The President's concern over the questions asked at the civil deposition about Ms. Lewinsky also manifested itself in substantial efforts to contact Monica Lewinsky over the next two days. Shortly after her meeting with the President, Ms. Currie made several attempts to contact Ms. Lewinsky. Ms. Currie testified it was "possible" she did so at the President's suggestion, and said "he may have asked me to call [Ms. Lewinsky] to see what she knew or where she was or what was happening."⁽⁴¹⁹⁾ Later that same night, at 11:01 p.m., the President again called Ms. Currie at home.⁽⁴²⁰⁾ Ms. Currie could not recall the substance but suggested that the President had called to ask whether she had spoken to Ms. Lewinsky.⁽⁴²¹⁾ The next day, January 19, 1998, which was a holiday, Ms. Currie made seven unsuccessful attempts to contact Monica Lewinsky, by pager, between 7:00 a.m. and 9:00 a.m.⁽⁴²²⁾ The President called Ms. Currie at home twice, and Ms. Currie called the President at the White House once that day.⁽⁴²³⁾

3. Conversation Between the President and Ms. Currie on Tuesday, January 20, 1998, or Wednesday, January 21, 1998.

On either Tuesday, January 20 or Wednesday, January 21 of that week, the President again met with Ms. Currie and discussed the Monica Lewinsky matter. Ms. Currie testified as follows:

BC: It was Tuesday or Wednesday. I don't remember which one this was, either. But the best I remember, when he called me in the Oval Office, it was sort of a recap[it]ulation of what we had talked about on Sunday -- you know, "I was never alone with her" -- that sort of thing.

Q: Did he pretty much list the same --

BC: To my recollection, sir, yes.

Q: And did he say it in sort of the same tone and demeanor that he used the first time he told you on Sunday?

BC: The best I remember, sir, yes.

* * * *

Q: And the President called you into the Oval Office specifically to list these things?

BC: I don't know if that's specifically what he called me in for, but once I got inside, that's what he --

Q: That's what he told you?

BC: Uh-huh.⁽⁴²⁴⁾

B. The President's Grand Jury Testimony

The President was asked why he might have said to Ms. Currie in their meeting on Sunday, January 18, 1998, "we were never alone together, right?" and "you could see and hear everything." The President testified:

[W]hat I was trying to determine was whether my recollection was right and that she was always in the office complex when Monica was there, and whether she thought she could hear any conversations we had, or did she hear any.

* * * *

I was trying to -- I knew . . . to a reasonable certainty that I was going to be asked more questions about this. I didn't really expect you to be in the Jones case at the time. I thought what would happen is that it would break in the press, and I was trying to get the facts down. I was trying to understand what the facts were.⁽⁴²⁵⁾

Later, the President stated that he was referring to a larger area than simply the room where he and Ms. Lewinsky were located. He also testified that his statements to Ms. Currie were intended to cover a limited range of dates:

WJC: . . . . [W]hen I said, we were never alone, right, I think I also asked her a number of other questions, because there were several times, as I'm sure she would acknowledge, when I either asked her to be around. I remember once in particular when I was talking with Ms. Lewinsky when I asked Betty to be in the, actually, in the next room in the dining room, and, as I testified earlier, once in her own office.

But I meant that she was always in the Oval Office complex, in that complex, while Monica was there. And I believe that this was part of a series of questions I asked her to try to quickly refresh my memory. So, I wasn't trying to get her to say something that wasn't so. And, in fact, I think she would recall that I told her to just relax, go in the grand jury and tell the truth when she had been called as a witness.

Q: So, when you said to Mrs. Currie that, I was never alone with her, right, you just meant that you and Ms. Lewinsky would be somewhere perhaps in the Oval Office or many times in your back study, is that correct?

WJC: That's right. We were in the back study.

Q: And then --

WJC: Keep in mind, sir, I just want to make it -- I was talking about 1997. I was never, ever trying to get Betty Currie to claim that on the occasions when Monica Lewinsky was there when she wasn't anywhere around, that she was. I would never have done that to her, and I don't think she thought about that. I don't think she thought I was referring to that.

Q: Did you put a date restriction? Did you make it clear to Mrs. Currie that you were only asking her whether you were never alone with her after 1997?

