000: 38: 25 04DEC97 18: 38: 57 000: 09: 15 05DEC97 07: 44: 23 000: 12: 16 05DEC97 07: 58: 14

000: 38: 58 OSDEC97 08: 07: 06 000: 01: 46 05DEC97 13: 27: 42 001: 20: 32 05DEC97 13: 30: 28 000: 12: 21 OSDEC97 14: 33: 30

000: 00: 50 05DEC97 14: 55: 33

000: 00: 22 05DEC97 16: 46: 06

000: 03: 48 05DEC97 16: 58: 25

000: 00: 12 05DEC97 17: 47: 29

000: 00: 14 05DEC97 18: 19: 07

000: 00: 44 05DEC97 18: 26: 56 000: 13: 30 08DEC97 07: 44: 44 000: 22: 01 08DEC97 07: 59: 12

000: 02: 04 08DEC97 08: 23: 33 000: 10: 58 08DEC97 08: 56: 30 000: 01: 57 08DEC97 09: 06: 26 000: 00: 17 08DEC97 10: 08: 26

000: 02: 28 08DEC97 10: 29: 39 0OO: OS: lO 08DEC97 11: 03: 29 000: 49: 01 08DEC97 11: 57: 14

000: 00: 08 08DEC97 13: 05: 35

000: 00: 40 08DEC97 14: 15: 54 0OO: OO: lO 08DEC97 14: 31: 45

000: 06: 48 08DEC97 16: 22: 52

000: 00: 28 08DEC97 16: 32: 37 000: 03: 31 08DEC97 16: 49: 35

000: 00: 50 08DEC97 17: 09: 31

000: 02: 03 08DEC97 17: 19: 38

000: 00: 08 08DEC97 17: 41: 35

000: 03: 34 08DEC97 17: 44: 05 000: 00: 08 08DEC97 18: 10: 14 000: 11: 58 08DEC97 18: 19: 35

000: 00: 50 08DEC97 18: 31: 27 000: 29: 10 09DEC97 07: 58: 29 000: 01: 51 09DEC97 09: 41: 21

000: 02: 33 09DEC97 09: 52: 26 000: 21: 41 09DEC97 10: 05: 26 000: 08: 34 09DEC97 10: 22: 30

833- DC- 00017886

-- 2624

*-. a'

Bell Atlantic TEMPO MDR for 7036979312 per DTS- w Request dated 12 MAR 96

ORIG- TN DEST- TN DURATION Start date- time __________ ___------------ --------- -------------- s------------- ---_____

7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 '036979312 7036979312 '036979312 '036979312 '036979312 '036979312 7036979312 '036979312 '036979312 '0369.79312 '036979312

'036979312 '036979312 '036979312 ‘036979312 ‘036979312 ‘036979312 ‘036979312

age: 1 000: 17: 19 03NOV97 07: 57: 03

000: 18: 42 03NOV97 08: lS: OO 000: 00: 12 03NOV97 09: 21: 27 000: 02: 00 03NOV97' 10: 02: 54 000: 00: 09 03NOV97 10: 49: 07 000: 00: 04 03NOV97 11: 16: 01 000: 06: 52 03NOV97 11: 28: 00 000: 30: 05 03NOV97 12: 00: 35 000: 00: 36 03NOV97 12: 20: 53 000: 00: 25 03NOV97 12: 26: 46 000: 00: 14 03NOV97 12: 58: 31 000: 00: 15 03NOV97 13: 02: 09 000: 00: 12 OJNOV97 13: 24: 14 000: 05: 24 03NOV97 13: 34: 28 000: 01: 48 03NOV97 13: 41: 00 000: 00: 04 03NOV97 14: 51: 19 000: 01: 59 03NOV97 15: 47: 04 000: 00: 21 03NOV97 16: 04: 47 000: 00: 30 03NOV97 16: 53: 26 000: 02: 21 03NOV97 17: 06: 25 000: 00: 06 03NOV97 17: 08: 41 000: 00: 05 03NOV97 17: 09: 19 OOO: OOiO6 03NOV97 17: 12: 45 000: 00: 08 03NOV97 17: 33: 36 000: 04: 01 03NOV97 18: 01: 40 000: 00: 21 03NOV97 18: 11: 55 000: 13: 51 03NOV97 18: 15: 39 0OO: OO: lO 03NOV97 18: 24: 56 000: 01: 49 03NOV97 18: 50: 25 000: 00: 15 03NOV97 18: 54: 17 000: 00: 15 03NOV97 18: 56: 15 000: 00: 41 03NOV97 18: 57: 28 000: 00: 18 03NOV97 18: 58: 17 000: 20: 07 04NOV97 07: 56: 10 000: 00: 42 04NOV97 09: 05: 05 000: 00: 59 04NOV97 09: 12: 30 000: 06: 57 04NOV97 10: 05: 21 000: 00: 28 04NOV97 11: Ol: OO 000: 00: 24 04NOV97 11: 18: 58 000: 35: 21 04NOV97 11: 47: 46 000: 01: 47 04NOV97 12: 09: 16 000: 00: 28 04NOV97 12: 41: 22 000: 01: 53 04NOV97 12: 47: 54 000: 00: 38 04NOV97 14: 13: 06 000: 03: 49 04NOV97 14: 28: 01 000: 07: 38 04NOV97 15: 06: 28 000: 20: 58 04NOV97 15: 11: 47 000: 02: 35 04NOV97 15: 27: 47 000: 00: 09 04NOV97 15: 49: 00 000: 03: 32 04NOV97 15: 54: 16 000: 06: 59 04NOV97 16: 40: 12 000: 00: 39 04NOV97 16: 44: 52 000: 00: 34 04NOV97 16: 50: 29 000: 00: 54 04NOV97 16: 51: 15 000: 03: 28 04NOV97 17: 06: 52 000: 04: 17 04NOV97 17: 15: 14 000: 00: 07 04NOV97 17: 20: 06 000: 01: 57 04NOV97 17: 25: 16 00@: 00: 49 04NOV97 17: 45: 41 000: 04: 10 04NOV97 17: 58: 10

2625

Bell Atlantic TEMPO MDR for 7036979312 per DTS- W Revest dated 12 MAR 98 OPTG TN DEST- TN DURATION Start date- time ------- -------------__ ---___--- -------------------------- --------- mm___ --- - 6979312 I- ;979312 'I -46979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 '1036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312

7 i979312 - 6979312

'979312

7. .- J979312 7036979312 7036979312

000: 03: 33 150CT97 17: 39: 08

000: 03: 20 15OCT97 18: 21: 22

000: 00: 53 16OCT97 07: 36: 58

000: 23: 57 160CT97 07: 56: 34

000: 01: 48 160CT97 08: 35: 23

000: 08: 44~ 16OCT97 08: 36: 36

000: 00: 55 16OCT97 08: 47: 56 000: 18: 48 16OCT97 09: 31: 19 000: 01: 59 160CT97 10: 49: 51 001: 05: 20 16OCT97 11: 59: 39 000: 00: 28 160CT97 13: 18: 17 000: 00: 16 16OCT97 14: 48: 20

000: 05: 25 160CT97 17: 33: 13

000: 03: 32 160CT97 17: 50: 52 000: 13: 21 16OCT97 18: 07: 33 000: 00: 18 16OCT97 18: 42: 45 000: 00: 21 160CT97 18: 48: 40 000: 00: 12 16OCT97 18: SO: Ol

000: 05: 02 16OCT97 18: 52: 38

000: 00: 05 160CT97 18: 56: 39 000: 01: 49 16OCT97 19: 12: 32

000: 00: 53 16OCT97 19: 14: 52

000: 00: 23 16OCT97 19: 23: 01 000: 01: 46 160CT97 19: 24: 55

000: 28: 44 16OCT97 19: 36: 30 000: 01: 52 160CT97 19: 54: 29 000: 19: 11 170CT97 07: 58: 06 000: 00: 29 170CT97 09: 04: 08

