The History Place - Presidential Impeachment Proceedings

President Clinton's Deposition
January 17, 1998

(Below is an excerpt from the deposition given under oath by President Bill Clinton in the Paula Jones sexual harassment civil lawsuit. The excerpt contains questions posed to the President by Jones's lawyer James A. Fisher concerning the President's relationship with Monica Lewinsky.)

Question. (from Jones's lawyer) Now, do you know a woman named Monica Lewinsky?

Answer. (by President Clinton) I do.

Q. How do you know her?

A. She worked in the White House for a while, first as an intern, and then in, as the, in the legislative affairs office.

Q. She began � excuse me.

A. So that's how I know her.

Q. Excuse me for interrupting you, sir. Did she begin to work as an intern in the White House in the summer of 1995?

A. I don't know when she started working at the White House.

Q. Do you recall when you met her for the first time?

A. It would be sometime, I'd think, in later 1995.

Q. She began to work in the White House office of legislative affairs around December of 1995, correct?

A. I have no idea.

Q. Do you know how she obtained that job?

A. No.

Q. Did you ever talk to anyone about finding a job for Monica Lewinsky?

A. When she got the job in the legislative affairs office? No.

Q. Before she got that job.

A. No.

Q. Did you ever talk to anyone about the possibility of her obtaining a job in the White House?

A. She, she came there as an intern, and as several of them have, she applied for some job there apparently and got the job. I was not involved in her moving from being an intern to being a full-time employee. I had no involvement in that whatever.

Q. And you never talked to anyone about that?

A. No, I did not.

Q. In April of 1996 she was offered and she accepted a job as assistant to the assistant secretary for public affairs at the U.S. Department of Defense; is that correct?

A. I don't know when she went over there.

Q. Is it correct that she did accept that job at some point?

A. I don't know what her specific job was. I know that she moved over to the Department of Defense.

Q. And worked at the Pentagon, correct?

A. Well, she worked for the Department of Defense. I think that's where all their offices are in Washington.

Q. Is it true that when she worked at the White House she met with you several times?

A. I don't know about several times. There was a period when the, when the Republican Congress shut the government down that the whole White House was being run by interns, and she was assigned to work back in the chief of staff's office, and we were all working there, and so I saw her on two or three occasions then, and then when she worked at the White House, I think there was one or two other times when she brought some documents to me.

Q. Well, you also saw here at a number of social functions at the White House, didn't you?

A. Could you be specific? I'm not sure. I mean when we had, when we had like big staff things for, if I had a, like in the summertime, if I had a birthday party and the whole White House staff came, then she must have been there. If we had a Christmas party and the whole White House staff was invited, she must have been there. I don't remember any specific social occasions at the White House, but people who work there when they're invited to these things normally come. It's a � they work long hours, it's hard work, and it's one of the nice things about being able to work there, so I assume she was there, but I don't have any specific recollection of any social events.

(Short recess)

Q. Mr. President, before the break, we were talking about Monica Lewinsky. At any time were you and Monica Lewinsky alone together in the Oval Office?

A. I don't recall, but as I said, when she worked at the legislative affairs office, they always had somebody there on the weekends. I typically worked some on the weekends. Sometimes they'd bring me things on the weekends. She � it seems to me she brought things to me once or twice on the weekends. In that case, whatever time she would be in there, drop it off, exchange a few words and go, she was there. I don't have any specific recollections of what the issues were, what was going on, but when the Congress is there, we're working all the time, and typically I would do some work on one of the days of the weekends in the afternoon.

Q. So I understand, your testimony is that it was possible, then, that you were alone with her, but you have no specific recollection of that ever happening?

A. Yes, that's correct. It's possible that she, in, while she was working there, brought something to me and that at the time she brought it to me, she was the only person there. That's possible.

