(Below is an excerpt from the Starr Report outlining eleven impeachable
offenses allegedly committed by President Bill Clinton.)
Pursuant to Section 595(c) of Title 28, the Office of Independent Counsel
(OIC) hereby submits substantial and credible information that President
Clinton obstructed justice during the Jones v. Clinton sexual harassment
lawsuit by lying under oath and concealing evidence of his relationship
with a young White House intern and federal employee, Monica Lewinsky.
After a federal criminal investigation of the President's actions began
in January 1998, the President lied under oath to the grand jury and obstructed
justice during the grand jury investigation. There also is substantial
and credible information that the President's actions with respect to Monica
Lewinsky constitute an abuse of authority inconsistent with the President's
constitutional duty to faithfully execute the laws.
There is substantial and credible information supporting the following
eleven possible grounds for impeachment:
1. President Clinton lied under oath in his civil case when he denied
a sexual affair, a sexual relationship, or sexual relations with Monica
2. President Clinton lied under oath to the grand jury about his sexual
relationship with Ms. Lewinsky.
3. In his civil deposition, to support his false statement about the
sexual relationship, President Clinton also lied under oath about being
alone with Ms. Lewinsky and about the many gifts exchanged between Ms.
Lewinsky and him.
4. President Clinton lied under oath in his civil deposition about his
discussions with Ms. Lewinsky concerning her involvement in the Jones case.
5. During the Jones case, the President obstructed justice and had an
understanding with Ms. Lewinsky to jointly conceal the truth about their
relationship by concealing gifts subpoenaed by Ms. Jones's attorneys.
6. During the Jones case, the President obstructed justice and had an
understanding with Ms. Lewinsky to jointly conceal the truth of their relationship
from the judicial process by a scheme that included the following means:
(i) Both the President and Ms. Lewinsky understood that they would lie
under oath in the Jones case about their sexual relationship; (ii) the
President suggested to Ms. Lewinsky that she prepare an affidavit that,
for the President's purposes, would memorialize her testimony under oath
and could be used to prevent questioning of both of them about their relationship;
(iii) Ms. Lewinsky signed and filed the false affidavit; (iv) the President
used Ms. Lewinsky's false affidavit at his deposition in an attempt to
head off questions about Ms. Lewinsky; and (v) when that failed, the President
lied under oath at his civil deposition about the relationship with Ms.
7. President Clinton endeavored to obstruct justice by helping Ms. Lewinsky
obtain a job in New York at a time when she would have been a witness harmful
to him were she to tell the truth in the Jones case.
8. President Clinton lied under oath in his civil deposition about his
discussions with Vernon Jordan concerning Ms. Lewinsky's involvement in
the Jones case.
9. The President improperly tampered with a potential witness by attempting
to corruptly influence the testimony of his personal secretary, Betty Currie,
in the days after his civil deposition.
10. President Clinton endeavored to obstruct justice during the grand
jury investigation by refusing to testify for seven months and lying to
senior White House aides with knowledge that they would relay the President's
false statements to the grand jury -- and did thereby deceive, obstruct,
and impede the grand jury.
11. President Clinton abused his constitutional authority by (i) lying
to the public and the Congress in January 1998 about his relationship with
Ms. Lewinsky; (ii) promising at that time to cooperate fully with the grand
jury investigation; (iii) later refusing six invitations to testify voluntarily
to the grand jury; (iv) invoking Executive Privilege; (v) lying to the
grand jury in August 1998; and (vi) lying again to the public and Congress
on August 17, 1998 -- all as part of an effort to hinder, impede, and deflect
possible inquiry by the Congress of the United States.