000: 04: 05 17oCT97 10: 35: 35 000: 00: 26 170CT97 11: 10: 54 000: 00: 18 17OCT97 11: 16: 42 000: 02: 28 170CT97 11: 18: 44 0OO: OO: lO 17OCT97 11: 34: 48 000: 00: 14 170CT97 12: 50: 56 000: 00: 14 170CT97 13: 06: 23

000: 03: 20 17OCT97 13: 23: 31 000: 00: 11 17oCT97 14: 33: 47 000: 00: 06 17OCT97 14: Sl: Ol

000: 00: 47 17OCT97 14: 56: 26 000: 13: 28 17OCT97 15: 18: 48 000: 00: 29 17oCT97 15: 32: 49 000: 00: 27 17OCT97 15: 41: 14

000: 00: 08 17OCT97 15: 52: 02 000: 00: 19 17OCT97 15: 52: 43

000: 00: 04 17oCT97 15: 59: 04

000: 00: 53 17OCT97 16: 09: 29 000: 02: 18 170CT97 16: 11: 25 000: 00: 52 170CT97 16: 19: 41 000: 00: 59 17OCT97 16: 41: 23

000: 00: 37 17OCT97 17: 07: 48 000: 00: 19 17OCT97 18: 21: 01

000: 00: 53 17OCT97 18: 22: 10 000: 10: 38 170CT97 18: 26: 20

000: 00: 36 170CT97 18: 41: 52

000: 00: 47 17OCT97 18: 44: 25 0OO: OO: ll 170CT97 19: 16: 08 0OO: OO: OS 200CT97 06: 25: 13 000: 00: 05 200CT97 06: 37: 23 000: 30: 55 200CT97 07: 55: 39 000: 05: 19 200CT97 08: 25: 45

7 :979312

7 s979312 -'L 379312 7, 979312 7036579312

Page: 4 833- DC- 00017869

2626

Bell Atlantic TEMPO MDR for 7036979312 per DTS- W Request dated 12 MAR 98 c- TG TN DEST- TN DURATION Start date- time -- em--- --_-_---__----- --------- ---- em ------------------------------------- .-. a6979312

6979312 36979312 +036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7" 36979312

16979312 -36979312

6979312 ,6979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312 7036979312

36979312 'i6979312 ‘. L 5979312

6979312 7U36979312 Page: 2

000: 00: 07 06OCT97 000: 00: 45 06OCT97 0OO: OO: lO 06OCT97 000: 00: 24 06OCT97 000: 00: 51 06OCT97 000: 03: 56 06OCT97 000: 00: 59 06OCT97 000: 05: 16 06OCT97 000: 05: 53 06OCT97 000: 02: 23 060CT97 000: 00: 05 06OCT97 000: 07: 00 06OCT97 000: 02: 30 06OCT97 000: 22: 10 07ocT97 000: 00: 13 07ocT97 000: 02: 09 07ocT97 000: 04: 10 07ocT97 000: 01: 51 07ocT97 000: 00: 01 07oCT97 000: 00: 33 07ocT97 000: 33: 53 07ocT97 000: 18: 23 07OCT97 000: 00: 07 07ocT97 000: 00: 48 07OCT97 000: 00: 27 07OCT97 000: 00: 13 070CT97 0OO: OO: SO 070CT97 000: 00: 43 07ocT97 000: 00: 48 070CT97 000: 02: 05 07OCT97 000: 00: 09 070CT97 000: 00: 54 07ocT97 000: 05: 53 07ocT97 0OO: OO: lO 070CT97 000: 00: 09 07ocT97 000: 15: 12 080CT97 000: 15: 49 08OCT97 000: 07: 03 08OCT97 000: 01: 56 08OCT97 OOO-: 09: 09 08OCT97 000: 35: 10 08OCT97 000: 00: 46 08OCT97 000: 01: 54 08OCT97 000: 08: 20 08OCT97 000: 05: 02 080CT97 000: 01: 43 08OCT97 000: 00: 20 08OCT97 000: 03: 51 08OCT97 000: 05: 23 080CT97 000: 01: 57- 08OCT97 000: 00: 26 08OCT97 000: 00: 35 080CT97 000: 00: 45 080CT97 000: 00: 20 090CT97 000: 48: 30 090CT97 000: 00: 24 090CT97 000: 00: 04 090CT97 000: 08: 56 090CT97 000: 17: 26 090CT97 000: 10: 26 090CT97

10: 43: 23 10: 44: 18 10: 48: 23 11: 06: 25 11: 07: 12 11: 54: 36 12: 24: 25 15: 34: 01 15: 44: 17 15: 54: 16 16: 05: 48 16: 16: 42 16: 27: 59 07: 55: 15 09: 24: 05 09: 37: 54 09: 59: 36 10: 53: 05 11: 09: 53 11: 15: 57 11: 55: 11 12: 21: 59 13: 10: 26 13: 37: 38 14: Ol: ll 15: 02: 07 15: 02: 41 15: 05: 09 15: 10: 03 16: 11: 13 16: 38: 13 16: 50: 20 17: 20: 28 17: 49: 23 18: 35: 07 07: 58: 48 08: 12: 50 08: 24: 12 10: 34: 44 11: 38: 43 11: 44: 57 13: 05: 27 13: 07: 28 13: 10: 54 13: 17: 55 13: 42: 46 14: 00: 29 14: 01: 21 14: 13: 19 16: 32: 15 16: 34: 08 17: 41: 11 17: 42: 20 07: 28: 19 07: 56: 46 09: 20: 27 09: 24: 00 09: 37: 44 10: 19: 43 10: 38: 20 833- DC- 00017867

2627

CLIENT CALL BY. L’

’ CCP FIEF 0

837~ DC- 00000004

FROM TO:

TIME IN

2628

2629

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I CALL 6V:

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2631

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2632

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2633

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2652

837- DC- 00000026

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1 1 7 I .I. 1 1 I -. 1 1

2654

U. S. Secret Service uale 01 repon.

Epass Access Control Reporf Oll27198 Search Criteria: MONDALE, ELEANOR Search Dates: . 07/ 01197 to 12/ 31/ 97 .

Date Time Name Badge Type post status 07/ 20/ 97 14: 09: 09 MONDALE, ELEANOR 346672 A A4 ENTERING 07/ 20/ 97 16: 26: 56 MONDALE, ELEANOR 346672 A A4 EXITING 12/ 06/ 97 09: 32: 57 MONDALE, ELEANOR 34667A A A4 ENTERING 12/ 06/ 97 10: 46: 08 MONDALE, ELEANOR 34667A A A4 EXITING

01/ 2- J/ 98 Page: I

2655

2656

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2673

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2674 -

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2676

2677 .- . . . .

2678

Letters Editor Newsweek 251 West 57th Street New York, New York 10019- 1894

(BY FAX: 212.4454120) I would like to clarify the questions that have arisen about my involvement in the matter reported by hewswe&” its August Ilth edition. Contrary to the perception held by many that I granted Newsweek ‘ an intew for this story, the truth is the reporter appeared, uninvited and unannounced, in my office at the Pentagon in late March 1997. I was compelled to respond when he asserted that Ms. Willey had given him my name, as a purported contemporaneous witness who could corroborate her new claim of ‘ harassmer$ or ‘ inappropriate behaviof on the part of the President.

My response then, as it remains today, was that this was completely inaccurate and that her version in 1993 and her version in 1997 were wholly inconsistent One must wonder how such disparate allegations spanning a period of four years could have much, if any, credibilii.

Regarding the comment made by the Presidenrs attorney about me, which appeared in the same article, I am acutely diiinted that my integrity has been questioned.