Q. Did it ever happen that you and she went down the hallway from the Oval Office to the private kitchen?

MR. BENNETT: (Clinton's lawyer) Your Honor, excuse me, Mr. President, I need some guidance from the Court at this point. I'm going to object to the innuendo. I'm afraid, as I say, that this will leak. I don't question the predicates here. I question the good faith of counsel, the innuendo in the question. Counsel is fully aware that Ms. Jane Doe 6 has filed, has an affidavit which they are in possession of saying that there is absolutely no sex of any kind in any manner, shape or form, with President Clinton, and yet listening to the innuendo in the questions �

JUDGE WRIGHT: No, just a minute, let me make my ruling. I do not know whether counsel is basing this question an any affidavit, but I will direct Mr. Bennett not to comment on other evidence that might be pertinent and could be arguably coaching the witness at this juncture. Now, I, Mr. Fisher is an officer of this court, and I have to assume that he has a good faith basis for asking the question. If in fact he has no good faith basis for asking this question, he could later be sanctioned. If you would like, I will be happy to review in camera any good faith basis he might have.

MR. BENNETT: Well, Your Honor, with all due respect, I would like to know the proffer. I'm not coaching the witness. In preparation of the witness for this deposition, the witness is fully aware of Ms. Jane Doe 6's affidavit, so I have not told him a single thing he doesn't know, but I think when he asks questions like this where he's sitting on an affidavit from the witness, he should at least have a good faith proffer.

JUDGE WRIGHT: Now, I agree with you that he needs to have a good faith basis for asking the question.

MR. BENNETT: May we ask what it is, Your Honor?

JUDGE WRIGHT: And I'm assuming that he does, and I will be willing to review this in camera if he does not want to reveal it to counsel.


MR. FISHER: I would welcome an opportunity to explain to the Court what our good faith basis is in an in camera hearing.

JUDGE WRIGHT: All right.

MR. FISHER: I would prefer that we not take the time to do that now, but I can tell the Court I am very confident there is substantial basis.

JUDGE WRIGHT: All right, I'm going to permit the question. He's an officer of the Court, and as you know, Mr. Bennett, this Court has ruled on prior occasions that a good faith basis can exist notwithstanding the testimony of the witness, of the deponent, and the other party.

MR. BENNETT: Yes, Your Honor, but you understand, and I'm not arguing with you what my concern is, Your Honor, I wouldn't have any trouble with that if I knew that this deposition would be kept under seal. But when he mentions names, when he knows, or at least, you know, hearsay, hearsay, hearsay about something, they check it out, they get an affidavit from the woman, they ask these questions, and the Washington Times will have her name on the front page tomorrow or the day after.

JUDGE WRIGHT: As you know, I'm extremely sympathetic with your position, however this is a discovery deposition.

MR. BENNETT: I understand. That's all right, Your Honor. I'm sorry.


MR. FISHER: Thank you, Your Honor.

THE WITNESS: What was your question again, sir?

MR. FISHER: I've forgotten, Mr. President, I'm sorry.

JUDGE WRIGHT: Something about Ms. Jane Doe 6 in the hallway.

Q. Do you recall ever walking with Jane Doe 6 Lewinsky down the hallway from the Oval Office to your private kitchen there in the White House?

A. Well, let me try to describe the facts first, because you keep talking about this private kitchen. The private kitchen is staffed by two naval aides. They have total, unrestricted access to my dining room, to that hallway, to coming into the Oval Office. The people who are in the outer office of the Oval Office can also enter at any time.

I was, after I went through a presidential campaign in which the far right tried to convince the American people I had committed murder, run drugs, slept in my mother's bed with four prostitutes, and done numerous other things, I had a high level of paranoia.

There are no curtains on the Oval Office, there are no curtains on my private office, there are no curtains or blinds that can close the windows in my private dining room. The naval aides come and go at will. There is a peephole on the office that George Stephanopoulos first and then Rahm Emanuel occupied that looks back down that corridor. I have done everything I could to avoid the kind of questions you are asking me here today, so to talk about this kitchen as if it is a private kitchen, it's a little cubbyhole, and these guys keep the door open. They come and go at will. Now that's the factual background here.