WJC: Well, I don't recall whether I did or not, but I assumed -- if I didn't, I assumed she knew what I was talking about, because it was the point at which Ms. Lewinsky was out of the White House and had to have someone WAVE her in, in order to get in the White House. And I do not believe to this day that I was -- in 1997, that she was ever there and that I ever saw her unless Betty Currie was there. I don't believe she was.⁽⁴²⁶⁾

With respect to the word "alone," the President also stated that "it depends on how you define alone" and "there were a lot of times when we were alone, but I never really thought we were."⁽⁴²⁷⁾

The President was also asked about his specific statement to Betty Currie that "you could see and hear everything." He testified that he was uncertain what he intended by that comment:

Q: When you said to Mrs. Currie, you could see and hear everything, that wasn't true either, was it, as far as you knew. You've already -- . . .

WJC: . . . My memory of that was that, that she had the ability to hear what was going on if she came in the Oval Office from her office. And a lot of times, you know, when I was in the Oval Office, she just had the door open to her office. Then there was -- the door was never completely closed to the hall. So I think there was -- I'm not entirely sure what I meant by that, but I could have meant that she generally would be able to hear conversations, even if she couldn't see them. And I think that's what I meant.⁽⁴²⁸⁾

The President then testified that when he made the comment to Ms. Currie about her being able to hear everything, he again was referring to only a limited period of time:

Q: . . . .you would not have engaged in those physically intimate acts if you knew that Mrs. Currie could see or hear that, is that correct?

WJC: That's correct. But keep in mind, sir, I was talking about 1997. That occurred, to the -- and I believe that occurred only once in February of 1997. I stopped it. I never should have started it, and I certainly shouldn't have started it back after I resolved not to in 1996. And I was referring to 1997.

And I -- what -- as I say, I do not know -- her memory and mine may be somewhat different. I do not know whether I was asking her about a particular time when Monica was upset and I asked her to stand, stay back in the dining area. Or whether I was, had reference to the fact that if she kept the door open to the Oval Office, because it was always -- the door to the hallway was always somewhat open, that she would always be able to hear something if anything went on that was, you know, too loud, or whatever.

I do not know what I meant. I'm just trying to reconcile the two statements as best I can, without being sure.⁽⁴²⁹⁾

The President was also asked about his comment to Ms. Currie that Ms. Lewinsky had "come on" to him, but that he had "never touched her":

Q: . . . . [I]f [Ms. Currie] testified that you told her, Monica came on to me and I never touched her, you did, in fact, of course, touch Ms. Lewinsky, isn't that right, in a physically intimate way?

WJC: Now, I've testified about that. And that's one of those questions that I believe is answered by the statement that I made.⁽⁴³⁰⁾

Q: What was your purpose in making these statements to Mrs. Currie, if it weren't for the purpose to try to suggest to her what she should say if ever asked?

WJC: Now, Mr. Bittman, I told you, the only thing I remember is when all this stuff blew up, I was trying to figure out what the facts were. I was trying to remember. I was trying to remember every time I had seen Ms. Lewinsky.

. . . I knew this was all going to come out. . . . I did not know [at the time] that the Office of Independent Counsel was involved. And I was trying to get the facts and try to think of the best defense we could construct in the face of what I thought was going to be a media onslaught.⁽⁴³¹⁾

Finally, the President was asked why he would have called Ms. Currie into his office a few days after the Sunday meeting and repeated the statements about Ms. Lewinsky to her. The President testified that although he would not dispute Ms. Currie's testimony to the contrary, he did not remember having a second conversation with her along these lines.⁽⁴³²⁾

C. Summary

The President referred to Ms. Currie on multiple occasions in his civil deposition when describing his relationship with Ms. Lewinsky. As he himself recognized, a large number of questions about Ms. Lewinsky were likely to be asked in the very near future. The President thus could foresee that Ms. Currie either might be deposed or questioned or might need to prepare an affidavit.

The President called her shortly after the deposition and met with Ms. Currie the next day. The President appeared "concerned," according to Ms. Currie. He then informed Ms. Currie that questions about Ms. Lewinsky had been asked at the deposition.

The statements the President made to her on January 18 and again on January 20 or 21 -- that he was never alone with Ms. Lewinsky, that Ms. Currie could always hear or see them, and that he never touched Ms. Lewinsky -- were false, but consistent with the testimony that the President provided under oath at his deposition. The President knew that the statements were false at the time he made them to Ms. Currie. The President's suggestion that he was simply trying to refresh his memory when talking to Ms. Currie conflicts with common sense: Ms. Currie's confirmation of false statements could not in any way remind the President of the facts. Thus, it is not plausible that he was trying to refresh his recollection.