Linda Ft. Tripp Department of Defense Washington, DC. 20801- l 400

2680 I I I

-I- %# - - /

2681

Friday, September 12that gate, hour and a half -- repeated calls to office, finally she came out and got her -- long talk, he left. She poke to him before she left and told him XX was hysterical and at the gate and that she would clear her in and determine if she was a "crazy woman" --

Sept 14 'Sunday night -- her plane from Illinois was cancelled, luckily she ran into Glickman who claimed she was with their

w party and got her on their flight out but to National instead of BWI -- she had to go get her car at BWI and called at 7: 00 or so

?fY -- said she would call him and if he checked his messages, maybe

he would call her back. He was at the pool at 7: 30 -- she didn't know if he had company or what, but he called her later that

"- 37 -Q evening and said that he would talk to XX Xxx this week. 845- DC- 00000193

2682

PRESIDENT CLINTON’S RESPONSE TO PLAINTIFF’S THIRD SET OF

INTERROGATORIES JONES V. CLINTON SEALED PURSUANT TO

COURT ORDER

2683

2684

PAULA CORBIN JONES V WILLIAM JEFPE’RSON CLINTON

WITNESS LIST

‘ -

2686

Monica S. Lcwineky

11 December 1997 Ms. Ursula Fairbairn EVP, Human Resources & Quality American Express Company American Express Tower. World Financial Center New York, New York 10285

Dear Ms. Fairbaim: I ~III writing at the suggestion of Vernon Jordan, who has spoken with you on my behalf. I am interested in exploring opportunities in Communications or Public Relations in New York. I am hoping to secure a position which would require effective communication skills, creativity, and frequent interaction with people. My various jobs in Washington, DC have provided me with the training and skills needed to further pursue a career in these areas.

Most recently, I have been working for the Honorable Ken Bacon, the Assistant Secretary of Defense for Public Affairs, as his primary assistant. My responsibilities range from interacting with the media on his behalf, to providing administrative assistance on the Secretary of Defense’s international trips, to assembling timely updates of current media stories. My prior experience was at the White House in Legislative Affairs and the Chief of Staff’s Office. -Please see the enclosed resume for further detail.

I am moving to New York and am seeking employment to begin the first of the year. I am ready and available to speak with whoever in your office you might deem appropriate. I will follow up with a phone call to your office on Monday, December 15th, 1997.

Thank you for time. Sincerely;

8% DCM30000( n Monica S. Lewinsky

From Ursula Fairbaim’s Files

CC: Mr. Vernon Jordan

2687

JOB 08008 OP JNH WS IDW09W NODE4 CF12982 P O- 2/ 03/ 98 15:& 25 AA LEWIS, 2117, 0, $0500, 7/ 96 WILKES SUBPOENA DESK NC 2010

856DC- 00001485

NC 99999

2688

MONICA s LEWXNSKY 12- 17- 97 ffiNOl228 2136

004 l/ O085

- - Express Cash Statement Electromc Fund Transfers Inmivq

Withdrawak From Checkmg Accavr.: Cash Withdrawal From Financial Institution Account No

1 I -29- 97 Cash Recewd: ~300.00 Fee: S- 00 Transaction Total: Dwenser: OLOI s300.00

UBOC BRENTWOOD W/ U LOS ANGELECAUS 12- 04- 97 Cash Recerved: $168.49 Fee: S. OD Transaction Totab

Dwensx LSBDCCll LLOYDS BANK, U. K. 5168.49 LLOY OSGB

12-@ j- g7 cash RecenRd: Dispenser $134.79 Fee: s. 00 Transaction Total: $134.79

. LSBCGCll LLOYDS BANK. U. K. LLOY DSGB To change ywr bank or Persmal Icientifmtion Numb% OT to find out lhe Express Cash bcation nearest you, call 1 -BOO- CABH-~ W.

S/E l 9410126785 WE l 9420124570

WTAL ?ora - - .bl- 14724 .- 455.37

ITEU 3 s3w. 00 x) 1217 ATY W! TKXAWAL 1 l/ 29197

mm L - -w -w 1 I/ 29/ 97 001217 m

sm.. n-~, Qu 2C022 N -.- raoR

WVEWENTKEC RmH* BER a01

WE I 5026614182 IOTAI - $300.00 .-

5 SW. 49 ATM WIllUlAWAL 12/ M/ 97 cam- m a-- 4 -w

12/ 04/ 97 233wl -- 00 so.- L- I ,I.,-

20022N

GWGWENTKEC m NAMER L9eaxll

AizEKa &SEKtTEL. PM CM. Lo9oN $752.26 -- lm

d 09.*-

97/ 12/ B %iG& -- ITEN 5134.79 l422M A:" WlTtCRAWAL 12/ 04/ 97

D---- -w -u 12/ 04/ 97 442204 m

- an- I Lull 20022 N W”. dW

CDWUUWTICEC KcruBERL9Baxll

S/ E # 5026514182 TOILL - $134.79 .-

852- DC- 5

2689

GO40/ 0085 s Al 0 3 YOUR ACCOUNT IS 60 DAYS PAST DUE. PLEASE

12- 17- 97 Sl. 842.42 MAIL PAYhtENT TO: MONICA S LEWINSKY

AMERICAN EXPRESS P- 0. BOX 42010 PHILADELPHIA PA 19162- 4201

l,,, lll~ l~~~~~ ll, ll,,,, l, l, l,, l~~ l~ lll~~~~~~ lil, l,, l, l,,, ll,, l

837b985Sb3 OOlt8’+ 2~ 2000137538b

Summary of Account -t cafeuloeer ww Governrent -t nMtr MONICA S LEWINSKY

Prtvias Btltnct Rev Cturgts otter Penits Pamems Received attvr crteits klance Due

B67.04 $1.756.79 $16.59 s- 00 s. 00 $1 l 642.42

Rthrawt hmtr

094338 390342 501334 501339 501339 823334 623339 823339

1ttt MmJtr

1 2 3 4

Description of LlDnthly Activity

PREVIOUS BALANCE

Cturgts

$67 -04

HOLIDAY INN, OIEGEM BELGIUM

14.724 BELGIAN FRANCS BILLED AS 403.25 GROSVENOR HOUSE HOTEL, PARK LANE, LONOON

UNITE0 KINGDOM 455.37 POUNDS STERLING BILLED AS GO1217 ATM WITHDRAWAL 1 l/ 29/ 97

UBOC BRENTWOOD W/ U LOS ANGELECAUS 442204 ATM WITHDRAWAL 12/ 04/ 97

LLOYOS BANK. U. K. LLOY DSGB 23306 1 ATM WITHDRAWAL 12/ 04/ 97

LLOYDS BANK. U. K. LLOY OSGB ATM CASH ADVANCE FEE

DATE OF ABOVE 11/ 30 ATM CASH ADVANCE FEE

OATE OF ABOVE 12/ 05 ATM CASH ADVANCE FEE

DATE OF ABOVE 12/ 05 TOTAL CHARGES AN0 CREDITS

BALANCE DUE PAGE 1 OF 2 852- DC- 00000044

strtmmt clostng oatt

12- 17- 97 752.26 300.00

134.79 168.49

8.25 4.63 3.71 $1.775.36 S1.842.42

FOR INOUKRIES ABOUT YOUR ACCOUNT. CALL TOLL- FREE l- 800- 492- 4922 OR WRITE US AT P. O. BOX 297812. CT. LAUDERDALE. FL 33329- 7812.

crta1ts

S --_--^

2690

0033/ clG85 s A4 0 2 YOUR ACCOUNT IS 30 DAYS PAST DUE. PLEASE

DISREGARD THIS NOTICE IF EXPENSE REPORTS HAVE BEEN SUBMITTED OR PAYMENT SENT.