Now, to go back to your question, my recollection is that, that at some point during the government shutdown, when Ms. Lewinsky was still an intern but was working the chief staff's office because all the employees had to go home, that she was back there with a pizza that she brought to me and to others. I do not believe she was there alone, however. I don't think she was. And my recollection is that on a couple of occasions after that she was there but my secretary Betty Currie was there with her. She and Betty are friends. That's my, that's my recollection. And I have no other recollection of that.

MR. FISHER: While I appreciate all of that information, for the record I'm going to object. It's nonresponsive as to the entire answer up to the point where the deponent said, "Now back to your question."

Q. At any time were you and Monica Lewinsky alone in the hallway between the Oval Office and this kitchen area?

A. I don't believe so, unless we were walking back to the back dining room with the pizzas. I just, I don't remember. I don't believe we were alone in the hallway, no.

Q. Are there doors at both ends of the hallway?

A. They are, and they're always open.

Q. At any time have you and Monica Lewinsky ever been alone together in any room in the White House?

A. I think I testified to that earlier. I think that there is a, it is � I have no specific recollection, but it seems to me that she was on duty on a couple of occasions working for the legislative affairs office and brought me some things to sign, something on the weekend. That's � I have a general memory of that.

Q. Do you remember anything that was said in any of those meetings?

A. No. You know, we just have conversation, I don't remember.

Q. How long has Betty Currie been your secretary?

A. Since I've been president.

Q. Did she also work with you in Arkansas?

A. Not when I was governor. She worked in the transition. She worked for Warren Christopher in the transition, and then she came to work for me.

Q. How is her work schedule arranged? Does she have a certain shift that she works. or do you ask her to work certain hours the following day? Please explain how her schedule is determined.

A. She works, she comes to work early in the morning and normally stays there until I leave at night. She works very long hours, and then when I come in on the weekend, or on Saturday, if I work on Saturday, she's there, and normally if I'm, if I'm working on Sunday and I'm having a schedule of meetings, either she or Nancy Hernreich will be there. One of them is always there on the weekend. Sometimes if I come over just with paperwork and work for a couple of hours, she's not there, but otherwise she's always there when I'm there.

Q. Are there any other individuals who are specifically assigned to be your secretary?

A. No, just Betty. Betty and Nancy Hernreich basically runs the outer office for me. They are my two major assistants, and of course, and there are a couple of other people who work with them, Janice Kearney who keeps my, in effect, diary now of what's going on, who's been � she's been doing that maybe a. . .

Pages 61 to 64 of the deposition missing

A. I don't know.

Q. Have you ever met with Monica Lewinsky in the White House between the hours of midnight and six a.m.?

A. I certainly don't think so.

Q. Have you ever met �

A. Now, let me just say, when she was working there, during, there may have been a time when we were all � we were up working late. There are lots of, on any given night, when the Congress is in session, there are always several people around until late in the night, but I don't have any memory of that. I just can't say that there could have been a time when that occurred, I just � but I don't remember it.

Q. Certainly if it happened, nothing remarkable would have occurred?

A. No, nothing remarkable. I don't remember it.

Q. It would be extraordinary, wouldn't it, for Betty Currie to be in the White House between midnight and six a.m., wouldn't it?

A. I don't know what the facts were. I mean I don't know. She's an extraordinary woman.

Q. Does that happen all the time, sir, or rarely?

A. Well, I don't know, because normally I'm not there between midnight and six, so I wouldn't know how many times she's there. Those are questions you'd have to ask her. I just can't say.

Q. Has it ever happened that a White House record was created that showed the Monica Lewinsky was meeting with Betty Currie when in fact Monica Lewinsky was meeting with you?

MR. BENNETT: No, Your Honor, I'm going to certainly let the president answer that, but I object to the form of the question because it assumes facts not in evidence, and I again question their good faith in this line of questioning.