The President's grand jury testimony reinforces that conclusion. He testified that in asking questions of Ms. Currie such as "We were never alone, right" and "Monica came on to me, and I never touched her, right," he intended a date restriction on the questions. But he did not articulate a date restriction in his conversations with Ms. Currie. Moreover, with respect to some aspects of this incident, the President was unable to devise any innocent explanation, testifying that he did not know why he had asked Ms. Currie some questions and admitting that he was "just trying to reconcile the two statements as best [he could]." On the other hand, if the most reasonable inference from the President's conduct is drawn -- that he was attempting to enlist a witness to back up his false testimony from the day before -- his behavior with Ms. Currie makes complete sense.

The content of the President's statements and the context in which those statements were made provide substantial and credible information that President Clinton sought improperly to influence Ms. Currie's testimony. Such actions constitute an obstruction of justice and improper influence on a witness.

X. There is substantial and credible information that President Clinton endeavored to obstruct justice during the federal grand jury investigation. While refusing to testify for seven months, he simultaneously lied to potential grand jury witnesses knowing that they would relay the falsehoods to the grand jury.

The President's grand jury testimony followed seven months of investigation in which he had refused six invitations to testify before the grand jury. During this period, there was no indication that the President would admit any sexual relationship with Ms. Lewinsky. To the contrary, the President vehemently denied the allegations.

Rather than lie to the grand jury himself, the President lied about his relationship with Ms. Lewinsky to senior aides, and those aides then conveyed the President's false story to the grand jury.⁽⁴³³⁾

In this case, the President lied to, among others, three current senior aides -- John Podesta, Erskine Bowles, and Sidney Blumenthal -- and one former senior aide, Harold Ickes. The President denied any kind of sexual relationship with Monica Lewinsky; said that Ms. Lewinsky had made a sexual demand on him; and denied multiple telephone conversations with Monica Lewinsky. The President, by his own later admission, was aware that his aides were likely to convey the President's version of events to the grand jury.

The President's aides took the President at his word when he made these statements. Each aide then testified to the nature of the relationship between Monica Lewinsky and the President based on those statements -- without knowing that they were calculated falsehoods by the President designed to perpetuate the false statements that the President made during his deposition in the Jones case.

The aides' testimony provided the grand jury a false account of the relationship between the President and Ms. Lewinsky. Their testimony thus had the potential to affect the investigation -- including decisions by the OIC and grand jury about how to conduct the investigation (for example, whether to subpoena Secret Service agents) and whether to indict particular individuals.

A. The Testimony of Current and Former Aides >

1. John Podesta

John Podesta, Deputy Chief of Staff,⁽⁴³⁴⁾ testified that on several occasions shortly after the media first began reporting the Lewinsky allegations, the President either denied having a relationship with Ms. Lewinsky or otherwise minimized his involvement with her.

Mr. Podesta described a meeting with the President, Chief of Staff Erskine Bowles, and Deputy Chief of Staff Sylvia Matthews, in the morning of January 21, 1998.⁽⁴³⁵⁾ During that meeting, the President stated: "Erskine, I want you to know that this story is not true."⁽⁴³⁶⁾ Mr. Podesta further recalled that the President said "that he had not had a sexual relationship with her, and that he never asked anybody to lie."⁽⁴³⁷⁾

Several days later, on January 23, 1998, the President more adamantly told Mr. Podesta that he had not engaged in sex of any "kind, shape or manner" with Ms. Lewinsky. Mr. Podesta recalled:

JP: [H]e said to me that he had never had sex with her, and that -- and that he never asked -- you know, he repeated the denial, but he was extremely explicit in saying he never had sex with her.

Q: How do you mean?

JP: Just what I said.

Q: Okay. Not explicit, in the sense that he got more specific than sex, than the word "sex."

JP: Yes, he was more specific than that.

Q: Okay. Share that with us.

JP: Well, I think he said -- he said that -- there was some spate of, you know, what sex acts were counted, and he said that he had never had sex with her in any way whatsoever --

Q: Okay.