GovtmmYlt Al2comt ww Statement Closing Oatt Total &wult be

08- 17- 97 $1.895.36 MONICA S LEWINSKY OSD/ WHS

MAIL PAYMENT TO: AMERICAN EXPRESS P- 0. BOX 42010 PHILADELPHIA PA 19162- 4201

8376985563 OOLB= l53bOOOLO= i1b30

SummaryofAccount

@v- t Carmolder Name bvemm4lt kcant Hdcr

MONICA S LEWINSKY

Prevcous Balance

$803.73 New Qvrocs other otetts Psymtnts Received

$1.083.38 $8.25 t. 00

Rcftrabct n* bcr

395199 390200 316209 501202 323202

1ttt lkatr

1 2

OCScrIPtim of Mmthly Actlvlty

PREVIOUS BALANCE DUNA HOTEL MARRIOTT, BUDAPEST

HUNGARY 52.120.00 HUNGARIAN FORINT BILLED AS RUS HOTEL. KIEV

UKRAINE. 137.00 U. S. DOLLARS BILLED AS 137. Oc HOTEL SHERATON SOFIA, SOFIA

BULGARIA 367.72 U. S. DOLLARS BILLED AS GGOG61 ATM WITHDRAWAL 07/ 20/ 97

UB of CA BRENTWOOD W/ U LOS ANGELECAUS ATM CASH ADVANCE FEE

DATE OF ABOVE 07/ 21 TOTAL CHARGES AND CREDITS

BALANCE DUE PAGE 1 OF 2 852- Dc- oamoo37

statement Closing Date

06- 17- 97

Other Credits s. 00

OW# S

S& 03.7? 278.6f

367.72 3GO. OC

a. 25 $1.091.63 $1.895.36

Bllna out

$1.895.36

cre81ts

FOR INOUIRIES ABOUT YOUR ACCOUNT, CALL TOLL- FREE l- 800- 492- 4922 OR WRITE US AT

P. O. BOX 297812. FT. lAUDERDALE, FL 33329- 7812.

Express Cash Statement

Card Number. - Cash Withdrawal From Financial Institution Account No

Electrcnic Fund Transfers ln~ hng Withdrawals Frcrn Checking ~c= unf

07- 08- 97 cash f% ZWiWd: $67.97 Fee: Transx& m TotaI: Dispenser: 2150 AMEX- PLAZA DE L%? ORTES MADRID TSD $67.97 ES

07- 08- 97 &Sh &Cx3iWd: $33.99 Fee: TransaWm Totat: Dispenser. 2150 AMEX- PLAZA DE L&? DRTES MADRID TSO ES $33.99

07- 1 O- 97 cash Received: $10.76 Fee: s- 00 Transaction Total: Dispeoser . 2062 AMEX- AMEX- BUDAPEST TSO BUDAPEST TSO HU $10.76

07- 10- 97 cash Fkceived: 553.82 Fee: Dispen* r: 2062 s. 00 Transxwn TOW:

AMEX- AMEX- BUDAPEST TSO BUDAPEST TSO HU s53.82 07- 1 o- 97 Cash Received: $107.63 Fee: Transaction Tow:

Dispenser: 2062 S- 00 AMEX- AMEX- BUDAPEST TSO BUDAPEST TSO HU $107.63

852~ DC- OOOOOO35

TO change yaw bank cr Perscnal Mentificaticn Number. cr to find out the Express Cash kcatjcr~ nearest pu, tit 1 -~~- cASH- NOW.

ITEU 1 1402.22 PALbcEMTEL. MUIR10

a-- L ~.~ PIR mu u.. d c. m m 97/ 07/ 09 191001816 29

rmA& - 59348 TuTA2

- 22oDO. 00 .- 7 A-

:% o 3 s33.99 AN WITI- CRAWAL 07/ 08/ 97

C.-- w D-. ticba. m -u 07/#./ 97 03K32o -do"

S/ E I 5026514182 lD. U F". U4 ." OU. $33.99

Il- Eu 2 *llQ ml -..-.- AmIT mum. 9mwEST

ca-~-~ 09”* cu.~ umau -w

97/ 07/ 10 1607 31

re-.. nI-~ utu. m .uoIT mKLm WI U. S. a*-

S67.97 07/ 08/ 97 -V- Oh r ~". lDr.

07/ 08/ 97 ?Giior -$- WCi=- ENT/ CEC KC N. RBER 2150

S/ E I t& S514182 $67.97

2692

THE WHITE HOUSE

I I -

880- DC- 00000002

IIIIIlll GUIllI Ii I! lllllllln 11111 IllI llll HB 004746

2693

880- DC- 3

lul~~ llnlu~ lllllllllllllllllllllll~ HB 004747

2694

I THE WHITE HOUSE

2695 -- . .

880- DC- 5

-L

2696

I-

THE WHITE HOUS-&---

880- DC- 00000006

lllill~ llllllllllll~ llllsRllllliwl HB 004750

w- -

I II THE WHITE HOUSE II II .- II

880- DC- 00000008

2699

DAVID PYKE, ESQ. Rader, Campbell, Fisher & Pyke Counsel for Plaintiff Stemmons Place, Suite 1080 2777 Stemmons Freeway Dallas, Texas 75207

and ROBERT S. BENNETT, ESQ. KATHERINE S. SEXTON, ESQ. Skadden, Arps, Slate, Meager & Flom LLP Counsel for Defendant Clinton 1440 New York Avenue, N. W. Eleventh Floor Washington, D. C. 20005- 2111

and BILL W. BRISTOW, ESQ. Counsel for Defendant Ferguson 216 E. Washington Jonesboro, Arkansas 72401

2700

MS. MONICA S. LEWINSKY Page 2 01/ 12/ 98 01, '15/ 98

01/ 20/ 98 01/ l- 5/ 98 01/ 07/ 98 01/ 12/ 98

01/ 14/ 98 01/ 15/ 98

Hours Draftina Matter Draft letter to Atty David Pyke. Draft memo to file re: courier issue. Draft Motion to Quash and for Protective Order.

Draft letter to Atty Speights. Draft letter to Atty Speights.

SUBTOTAL: E 3.50 875.001 Telephone conf. Telephone conference with Atty Jordan. 0.20 SUBTOTAL:

Research Research: discovery limits.

0.50 0.30 5.90

0.40 0.30 .

Amount [ 7.40 1,850.00]

3.50 Telephone message to Atty David Pyke. Telephone conference with Client. Telephone conference with Atty David Pyke.

Telephone conference with Client. Telephone conference with Client. Telephone conference with Client.

0.10 0.20 0.20

0.20 0.20 0.20

2702

CARTER & VARRONE Attorneys- at- Law Suite 510, The. Colorado Building

1341GSIrc@ Nw

Washington, DC 20005

(202) 393- 4330

Packnile (202) 3934657

Francis D. Carter Edward G. Vanone* StcphanieY. Bmdley* ofcounstl ‘dwadldodin~ l b odmitudinMDudNY

Invoice submitted to: MS. MONICA S. LEWINSKY 700 New Hampshire Avenue, N. W. Apartment 114 Washington DC 20037

January 7, 1998 In Reference To: Jones v. Clinton and Ferguson Invoice #lo951

Professional services Hours

12/ 22/ 97 Meeting with Client (Office), 12/ 23/ 97 Meeting with Attys Bob Bennett adn

Kathy Sexton (their Office). 1.10

1.00 01/ 05/ 98 Meeting with Client (Office). 1.10

Amount

SUBTOTAL: I 3.20 800.00] Document Review 01/ 05/ 98 Review material from Atty Kathy

Sexton. 0.20 01/ 06/ 98 Review material from Atty Sexton at

Skadden, Arps. 0.40 SUBTOTAL: 1 0.60 150.001

2703

MS. MONICA S. LEWINSKY Drafting Matter 12/ 24/ 97 Draft Engagement Agreement.

Draft letter to Client. 01/ 06/ 98 Draft Affidavit for Client.

SUBTOTAL: Telephone conf.

Hours 0.50 0.20 0.60

Amount I 1.30 325. OOJ

12/ 22/ 97 Telephone message to Atty Bob Bennett. Telephone conference with Atty Kathy Sexton.