JUDGE WRIGHT: I overrule the objection. I will permit it. The nature of many of the responses has been he doesn't recall or he doesn't know, and so he has not outright denied it. This is discovery and I'll permit the question. Go ahead.

A. Would you repeat the question?

Q. Yes sir. Has it ever happened that a White House record was created that reflected that Betty Currie was meeting with Monica Lewinsky when in fact you were meeting with Monica Lewinsky?

A. Not to my knowledge.

Q. Are there records created of your meetings with people in the White House?

A. I believe we have a record of the people that, that see me. We have � I think there's a record of everybody that comes in and out of the White House. Of course the people who work there and have permission to be there can come in and out and move in and out of the offices, and I don't know if there are records of all those meetings or not. For example there are several of my staff people I see many times a day, and I have no idea whether there's a record of every time I see those people.

Q. All right, sir, and I appreciate that, but just to be precise I'm not asking about records of everyone coming into the White House, but I'm asking specifically about records of meetings with you.

A. The answer to that is I don't know. I mean I, Rahm Emanuel comes through that back door into the kitchen and the hallway you talked about three or four times a day, unannounced, unscheduled, sometimes at night, sometimes in the daytime. I have no idea if there's a record of every time he comes to see me. I have no idea if there's a record of every time John Podesta comes down the hall and sticks his head in and talks to me about something. I simply don't know. I don't know the answer to your question.

Q. You suspect, don't you, that there are at least some meetings that you have for which there's no written record made, correct?

A. I don't know the answer to that. They keep a pretty good record of everything I do, I think.

Q. When was the last time you spoke with Monica Lewinsky?

A. I'm trying to remember. Probably sometime before Christmas. She came by to see Betty sometime before Christmas. And she was there talking to her, and I stuck my head out, said hello to her.

Q. Stuck your head out of the Oval Office?

A. Uh-huh, Betty said she was coming by and talked to her, and I said hello to her.

Q. Was that shortly before Christmas or �

A. I'm sorry, I don't remember. Been sometime in December, I think, and I believe � that may not be the last time. I think she came to one of the, one of the Christmas parties.

Q. Did she tell you she had been served with a subpoena in this case?

A. No. I don't know if she had been.

Q. Did anyone other than your attorneys ever tell you that Monica Lewinsky had been served with a subpoena in this case?

A. I don't think so.

Q. Did you ever talk with Monica Lewinsky about the possibility that she might be asked to testify in this case?

A. Bruce Lindsey, I think Bruce Lindsey told me that she was, I think maybe that's the first person told me she was. I want to be as accurate as I can.

MR. BENNETT: Keep your voice up Mr. President.


A. But he may not have. I don't have a specific memory, but I talked with him about the case on more than one occasion, so he might have said that.

Q. Did he tell you that on the phone or in person?

A. I don't know. I talk to him and see him several times a day, so I don't know. I would have no way of remembering that.

Q. Did you talk to Mr. Lindsey about what action, if any, should be taken as a result of her being served with a subpoena?

A. No.

Q. I believe I was starting to ask you a question a moment ago and we got sidetracked. Have you ever talked to Monica Lewinsky about the possibility that she might be asked to testify in this lawsuit?

A. I'm not sure, and let me tell you why I'm not sure. It seems to me the, the, the � I want to be as accurate as I can here. Seems to me the last time she was there to see Betty before Christmas we were joking about how you-all, with the help of the Rutherford Institute, were going to call every woman I'd ever talked to, and I said, you know �

MR. BENNETT: We can't hear you, Mr. President.

A. And I said that you-all might call every woman I ever talked to and ask them that, and so I said you would qualify, or something like that. I don't, I don't think we ever had more of a conversation than that about it, but I might have mentioned something to her about it, because when I saw how long the witness list was, or I heard about it, before I saw, but actually by the time I saw it her name was in it, but I think that was after all this had happened. I might have said something like that, so I don't want to say for sure I didn't, because I might have said something like that.