JP: --that they had not had oral sex.⁽⁴³⁸⁾

Later, possibly that same day,⁽⁴³⁹⁾ the President made a further statement to Mr. Podesta regarding his relationship with Ms. Lewinsky. Mr. Podesta testified that the President "said to me that after [Monica] left [her job at the White House], that when she had come by, she came by to see Betty, and that he -- when she was there, either Betty was with them -- either that she was with Betty when he saw her or that he saw her in the Oval Office with the door open and Betty was around -- and Betty was out at her desk."⁽⁴⁴⁰⁾ The President relayed to Mr. Podesta one of the false "cover stories" that the President and Ms. Lewinsky had agreed to use.

Both the President and Mr. Podesta knew that Mr. Podesta was likely to be a witness in the ongoing grand jury criminal investigation.⁽⁴⁴¹⁾ Nonetheless, Mr. Podesta recalled that the President "volunteered" to provide information about Ms. Lewinsky to him⁽⁴⁴³⁾ even though Mr. Podesta had not asked for these details.⁽⁴⁴⁴⁾

Mr. Podesta "believe[d]" the President, and testified that it was important to him that the President denied the affair.⁽⁴⁴⁵⁾ Mr. Podesta repeated to the grand jury the false and misleading statements that the President told him.

2. Erskine Bowles

Mr. Bowles, the White House Chief of Staff,⁽⁴⁴⁶⁾ confirmed Mr. Podesta's account of the President's January 21, 1998, statement in which the President denied having a sexual relationship with Ms. Lewinsky. Mr. Bowles testified:

EB: And this was the day this huge story breaks. And the three of us walked in together -- Sylvia Matthews, John Podesta, and me -- into the Oval Office, and the President was standing behind his desk.

Q: About what time of day is this?

EB: This is approximately 9:00 in the morning, or something -- you know, in that area. And he looked up at us and he said the same thing he said to the American people. He said, "I want you to know I did not have sexual relationships [sic] with this woman Monica Lewinsky. I did not ask anybody to lie. And when the facts come out, you'll understand."⁽⁴⁴⁷⁾

Mr. Bowles testified that he took the President's statements seriously: "All I can tell you is: This guy who I've worked for looked me in the eye and said he did not have sexual relationships with her. And if I didn't believe him, I couldn't stay. So I believe him."⁽⁴⁴⁸⁾ Mr. Bowles repeated the President's false and misleading statement to the grand jury.

3. Sidney Blumenthal

Sidney Blumenthal, an Assistant to the President,⁽⁴⁴⁹⁾ similarly testified that the President made statements to him denying the Lewinsky allegations shortly after the first media report.

Mr. Blumenthal stated that he spoke to Mrs. Clinton on the afternoon of January 21, 1998, and to the President early that evening. During those conversations, both the President and Mrs. Clinton offered an explanation for the President's meetings with Ms. Lewinsky, and President Clinton offered an explanation for Ms. Lewinsky's allegations of a sexual relationship.⁽⁴⁵⁰⁾

Testifying before the grand jury, Mr. Blumenthal related his discussion with President Clinton:

I said to the President, "What have you done wrong?" And he said, "Nothing. I haven't done anything wrong."

. . . And it was at that point that he gave his account of what had happened to me and he said that Monica -- and it came very fast. He said, "Monica Lewinsky came at me and made a sexual demand on me." He rebuffed her. He said, "I've gone down that road before, I've caused pain for a lot of people and I'm not going to do that again."

She threatened him. She said that she would tell people they'd had an affair, that she was known as the stalker among her peers, and that she hated it and if she had an affair or said she had an affair then she wouldn't be the stalker any more.⁽⁴⁵²⁾

Mr. Blumenthal testified that the President appeared "upset" during this conversation.⁽⁴⁵³⁾

Finally, Mr. Blumenthal asked the President to explain alleged answering machine messages (a detail mentioned in press reports).

He said that he remembered calling her when Betty Currie's brother died and that he left a message on her voice machine that Betty's brother had died and he said she was close to Betty and had been very kind to Betty. And that's what he recalled.⁽⁴⁵⁴⁾

According to Mr. Blumenthal, the President said that the call he made to Ms. Lewinsky relating to Betty's brother was the "only one he could remember."⁽⁴⁵⁵⁾ That was false: The President and Ms. Lewinsky talked often on the phone, and the subject matter of the calls was memorable.

A grand juror asked Mr. Blumenthal whether the President had said that his relationship with Ms. Lewinsky included any kind of sexual activity. Mr. Blumenthal testified that the President's response was "the opposite. He told me that she came on to him and that he had told her he couldn't have sexual relations with her and that she threatened him. That is what he told me."⁽⁴⁵⁶⁾

Mr. Blumenthal testified that after the President relayed this information to him, he "certainly believed his story. It was a very heartfelt story, he was pouring out his heart, and I believed him."⁽⁴⁵⁷⁾ Mr. Blumenthal repeated to the grand jury the false statements that the President made to him.