12/ 23/ 97 Telephone conference with Atty Kathy Sexton.

Telephone conference with Client. Telephone conference with Client. 12/ 29/ 97 Telephone conference with Client. 12/ 30/ 97 Telephone conference with Atty Kathy

Sexton, Skadden, Arps firm. Telephone conference with Client. 01/ 06/ 98 Telephone conference with Atty Katy

Sexton, Skadden, Arps. Telephone message to Atty David Pyke. Telephone conference with Client.

902~ DC- 00000038

0.10 0.20

0.10 0.10 0.20 0.10 0.10

0.10 0.30

0.10 0.10

Issued by the UNITED STATI% DISTRICT COURT

PAUUIONES,

DXSSTRICT OF cm

SUBPOENA IN A CIVIL CASE

CASENUMBER? LR- C- 94- 290

WIU. L4MJEFFERsoNcuNToN 8nd DANNYFERCUSON~

DCjbldentr

TO: MONKA LFNlNSKY

PLACE OF DEPOSlTION DATEANDTME

The Ruthclford Instimtc Friday, Janmy 23.1998 733 15th strca NW., suite 410 930 1111 W~~~~ 2~ 5

ISYOU ARE COMMAND ED to produce and permit inton and CC& Q of the following dtmmcm or objazts at the place, date, and time specified below (list doamcnfs or objcets):

Exhibit A. attached hutto.

PUCE. DAlF# ANDnhtE The Ruthaford Instittttc Friday, Januq 23.1998 733 15th &mu NW, suite 410 930 Am. wahittgto& Dc2ooo5

0 YOU ARE COMMANDED to permit impcction of the following premises at the date and time specified below. MtEANDnhtE

Any~ tionnotapanytothissuitthatissubpotoledforthcar) oingofa~ onshalldtsignatcomormorr: offian, directon, armaoagingagcngorothr~~ conscnttotntifyanitrtKhattandnravKtforth, fortacSpcnond~ ignaud,~ matters on which the person designated, the matten on which the person will tckfy, Fcdcral Rules of Civil Froceduk. 30( b) (6).

tssutNG 0mcER StGNARJRE OR DEFENDANT) DATE t! SUtNG OFFtCEWSNAhtE ADDRESS ~PH\ 6NENUMBER

Donovan Campbell, Jr., Rader, CampbeE, Fisher & Pyke, Stcmmons Place, Suite 1080, 2777 Stcmmons Freeway, Dallas, Texas 75207, (214) 630- 4700 902- DC40000135

(See Rule 45. FedetA Rules of Civil Procedure. Pam C & D on Rev-)

1 If actIon is pending in district other than district of issuance. State distnct under case numbcr.

2705

DEC. -19’ 9’ iFRIl 1J: li RADER CXRBELL TEL:! 14 630 9996 P. 002

EXHIBITA DOCUMENTS AND THINGS TO BE PRODUCED

Forthcpqosesofthescrquests, 13ddlowing~ tio11~ applyt =De& kndmt Fcrgrrsoa” mcmrsDaany Fcrgusoa

“Pcxsau” rueam any idaMiable entity, in& ding but nut J&,& d ~0 &livid~&, corporations, partnaship$ soleproplictcahipq and Ilecoxparatcd a% ociations.

“you” xlcuns t? lo Dcpw JlvsTRucrxo~

EXHEX? J A - DOCUMENTS AND TIINGS TO DE PRODUCED Page 1

-_ 2706

DEC. -19’ 9: IFRI I 14: 15. RIDER CAYPEEL TEL:! 14 630 9996

Ywactto~~ tanlyrhtdonrmcntsand~ ia~~~ p~~ i~ but also those over which you bave Andy or control, includiq but not l&& d to d4cument3 and things in tbc postion, custody, or contnll of yuur lIgellt( s), your acrmmtantfs), you artameyo, w investigatm CmploW by you or by rota attmhs). or any consultant or expert wi! ness employed hy you or by your attnmcy( s).

If, in tespot~~ c to a particular quest, an objection is i. nteqmsed, and tie oI+ ction 8ppIies to some but Llot aU of the documents nquc.. pIease pdnce all responsive

document and things to wbioh the objection dots not apply. p~ oul$ jT FOR P’RODU~ ON NO. I: Every documcni n& sting to any priv& uiietings behvecn you and Dcfcadant CJlixbm including any agendas, letters, journals, diariy~ noteq lapencordingsorxn~

-FOR- Evely dfmzumult wnstituting or l2onth& i

ccznmunicruionc between you and Dekuiant Clinton, including ktkra, ciirds, notes IIEIIIO~~~~, andallfclcplollere# rrds, notesormcmorandareac~ callstaor~ any t& phone in the Wbitc House, the P- on, any governmental nffice or propaty, or your

home or o& c, any cellular or mobile telephcme, or to or htn ay other t& phone ~UIII~ JCKS of Bill CIinm &r you or myoiie acring tbr or on behalf of him or you.

Ijj? OT TFST FOBE& nDU~ NO. 6: Evuy docatment &ring to any ccmmnk&,,, s withallycnzcconccming~- iuvohiug you and Dcfcndm Clhm, includiug any

am, lcttcrs, jOtIHdS, diaries. MtCS, time TCCOrck emPioymcnt records. tape TdhF

or memoranda. r 902- DC40000137

EXHIBITA- DOCUMENT S AND THINGS TO BE PRODUCEU

2707 -- DEC. - 19’ 9’ (FRl 1 14: Ii RADER CAWI~ LL ILL:; ls OJU YYYO .I

~CW’l3I’ FOR PRODUCTION NO. 8: Please produce each and e= q’ document ~eationjmg~ dcocribinganygiftgivcntoyoubyD&~-

EXHIBIT A - DOCUMENT S AND TIlINCS TO BE PRODUCED

2708

Dec. 22 LI~~+ MY -----

--- -- ---- i _-----.

--- j,: _.__~.~. -__- 1: if __--- .- -- _ _.._ _-- i .-

--___.-- -._-

2709

Jan. 5 Mc+ mAY

r -

!302- DC- 00000232

2710 902~ Dc- ooooO251

2711

PMX HYATT - WWINGTU1, D. C

K3JXJSE -GHHx: - 1SOl

TAKE: 8/ l

YhVEk 101 LIsb MTE: J& 407’ % W57AH~ WD TYFE: m1Gw EmEss

E& zE: ZF- AJTH cm: 9x042

VEJCRDIW

2712 ,

Issued by the UNITED STATES DISTRICT COURT

DISTRICT OF IA

PAU’ A JONES. PLlilldfl SUBPOENA IN A CIVIL CASE

V. CASENUMBER. ’ LR- C- 94- 290 wXLLiM JEFFERSON CtnrrON

ud DArVh’ YFERCiUSON~

DrfrnhJUS 92o-~ Mx) ooo13

To: MONICA LEWINSKY MMANDED tn appear in the United States Disukt Court at the place, date, and time specified b& w to testify in the above case.

PUCE OF TESITMOXY coiRlxonM

PLACE OF DEPosmQN MlF. AtmlmE The Rurhcrford lnscitute Friday. Januq Z& l998 733 15th Sireel NW.. Suite 410 930 am. Washingxon. DC 20005

iBYOU ARE co MMANDEDto~ mdpcrmit~ onmdcopyingofttrfouo~ dowmcn5orobjectsuthepLce, dut. and time specified below (list dOcumeo ts or objtctr):

Erhibtr A. mxkd kmn. PUCE DATEANDTIME

The Rutherford lnnirute Friday. January 23.1998 733 15th Sm NW.. Suite 410 930 a. m Washington. DC 20005

@ YOU ARE COMMANDED to pamit inspection of the following prcmiKs at the date and time specified below.