Q. Was anyone else present when you said something like that?

A. Betty, Betty was present, for sure. Somebody else might have been there, too, but I said that to a lot of people. I mean that was just something I said.

Q. What, if anything, did Monica Lewinsky say in response?

A. Nothing that I can remember. Whatever she said, I don't remember. Probably just some predictable thing.

Q. Recently you took a trip that included a visit to Bosnia, correct?

A. That's correct.

Q. While you were on that trip, did you talk to Monica Lewinsky?

A. I don't believe she was on that trip.

Q. Did you talk to her on the telephone?

A. No.

Q. While you were on that trip, did you ask anyone to talk to her?

A. I don't believe so, no. Can you be more specific? I don't have any idea. I don't think so, no.

Q. While you were on that trip, did you ask anyone to meet with her?

A. Not to my knowledge.

Q. Excluding conversations that you may have had with Mr. Bennett or any of your attorneys in this case, within the past two weeks has anyone reported to you that they had had a conversation with Monica Lewinsky concerning this lawsuit?

A. I don't believe so. I'm sorry, I just don't believe so.

Q. You know a man named Vernon Jordan?

A. I know him well.

Q. You've known him for a long time.

A. A long time.

Q. Has it ever been reported to you that he met with Monica Lewinsky and talked about this case?

A. I knew that he met with her. I think Betty suggested that he meet with her. Anyway, he met with her. I, I thought that he talked to her about something else. I didn't know that � I thought he had given her some advice about her move to New York. Seems like that's what Betty said.

Q. So Betty, Betty Currie suggested that Vernon Jordan meet with Monica Lewinsky?

A. I don't know that.

Q. I thought you just said that. I'm sorry.

A. No, I think, I think, I think Betty told me that Vernon talked to her, but I, but my impression was that Vernon was talking to her about her moving to New York. I think that's what Betty said to me.

Q. What do you know about her moving to New York?

A. Just that.

Q. Is she going to move to New York?

A. I don't know. She may have already moved to New York. I don't know. My understanding was that her mother moved to New York and that she was going to move to New York and that she was looking for some advice about what she should do when she got there.

Q. Is it your understanding that she was offered a job at the U.N.?

A. I know that she interviewed for one. I don't know if she was offered one or not.

Q. Have You ever talked to Bill Richardson about Monica Lewinsky?

A. No.

Q. What's his title?

A. He's the ambassador to the U.N.

JUDGE WRIGHT: I'm sorry, I didn't hear that.

THE WITNESS: He's the ambassador to the U.N.

Q. Have you ever asked anyone to talk to Bill Richardson about Monica Lewinsky?

A. I believe that, I believe that Monica, what I know about that is I believe Monica asked Betty Currie to ask someone to talk to him, and she, and she talked to him and went to an interview with him. That's what I believe happened.

Q. And the source of that information is who?

A. Betty. I think that's what Betty � I think Betty did that. I think Monica talked to Betty about moving to New York, and I, my recollection is that that was the chain of events.

Q. Did you say or do anything whatsoever to create a possibility of Monica Lewinsky getting a job at the U.N.?

A. To my knowledge, no, although I must say I wouldn't have thought there was anything wrong with it. You know, she was a � she had worked in the White House, she had worked in the Defense Department, and she was moving to New York. She was a friend of Betty. I certainly wouldn't have been opposed to it, based on anything I knew, anyway.

Q. Well, have you ever given any gifts to Monica Lewinsky?

A. I don't recall. Do you know what they were?

Q. A hat pin?

A. I don't, I don't remember. But I certainly, I could have.

Q. A book about Walt Whitman?

A. I give � let me just say, I give people a lot of gifts, and when people are around I give a lot of things I have at the White House away, so I could have given her a gift, but I don't remember a specific gift.