4. Harold Ickes

Mr. Ickes, a former Deputy Chief of Staff,⁽⁴⁵⁸⁾ also related to the grand jury a conversation that he had with the President on the morning of January 26, 1998,⁽⁴⁶⁰⁾ during which the President denied the Lewinsky allegations.

Regarding that conversation, Mr. Ickes testified: "The two things that I recall, the two things that he again repeated in public -- had already said publicly and repeated in public that same Monday morning was that he had not had -- he did not have a -- or he had not had a sexual relationship with Ms. Lewinsky and that he had done nothing -- now I'm paraphrasing -- had done nothing to ask anybody to change their story or suborn perjury or obstruct justice."⁽⁴⁶¹⁾

Mr. Ickes recalled that the President probably volunteered this information.⁽⁴⁶²⁾ Mr. Ickes repeated the President's false statements to the grand jury.

B. The President's Grand Jury Testimony

The President admitted to the grand jury that, after the allegations were publicly reported, he made "misleading" statements to particular aides whom he knew would likely be

called to testify before the grand jury. The President testified as follows:

Q: Do you recall denying any sexual relationship with Monica Lewinsky to the following people: Harry Thomasson, Erskine Bowles, Harold Ickes, Mr. Podesta, Mr. Blumenthal, Mr. Jordan, Ms. Betty Currie? Do you recall denying any sexual relationship with Monica Lewinsky to those individuals?

WJC: I recall telling a number of those people that I didn't have, either I didn't have an affair with Monica Lewinsky or didn't have sex with her. And I believe, sir, that -- you'll have to ask them what they thought. But I was using those terms in the normal way people use them. You'll have to ask them what they thought I was saying.

Q: If they testified that you denied sexual relationship with Monica Lewinsky, or if they told us that you denied that, do you have any reason to doubt them, in the days after the story broke; do you have any reason to doubt them?

WJC: No.

The President then was specifically asked whether he knew that his aides were likely to be called before the grand jury.

Q: It may have been misleading, sir, and you knew though, after January 21st when the Post article broke and said that Judge Starr was looking into this, you knew that they might be witnesses. You knew that they might be called into a grand jury, didn't you?

WJC: That's right. I think I was quite careful what I said after that. I may have said something to all these people to that effect, but I'll also -- whenever anybody asked me any details, I said, look, I don't want you to be a witness or I turn you into a witness or give you information that would get you in trouble. I just wouldn't talk. I, by and large, didn't talk to people about this.

Q: If all of these people -- let's leave out Mrs. Currie for a minute. Vernon Jordan, Sid Blumenthal, John Podesta, Harold Ickes, Erskine Bowles, Harry Thomasson, after the story broke, after Judge Starr's involvement was known on January 21st, have said that you denied a sexual relationship with them. Are you denying that?

WJC: No.

Q: And you've told us that you --

WJC: I'm just telling you what I meant by it. I told you what I meant by it when they started this deposition.

Q: You've told us now that you were being careful, but that it might have been misleading. Is that correct?

419. Currie 5/7/98 GJ at 99-100. Ms. Lewinsky called Betty Currie shortly after 10:00 p.m., but told Ms. Currie that she could not talk to her that night. Id. at 101.

420. GJ Exhibit BC 3-12, V006-DC-00002068 (call log). The call lasted approximately one minute.

421. Currie 5/7/98 GJ at 102.

422. 831-DC-00000009 (Lewinsky pager records). As the records reflect, Betty Currie used the name Kay or Kate when paging Monica Lewinsky. Lewinsky 8/6/98 GJ at 215-17; Currie 7/22/98 GJ at 148-49.

423. V006-DC-00002069; V006-DC-00002070 (White House telephone records). Ms. Currie testified that she probably called the President to tell him that she had not yet spoken to Ms. Lewinsky. Ms. Currie does not remember the substance of the conversations with the President for either of the calls that he made to her. Currie 5/7/98 GJ at 106-07. The phone calls from the President were approximately one and two minutes in length. That Monday, January 19, was a holiday, and Ms. Currie was not at work.