PREHISEI DATEAp( DTME

Anyo~ tion114ta~~ rhisruirthat~ atbpoenacdfOrthC~ gOfa~ tionsballdaignavoncormomoffi~ dircc! oa, or managing ageno. or otba pcrsous wbo ConSalt to rcstify 00 if3 bcbalz and my set for& for each petson designaud, the maners on which tic pason designzted. the tuattm on which the pmon will mtify. Fcdmal Rules of Civil ~% x& tre, 30( b) (6).

ISSLW omckxa svxuuu -1~~~ tn4tx. 4~~ IF ATTMINEY rnn rwtfrn on DEENMml DATE

(I&, b ,ATl- ORNEYFORPL4INIEF . December 17. 1997 1

ISSLING OFFICER’ S NAME. ADDRESS AMI PI+ NUMB=

Donovan Campbell. Jr., Rader. Campbell, Fisher & Pyke, Stcmmorts Ph, Suite 1080. 2777 Stcmmons Freeway. Dallas, Texas 75207. (214) 630- 4700

(se Rule 45, F& ml Rules of Civil Procedure. Pans C & D on Reverse) ’ If mm IS pmdtng in dim- in other than diet of issuma. splc diiet under ease nunlber.

2713

PROOF OF SW Date Pk

SEWED

SERVED ON (- f'RIKT NAME) MANNER OF SERVICE SERVED BY (PJUNT NAME)

OFS; BVER

f &dare under penalty of pajuxy under the laws of the Unita! Smcs of Amcria th8t tt~ f0regoing infomation conmined in the Prmf of SCWiCCiSttUC aodaKrccf.

Excfutedan Date SignrtrPeofSava

AddnsofScrYer

lwc4J. FukdRuksofm- P8naCktk

2714

OFOF- Rate Pk

SERVED

12- 19- 97 AT 4: oo P. M. TJE PElVTAUlFJ. ABLIBGTOB. VA sE~ v’ m ON (PRINT NAME9 MANNER OF SERVICE

MOBICB LERIBskp

SERVED BY (PRINT NAME)

RuJc 45. Feded RI& S of Civil PVdLOC. RlltC& D:

2715 EXHIBIT A’ DO- S AM> TxrNGS TO BE PRODUCED pursuant to the Federal Rules of Civil pn> ctdurt, the Deponent is directed to produce, at the time and place of the Deponent’s deposition, all of the documents and tangible things described in the enumerated requests below. In responding to the following requests for pro&& on, the Deponent is directed to comply with the fohowing instructions and to apply the foIlowing de& itiolls.

DEFINITIONS For the purposes of these requests, the following definitions apply: “Defendant CLinton” means William Jefferson Clinton. “Defendant Feqtson” means Danny F- OIL “Document” means any tangiilc thing on which appears, or in which is stored or contained, any words, numbers, symbols, or images The term “document” includes any and all writings, drawings, grap4 charts, photographs, tape recordings, video recordings, phono records, and other data compilations fkom which inkmafion can be obtained and translated, if nec: ssary, tbrougb detection devices, into reasonably usable fona

“Person” means any identifiable entity, including but not limited to individuals, corporations, partnerships, sole proprietorships, and unincorporated associations.

“You” means the Deponent INSTRUCTIONS A request for any particular document or thing is a request for the original, for each and every photocopy or duplicate of that document or thing, and for each and every draft of the document or thixq K however, you produce the original of the document or thing, you are not required to produce any photocopies or duplicates unless they are not identical (as, for example, when marginal nctations are made on a copy).

The documents and things to be produced should, at the time of production, be organized and labeled to correspond to the enumerated requests below. In the alternative, they may be produced as they are kept in the ordinary course of business, ifit is possible to do so.

EXHIBIT A - DOCUMENTS AND THINGS TO BE PRODUCED Page 1

2716 You are to produce not only the documents and th@ in your immediate possessiotr, but also those over which you have custody or control, mciuding but not limited to documents and things in the possession, custody, or control of your agent( s), your accountant( s), your attomy( s), any investigator ~@ oY& by YOU or by your attorney( s), or any consultant or expert witness employed by YOU or by your attorney( s).

If, in response to a particular request, au objection is interposed, and the objection applies to some but not all of the documents requested, please produce all responsive documents and things to which the objection does not apply.

REOUESTS FOR PRODUCTION REOUEST FOR PRODUCTION NO. 1: Every document relating to any private meetings ~~ SV~ IZXI YOU and Defendant Clinton, including any agendas, letters, journals, diaries, notes, tape recordings or memoranda

OUEST FOR PRODUCTION NO. 2: Evq document constituting or containing communications between you and Defendant Clinton, including letters, cards, notes memoranda, and all telephone records, note- s or memo= da~ refkting calls to or from any telephone in the White House, the Pentagon, any govemrrrenti office or property, or your home or office, any cellular or mobile telephone, or to or from any other telephone numbers ofBill Clinton or you or anyone acting for or on behalf of him or you.

REOUEST FOR PRODUCTION NO. 3: Every document concerning any commtm& tions with persons other than Defendant Clinton which reference any relationship or any private meetings between you and Defendant Clinton.

REOUEST FOR PRODUCTION NO. 4: Every document concerning any CO~ ITUX&&~ S with persons other than Defendant Clinton which rcfaenct any relationship or any private meetings between you and Defendant Clinton.

REOUEST FOR PRODUCTION NO. 5: Evexy calendar or address book or other document reflecting any meetings between you and Defendant Clinton or reflecting the address or tckphone number of Defendant Clinton at any location.

REOUEST FOR PRODUCTION NO. 6: Every document relating to any commm& ations w- 21 anyone conc: ming any oc cummce involving you and Defendant Clinton, i. nclu& mg any agendas, letters, journals, diaries, notes, time records, employment records, tape recordings or memoranda.

E, YiIIBIT A - DOCUWEXTS AND THINGS TO BE PRODUCED Page 2

2717

REOUEST FOR PRODUCTION NO. 7: Please produce each and every gift including, but notlimitedto, a! lyandallctrtsses, acasories, and jewelry, and/ or hat pins given to you by, or on bchalfo~ Dcfidant Clinton

REOUEST FOR PRODUCTION NO. 8: P@ se produce each and every document mentioning or &scribing any gii’t given to you by Defendant Clinton.

920- Dc- OOOOOO18

EXHIBIT A - DOCUMENTS AND THNGS TO BE PRODUCED Pqe 3

2718

PAULA CORBIN JONES V WILLIAM JEFFEkSON CLINTON

SEALED DOCUMENTS

2719

2720

NntinnsRnnk. N. A. Regional Center. VA21Z5i%~ 1 PO. Box 27025 Richmond. V. 4 M& l- 7tlL5

HONICA S LEWINSKY - ReguIar Checking Additions and Subiractions

Date Posted Amount( S) Result-

Balanced ) “If; Transaction

07- 07 07- 07 07M

iE! i 07- 16 07- 18 07- 18 07- 18

07- 21 07- 21 07- 21 07- 21

E% 07- 21 07- 21 07 -22 07- 22

Oi -23 07- 23 07- 24 07- 25

07- 25

07- 25 07- 28 07- 28

1.5@ 1.5s

L5O- 1% 25- 966.25,

200* 00- 101.50-

50.00- 1.50-

201.5& 160.0@ lOO. OO-

70.31- 77.30-

1.% X L%?- 1.50- 4.60- 0.00 6o. och

80.00- 100.49- 1,290.53+

30.0@ 1.50- 0.00 16O. O( r

193.22 191.72 190.22 176.97 lJ43.22

943.22 Ml. 72 791.72 790.22

588.72 428.72 328.72 258.41

:x 178.11 176.61 172.01 172.01 232.01

15201 51.52 1.342.05

i, 312.05 1.310.55 1.310.55 1.15055

Edsf7- 11 07104 #6OO@ X& l Withdnvl 1500 S. Fern St. Arlington. VA Fee Chevy Chase Fe 07106 #000117101 Withdrwl