Q. Do you remember giving her a gold brooch?

A. No.

Q. Do you remember giving her an item that had been purchased from The Black Dog store at Martha's Vineyard?

A. I do remember that, because when I went on vacation, Betty said that, asked me if I was going to bring some stuff back from The Black Dog, and she said Monica loved, liked that stuff and would like to have a piece of it, and I did a lot of Christmas shopping from The Black Dog, and I bought a lot of things for a lot of people, and I gave Betty a couple of the pieces, and she gave I think something to Monica and something to some of the other girls who worked in the office. I remember that because Betty mentioned it to me.

Q. What in particular was given to Monica?

A. I don't remember. I got a whole bag full of things that I bought at The Black Dog. I went there, they gave me some things, and I went and purchased a lot at their store, and when I came back I gave a, a big block of it to Betty, and I don't know what she did with it all or who got what.

Q. But while you were in the store you did pick out something for Monica, correct?

A. While I was in the store � first of all, The Black Dog sent me a selection of things. Then I went to the store and I bought some other things, t-shirts, sweatshirts, shirts. Then when I got back home, I took out a thing or two that I wanted to keep, and I took out a thing or two I wanted to give to some other people, and I gave the rest of it to Betty and she distributed it. That's what I remember doing.

Q. Has Monica Lewinsky ever given you any gifts?

A. Once or twice. I think she's given me a book or two.

Q. Did she give you a silver cigar box?

A. No.

Q. Did she give you a tie?

A. Yes, she had given me a tie before. I believe that's right. Now, as I said, let me remind you, normally, when I get these ties, I get ties, you know, together, and they're given to me later, but I believe that she has given me a tie.

Q. Well, Mr. President, it's my understanding that Monica Lewinsky has made statements to people, and I'd like for you �

MR. BRISTOW: Object, object to the form of the question. Counsel shouldn't testify, and when you start out like that, it's obviously counsel testifying. I don't think that's proper.

MR. BENNETT: Let me add to that, Your Honor wouldn't permit me to make reference to this affidavit, and I respect your ruling.

JUDGE WRIGHT: Let me, let me just make my ruling. It is not appropriate for counsel to make comments about, about these things. I don't know whether he was trying to do this to establish a good faith basis for the next question or not, but it is inappropriate for counsel to comment, so I will sustain the objection.

MR. FISHER: I understand.

Q. Did you have an extramarital sexual affair with Monica Lewinsky?

A. No.

Q. If she told someone that she had a sexual affair with you beginning in November of 1995, would that be a lie?

A. It's certainly not the truth. It would not be the truth.

Q. I think I used the term "sexual affair." And so the record is completely clear, have you ever had sexual relations with Monica Lewinsky, as that term is defined in Deposition Exhibit 1, as modified by the Court.

MR. BENNETT: I object because I don't know that he can remember.

JUDGE WRIGHT: Well, it's real short. He can � I will permit the question and you may show the witness definition number one.

A. I have never had sexual relations with Monica Lewinsky. I've never had an affair with her.

Q. Have you ever had a conversation with Vernon Jordan in which Monica Lewinsky was mentioned?

A. I have. He told me that he called � he mentioned in passing to me that he had talked to her, and she had come to him for advice about moving to New York.

Q. She had come to him for advice?

A. Uh-huh. She'd come to him for advice about moving to New York. She had called him and asked if she could come see him, and Betty I think had maybe said something to him about talking to her, and he had given her some advice about moving to New York. That's all I know about that.

Q. Where were you when you had this conversation with Vernon Jordan.

A. I don't have any idea. I talk to Vernon Jordan a lot.

Q. Do you recall whether it was on the phone or in person?

A. No.

Q. What did he say that she had said to him in response?

A. He just said she seemed like a bright, energetic young woman and she had certain interests, and he made some suggestions to her and suggested where she ought to go for interviews. That's all I know about that.

Q. Did you express any approval or disapproval of anything Mr. Jordan had done?

MR. BENNETT: I object. I don't know what that means, Your Honor. That's awfully vague and ambiguous. Could you be more specific?