424. Currie 1/27/98 GJ at 80-82 (emphasis added).

425. Clinton 8/17/98 GJ at 56-57 (emphasis added). See also id. at 131-32 (Q: "You said that you spoke to her in an attempt to refresh your own recollection about the events involving Monica Lewinsky, is that right?" WJC: "Yes.").

426. Id. at 132-34 (emphasis added).

427. Id. at 134.

428. Id. at 134-35 (emphasis added).

429. Id. at 136-37.

430. The President is referring to the statement he read at the beginning of his grand jury appearance.

431. Id. at 139-40 (emphasis added).

432. Id. at 141-42.

433. Two federal criminal statutes, Sections 1512 and 1503 of Title 18 of the United States Code, prohibit misleading potential witnesses with the intent to influence their grand jury testimony. Section 1512 provides that whoever "corruptly . . . engages in misleading conduct toward another person, with intent to -- (1) influence, delay, or prevent the testimony of any person in an official proceeding . . . shall be fined under this title or imprisoned not more than ten years, or both." 18 U.S.C. § 1512(b). It is no defense to a charge of witness tampering that the official proceeding had not yet begun, nor is it a defense that the testimony sought to be influenced turned out to be inadmissible or subject to a claim of privilege. 18 U.S.C. § 1512(e).

Section 1503 provides that whoever "corruptly or by threats or force . . . influences, obstructs, or impedes or endeavors to influence, obstruct, or impede the due administration of justice" has committed a felony. 18 U.S.C. § 1503(a)-(b).

The Governor of Guam was convicted of witness tampering for lying to a potential witness "intending that [the witness] would offer [the Governor's] explanation concerning the [illegally used] funds to the FBI." United States v. Bordallo, 857 F.2d 519, 525 (9th Cir. 1988), amended on other grounds, 872 F.2d 334 (9th Cir.), cert. denied, 493 U.S. 818 (1989).

434. Podesta 2/5/98 GJ at 13. Mr. Podesta has served as Deputy Chief of Staff since January 1997, and previously served as Staff Secretary for the Clinton Administration from 1993 through 1995. Podesta 2/5/98 GJ at 9-10.

435. Podesta 6/16/98 GJ at 84-85.

436. Id. at 85.

437. Id.

438. Id. at 92 (emphasis added).

439. Mr. Podesta dated this conversation as perhaps taking place on January 23, 1998. Podesta 6/16/98 GJ at 88.

440. Id. at 88.

441. Mr. Podesta testified that he was "sensitive about not exchanging information because I knew I was a potential witness."⁽⁴⁴²⁾

442. Podesta 6/23/98 GJ at 79.

443. Podesta 6/16/98 GJ at 94; see also Podesta 6/23/98 GJ at 79.

444. See id. at 79 (emphasis added).

445. Podesta 6/23/98 GJ at 77-78.

446. Bowles 4/2/98 GJ at 12. Mr. Bowles has been the Chief of Staff for President Clinton since January 20, 1997. Id.

447. Id. at 83-84 (emphasis added).

448. Id. at 91.

449. Blumenthal 2/26/98 GJ at 4-5.

450. Blumenthal 6/4/98 GJ at 46-53. ⁽⁴⁵¹⁾

451. Blumenthal GJ 6/4/98 at 48-49. [we should question Morris abt this]

452. Blumenthal 6/4/98 GJ at 49 (emphasis added).

453. Blumenthal 6/25/98 GJ at 41.

454. Blumenthal 6/4/98 GJ at 50.

455. Blumenthal 6/25/98 GJ at 27.

456. Blumenthal 6/4/98 GJ at 52 (emphasis added).

457. Blumenthal 6/25/98 GJ at 17. See also Blumenthal 6/25/98 GJ at 26 ("My understanding was that the accusations against him which appeared in the press that day were false, that he had not done anything wrong").

458. Ickes 7/23/98 GJ at 8. Mr. Ickes worked as Deputy Chief of Staff for President Clinton from early 1994 through January 1997.⁽⁴⁵⁹⁾

459. Ickes 7/23/98 GJ at 8.

460. Ickes 6/10/98 GJ at 21-22, 66 (meeting occurred on Monday following the week that the media first reported the Lewinsky story).

461. Ickes 6/10/98 GJ at 73 (emphasis added). See also Ickes 8/5/98 GJ at 88 ("[H]e denied to me that he had had a sexual relationship. I don't know the exact phrase, but the word 'sexual' was there. And he denied any obstruction of justice").

462. Ickes 6/10/98 GJ at 73.