Chevy Chase Fe ~~~~~~ D~ i~~, Safeway t928 Ceo ChS etown 5y6kM WashingtonDC DC Fee Da0 Cl Eff Date: 970711 Des= fed Saiary ID= NationsBank ATM 07/ 16 #6fIOOO1861 Withdrwl

G& y City Mrkt Los- Angeles CA- 319 BOfA 07117 #000056215 Withdml (Ber& urAy City Mrkt Los Angeles CA Fee

07/ 19 #ooO124805 Withdrwl Beverly Hills Mai Beverl Hills CA Ub of CA 07120 ~~ 2 Withdrwl Brentwood W/ U Cnb Los Angeles CA

07119 #000426& 33 Withdrwl 9229 Sunset Blvd. Los AngeIes, CA White Dove 07118 ifooO742817 Purchase White Dove Santa Monica CA Check 320 BOfA 07/ 19 #000l! 24805 Withdrwl Beverly Hills Mai Beverly Hills CA Fee Cnb 07119 #~ Withdrwl F”, S; set Blvd. Los Angeles, CA Fee

07120 #6C@ OOO42 Withdrwl Brentwood WfU Los Angeles CA Fee Check 321 Fee For Electronic Account Inquiry NationsBank ATM 07123 #~ 39~ Fr Sav Pentagon N. C& x Washington VA Check

Check 35i Dao Cl

EfT Date: 979725 Des= fed Salary ID= s Citibank 90456 07124 ~~~~~ 4 Withdnvl loo0 COM Av NW DC Citibank 90406 07124 &?:$ 9: 4 Withdrwl 1000 Conn Av NW Fee For Electronic Account nquiry r DC Fee NationsBank ATM 07/ 28 fOOOOO7065 Withdnvl Pentagon N. Cone Washington VA

929- DC- 00000056

2721

ACTIVITY REPORT OCTOBER, 11, 1997

SATURDAY I . . .=. -- THIS -sHIi? IL~~ I~ D .. 'I*, %. lXl-, THE- PRESIDENT

WAS ON THE SECOND FLOOR RESId'iN? E.- PROTECTEE MOVEKENTS: 0952 f POTUS MOVED TO TBE OVhc OFFICE. 1028 BRS POTUS MOVED 'I'0 !JXE OVAL STUDY.

;JBE3. TEiISI. SHIFTWAS: RELIEVED BY !lTKE pf&.. Dm- ti.. .& '-, ov~~~ oFpIcE, ZXLIFT, THE ********* t* f* ttttttt* t************~******************~*********

952~ DC- 00000060 -

c ”

2722

RECORD TYPE: PRESIDENTIAL (NOTES HAIL) CREATOR: Betty W. Currie ( cN= Betty W. Currie/ OU= WHO/ O= EDP [ WHO J ) CWATION DATE/ TIME: 6- DEc- 1997 12: 05: 03. O'J SUBJECT:: TO: BRUCE R. (Pager) #LINDSEY ( BRUCE R. (Pager) #LINDSEY [ UNKNOWN ) ) READ : UNKNOWN

TEXT: Call Betty ASAP 0

%4-~ C- OOO00862

11: 15 2m- J lJa3am 11: 32

12: 30 pm- 690 pm

630 pm- 6: 15 pm

6: 15 pm- 6: 45 pm

BC AND EJRC RON

2723

MEETING OVAL OFFICE staff Contacr: %CJ$ w& m Hew@ 3 ,

BRIEFING OVAL OFFICE I 2: Yb Staff Contact: Sandy Berger ,2:+

MlBTING CABINET ROOM Staff Chum: Sarxly Berger. Rabm Emanuel

PHONJZ’OFFICE TIME OVAL OFFICE

BRIEFING OVAL OFFICE Staff Contact: Don Baer. Michael Waldman

TAPE R4DIO ADDRESS ROOSEVELT ROOM Staff COE. UCC Megan Maloney

THE WHITE HOUSE %8- DC- OOOOOO73

REDACTED z-

2724

WASHIYCTQY D. C. THIV~ D~\, N~ WIBER 13.1997

5: IO pm- COYG~ Sr, lON~ L RECEPTION h: OO pm STATE DINING ROOM

Staf: Contact: John HilIe\ Event Coordinator: Setti Warren CLOSED PRESS

Note: Call time for Congressional Members for 5: OO pm.

-- The President will meet and greet infwrnall~~ ivith 40 Congressional Members.

(,:? J em-

6:- l< pm BRIECING

RESIDENCE Staff Contact: Sandy Berger

6:- l- pm- S:.? S pm

PRIVATE DINNER WITH I’RESIDENT ZEDILLO OF MEXICO RESIDENCE Staf? Contact: Sandy Berger Event Coordinator: Setti Warren OFFICIAL PHOTOGRAPH ONLY

9@ 34% 00000187

$ ill (1fn THE PRESIDENT departs The White House via motorcade en route Private Residence [drive time: 35 minutes]

THE PRESIDENT arrives Pri\. ate Residence

lllllllll~ lllll lllll11111 II lllllllli illI 0 003547

2725

Saturdav, Ms= ch 29, 1397 Daynotes

0 The President talked, today, w) Lh 5: 38 p. m. , 9: 17 p. m.

, 9: Ol 11. m , f3: j2 p. n- , 0 I) ', :L:: ' , 'f : Ii7 1). 11, , IO: 44 p. m.

11: 12 a: m. 11: 23 a. m.

11: Sl a- n. 4: 14 p. m.

%8- DC- 00000236

2726

The President, left out of the Oval offlce do& r far the helicopter at 2: 20 0. m. ant'

0 The President arrived at Fort McHenry in Baltimore at 2: 50 p. m. r.

The President arrived at the hotel at 3: lO p. m.

%8- DC- oOOO263

. At 1 p. m., the President made Remarks on the Budget Accord: lnlsllMllllllllUnlellRn

0 003623

2728

PRESS SCHEDULE OF THE PRESIDENT FRIDAY, APRIL 5, 1996 PAGE 2

850 am 9: 20 am 9: 30 am 9: 45 am

THE PRESIDENT plants a tree in memory of Secretzuy of Commerce, Ronald H. Brown The South Lawn lNHOUSE POOL COVERAGE ONLY

Press Note: At the conclusion of the planting, the Inhouse Pool wiN be esconed IO the Marine One departure area

THE PRESIDENT departs the White House via Marine One en route Andrews AFB. MD The South Lawn OPEN PRESS

Press Note: R& s Set- Up Scenario for South Lawn 8: 45 - 9: lO am - Cabling, Mults & Pre- Set 9: lO - 9: IS am - ESCORS to South Lawn 9: lS am - FINAL Access to Departure

THE PRESIDENT arrives Andrews AFB, MD and boards Air Force One OPEN PRESS

THE PRESIDENT departs Andrews AFB, MD via Air Force One en route Oklahoma City, Oklahoma AF- I Travel Pool accompanies on board

FOR INFORMATION REGARDING THE PRESIDENT’S SCHEDULE WHILE IN

OKLAHOMA, PLEASE REFER TO THE WHITE HOUSE TRAVELING PRESS SCHEDULE, AVAILABLE IN THE WHITE HOUSE PRESS OFFICE

6: 20 pm C THE PRESIDENT departs Oklahoma City, Oklahoma en route hdrews -. MD AF- 1 Travel Pool accompanies on board %8- Dc- oaeu@ 841

-MORE-

PRESS SCHEDULE OF THE PRESIDENT SUNDAY, AUGUST 17, 1997

EDITOR’S ADVISORY: FOR NEWS PLASSING ONLY NOT FOR PUBLICATION OR RELEASE

lntown Travel Pool Wires: AP. Reuter, UP1

Wire Photo: AFP. AP. Reuter, UPI TV Corr & Crew: NBC Lights: NBC Mag Photo: USN& WR