Q. At the time that you talked to Vernon Jordan about his conversation with Monica Lewinsky concerning her possible move to New York, did you express any approval or disapproval?

A. I don't remember. I think he was just reporting on the meeting to me. There'd be no reason that I would have disapproved it. She was a young woman who'd worked in the White House and had gone to work in the Defense Department and was moving to New York. I would not have though there was anything wrong with that, with us trying to help her.

Q. Is it your testimony that you had nothing whatsoever to do with causing that conversation to take place between Monica Lewinsky and Vernon Jordan?

MR. BENNETT: I object. That, that misstates the testimony.

MR. FISHER: I'm asking what his testimony is.

MR. BENNETT: Anything to do, I think he's testified, Your Honor. If he want to ask more questions, that's all right, but � JUDGE WRIGHT: I will � you might rephrase the question and ask whether he ever intended to facilitate the conversation or took any action to help Ms. Lewinsky gain access to Vernon Jordan for this purpose, or for any purpose. You might ask that. The president has testified on this matter that he doesn't think it would be improper if he had, so go ahead, you can ask.

Q. Did you do anything, sir, to prompt this conversation to take place between Vernon Jordan and Monica Lewinsky?

A. I can tell you what my memory is. My memory is that Vernon said something to me about her coming in, Betty had called and asked if he would see her and he said she would, he said he would, and then she called him and then he said something to me about it. I'm sure if he said something to me about it I said something positive about it. I wouldn't have said anything negative about it. I didn't have any negative knowledge. I mean there would be no reason for me to be negative about it. Vernon liked to help people. He was always trying to help people.

Q. My question, though, is focused on the time before the conversation occurred, and the question is whether you did anything to cause the conversation to occur.

A. I think in the mean � I'm not sure how you mean the question. I think the way you mean the question, the answer to that is no, I've already testified. What my memory of this is, if you're asking did I set the meeting up, I do not believe that I did. I believe that Betty did that, and she may have mentioned, asked me if I thought it was all right if she did it, and if she did ask me I would have said yes, and so if that happened, then I did something to cause the conversation to occur. If that's what you mean, yes. I didn't think there was anything wrong with it. It seemed like a natural think to do to me. But I don't believe that I actually was the precipitating force. I think that she and Betty were close, and I think Betty did it. That's my memory of it.

Q. Have you ever had a conversation with Vernon Jordan in which Paula Jones was mentioned?

A. I'm sure I have. I don't remember what it would have been, but I'm sure I have. I mean after all this time, I'm sure I have.

MR. BRISTOW: Your Honor, I just think we should note for the record that it is now almost 12:30, and to my knowledge this is the first moment in the deposition that the word "Paula Jones" has been mentioned.

JUDGE WRIGHT: Are you suggesting we take a break?

MR. BRISTOW: I think it's a good time for a break, but I'm also thinking of the fact that we do have some time constraints and � but anyway, I just thought it was an appropriate thing to note.

MR. BENNETT: Your Honor, I hope the sandwiches are there, but I'm happy to break now, but I'd like to get some guidance from the Court on something. If at the completion of, as he has apparently just completed Miss Lewinsky.

MR. FISHER: No, I haven't, but go ahead.

MR. BENNETT: Oh, I'm sorry, well, I'll wait until you finish with Miss Lewinsky.

MR. FISHER: I have just a couple of other things.

MR. BENNETT: I can ask my generic question. Hypothetically, Your Honor, if I have affidavits of women that he's questioning the president about and Your Honor does not want me to emphasize or even mention it for fear of the witness, when they are, when he is finished at the end of the day, may I read to the president certain relevant portions of those affidavits that we have an ask the president if that's, as far as he knows, a true and accurate statement?

JUDGE WRIGHT: You may, because this is that type of deposition.

MR. BENNETT: Thank you.

JUDGE WRIGHT: And I realize that you want to make your record because you're fearful about what might take place.

MR. BENNETT: Thank you, Your Honor, thank you, Your Honor.

JUDGE WRIGHT: Would you like to finish these questions now before we break?

MR. FISHER: I have just a couple more on this particular subject.

JUDGE WRIGHT: All right, all right, let's proceed then.

Q. Mr. President, have you ever paid any money to Monica Lewinsky?

A. No, sir.

Q. Have you ever caused money to be paid to her?

A. Absolutely not.

Q. Have you ever paid off any debt that she owed to some other person?

A. No, sir.

Q. Have you ever caused a debt that she owed to some other person to be repaid?

A. No, sir.

MR. FISHER: That's all I have on that subject.

JUDGE WRIGHT: All right, how much time � I'm suggesting we have lunch for, within the next half-hour and then come back here in half an hour.

MR. BENNETT:Would you like to break now �

THE WITNESS: Mr. Fisher, is there something , let me just � you asked that with such conviction and I answered with such conviction, is there something you want to ask me about this? I don't, I don't even know what you're talking about, I don't think.

MR. FISHER: Sir, I think this will come to light shortly, and you'll understand.

MR. BENNETT: Your Honor, we've had an awful lot of innuendo, and I object to it, and if they have it, let's get to it.

JUDGE WRIGHT: Well, I'm not � we're going to have a break for lunch for a half an hour. I will use this time for Counsel for Ms. Jones to provide me with anything in camera that they might like to with respect to a good faith basis for some of the questions to which Counsel have objected. Again, this is discovery, we're not applying the Rules of Evidence. There must be a good faith basis for the questions, and I have not seen any of the deposition, I mean, excuse me, any of the affidavits to which you're referring. I had not even heard of some of these individuals until Monday when we met to discuss the � and I hate this word � the parameters of the deposition, and so if you would please provide me with an in camera document or document or documents, or you can just tell me in camera off the record what your good faith basis is, then I can rule.

MR. CAMPBELL: Will we do that in your room Judge, here?

JUDGE WRIGHT: You can do that in my room, yeah, it doesn't matter.

MR. BENNETT: Your Honor, that's fine with me. I have no objection to that, but since Your Honor has ruled that I will be permitted to do that, I don't feel that's necessary, and withdraw my request that they do that. What I was worried about is that a record would be finished and we'd just have a lot on innuendo, so I think as long as I'm permitted to do that, then I think it would be �

JUDGE WRIGHT: You may. And keep in mind, also, I don't know just for what purpose this deposition will be used. It's certainly a discovery deposition, that's the initial purpose. It's clear that because the Defendant is the president, and because this Court has actually enormous discretion with respect to the conduct of this case with respect to the Defendant, it would be possible that this might even be used for evidentiary purposes if Mr. Clinton can't be present to testify, and that is another reason I will permit Mr. Bennett to rehabilitate the witness or put anything else on the record that you might think would be appropriate.

MR. BENNETT: That being the case, Your Honor, I would ask that they not meet with you privately. I would never have the ability to question or challenge that. I thought that was a possible solution to a problem where I knew nothing and you might have the opportunity to rule something out, but since you've given me the leeway, it would then be my view that since you are the trial judge that there not be ex parte discussions on evidence, and it was my suggestion, and I, and I admit to that, but given what you just said, I think this is a better way to handle it.

JUDGE WRIGHT: I'd like to give Counsel the benefit of the doubt, and even though I do have very grave concerns about the leak of information under seal in this matter, I can't tie it directly to any Counsel of Ms. Jones, and I have to, I don't believe any of the Counsel here are responsible for these leaks, and if I had reason to believe so, I would take appropriate action.

MR. BENNETT: I would suggest that on Monday you might have more of a factual basis since, since the Rader firm is apparently doing the circuit here in Washington.

MR. CAMPBELL: Your Honor, we object to that side-bar.

JUDGE WRIGHT: Again, we have to assume that all Counsel are playing by the rules set by the Court and until that time, until it's brought to my attention, otherwise I'll just have to rest on that assumption. Let's take a break.

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