Radio: ABC Radio

Print: USA Today

lnhouse Pool

All of rhe l~~ mw~~ pool plus:

Net Cuts: NBC Mults: NBC Independent Pool: Reuters

8: 00 am Intown Travel Pool gathers, WI- I Briefing Room, for protective purposes

PRESS PLANE DEPARTURE SCENARIO TO MARTHA’S VINEYARD. MASS

lO: OO- 11: OO am - Gear and Baggage Call 10: 30- 11: 30 am - Passenger Check- In for press charter

1 I: 45 am - Passenger Check- In Ends 12: 15 pm - Press Charter Departs to Martha’s Vineyard. MASS

12: IS pn1 AF- I Travel Pool Check- In, Andrews AFB, Maryland. Operations Terminal

AF- I Travel Pool

Wires: AP, Reuter, UPI Wire Photo. AP. Reuter. AFP

TV Corr Rc Crew: NBC Mag Corr Newsweek Mag Photo- USN& WR Radio CBS Radio Prim Rnsron Globe

2730

Prers Schedule TRTP OF THE PRESIDENT

to Denver, Colorado; Seattle, Washington; and Vancouver. British Columbia. Canada Saturday. November 22 - Tuesday, November 25

NOT FOR BELEAsE OR Pm- For news planning only

Weather/ Denver: Mostly cloudy; no rain. High 49. low 24 Weather& attle: Rain. High SI. low 43. WeatherNancouver: Saturday: Showers, high 51, low 50.

Sunday: Rain likely, high 54, low 35. Monday: PartIy cloudy. high 43. low 31.

REMXVDER: Your check- in on Saturday is for an international dqarture. Please be on time with yourselves, your bags and gear. Remember you MUST have your valid passport with you for this check- in

“8- J= moo330o VANCOUVER NOTES: The International Press Center and Television workspace is located in the Vancouver Trade and Convention Center (VTCC). located directly across

the streetfrom the Wate@ ont Center Hotel (there is also an underground connector). The only time when access will be dt& ult will be between 2 and 5 pm on Monaky~ when the leaders are holding their meetings there. Pleaseplan accordingly,

Due to security neeo! s. the Waterfront Center Hotel rooms have been reservedforfour nights (even though we are only spending three). Therefore, you will be chargedfor Tuesday. so there is no need to check- out early.

For those in APEC Pools. expect to be standing outside for extended periods (even ifyourpool is indoors)- so, bepreparedcwith a coat and umbrella.

2733

March 1996

i i I

HILLARY RODHAM CLINTON

GL, HI, LA. MS. MO. OK. Ri, m. Tx Primatics

It. MI. OH Primtics

2734

July 1997 HILLARY RODHAM CLINTON

October 1997 HILLARY RODHAM CLINTON

2736

December 199 7

HILLAR Y RODHM CLINTON (21

2739

THE WHITE HOUSE

WASHINGTON

PRESIDENTIAL CALL LOG

MAY 'st .ne 97

OFC: WASHINGTON D. TLKD- OK 3: 32 P- n. OK: BOSTON, MA.

CONGAESSlrlAN JOHN M. SPRATT. JR. TLKD- OK 'I: 20 P. M. OFC: WASXINGTON. D. C.

2740

THE WHITE HOUSE

WASHINGTON

PRESIDENTIAL CALL LOG

KAY 24th 97 .I9 - TIME NAME ACTION PLACED DISC =W 8: oo AM 8: 00 WAKE- UP BY WHITE HOUSE OPERATOR COMPLETED 8: oo A. M.

INC &ax our AM

INC

w vi MR. DANIEL R. SHANKS TLKD- OK 5: 59 P. M. OFC: WASHINGTON, D. C. ,NC 5: 59 pn 5: 59 WHITE HOUSE ADMIN EXTW OUT AM

INC

937 xz REVEREND REX HORNE RFS: LITTLE ROCK, AR.

,NC 9: 57 PM 9: 59 - TLKD- OK 9: 58 P. M.

2741

THE WHITE HOUSE

WASH I NCTON

PRESIDENTIAL CALL LOG INC

OUT 10: 19 If: 10: 2! Xm our AM

INC PM 93fx 10: 24 AH 10: 38

INC Xo[ bl OUT AM I INC OUT 10: 50 If: 10154

Xi+% XWM OUT AM INC 9[# X Xi;

'NC 3.46 PM 4_

.iuLY .19 97

NAME ACTION

MESSAGE: ME 8: 00 A. M.

THAJj& (1

'MR. BRUCE R. LINDSEY CELLULAR PHONE TLKD- OK lo: 22 A. M.

NO NUMBER AVAILABLE MS. NANCY V. HERNREICH WASHINGTON, D. C. TLKD- OK IO: 25 K. N. NO NUMBER AVAILABLE

MS. STEPHANIE S. STREETT RES: WASHINGTON, D. C. TLKD- OK lo: 37 A. M. II

MR. JOHN D. PODESTA OFC: WASHINGTON, D. C. TLKD- OK lo: 51 A. M. WHITE HOUSE ADM. EXT. )

SECRETARY ROBERT E. AUBIN TREASURY OPERATOR TLKD- OK 3: 46 P. N.

NO NUMBER AVAILABLE

%8- DC- 00003546

2742

THE WHITE HOUSE WASHINGTON

PRESlDENTlAL CALL LOG

GULY il; th .I9 q7

TIME NAME PLACED DISC

CONFERENCE CbLi MR. BOB BENNEXT

c): qq PM ul; qq LIVINGSTON. XT.

OUT AM ‘W

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PRESIDENTIAL CALL LOG

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Thursday, November 13, 1997

The Iraq problem continue to escalate, in spite of the UN's resolution yesterday condeming their actions against American soldiers. The President responded to thei= threats yesterSay to expel2 Americans from the country, wit5 his own conderr_. ation and warnings, during remarks before a Bill signing.

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Today...

The President arrived at the Oval office at 8: 05 a. m., and had an 8: 15 a. m., Foreign Policy Meeting this morning in the Cabinet Room.

Participants in this meeting were: Veep,. Sec. Albright, Sec. Cohen, Ambassador Richardso, CIA Director Tenet, Erskine, Sandy, Gen. Shelton, Ambassador Pickering, Slocombe, Steinberg, Fuerth, Riedel, Welch, Pace King.

At 9: 15 a. m, the President made a foreign policy call to At 9: 45 a. m., the President Signed the Labor/ Health/ HHS bill in the Oval Office.

The President golfed with Congressional leaders today from I2 noon to 4 p. m. at the Army/ Navy Golf Course in Arlington (18 holes)

The President greeted 50 guests in the State Dining Room at 5: 22 p. m-, at a Reception for Democrats who supported the FastTrack Bill.

Attendants at the Reception, included: Representatives: Ken Bentsen, Marion Berry, Earl Pomeroy, Harold Ford, Jr., Robert Matsui, Sheila Jackson- Lee, William Jefferson, E- B. Johnson, David Price, Anna Eshoo, Bob Clement, Jim Davis, Cal Dooley, Vie Fazio, Norm Dicks, Vick Synder, Charles Stenholm, Ike Skelton, David Skaggs, Ellen Tauscher, Jane Harman, Matthew Martinez, Lloyd Doggett, Jim McDermott, Chet Edwards, Bob Etheridge, Ralph Hall, Lee Hamilton, Darlene Hooley, Zoe Lofgren, James Moran, Owen Pickett, John Tanner, Peter Deutsch.

Administration officials included: Secretary Glickman, Daley, Albright, Shalala, Richardson, Browner, Pena, Slater, Alvarez, Herman, Berger, Goodie and Silverman.

He proceeded to the Oval at 6: 34 p. m. He was briefed by Sandy, Tarullo, Brainard and Dobbins. He took a Foreign Call

at 6: 47 p. m. 968-~~- 00003799 REDACt ‘ED