Table of Contents

The content of the following materials are verbatim as forwarded by the Office of the Independent Counsel. The conversion to HTML has altered the pagination and format. The original Table of Contents is not provided.

Cover Page




Table of Contents




Chronology




Table of Names

The Principals
The First Family
Presidential Aides/Advisors/Assistants
Other White House Personnel
Department of Defense Employees
Monica Lewinsky's Friends/Family/Acquaintances
Monica Lewinsky's New York Employment Contacts
Secret Service
Lawyers and Judges
Media
Foreign Dignitaries
Other



Introduction

Factual Background
The Investigation
The Significance of the Evidence of Wrongdoing
The Scope of the Referral

1. Background of the Investigation.
2. Current Status of the Investigation.

The Contents of the Referral



Narrative

I. Nature of President Clinton's Relationship with Monica Lewinsky

A. Introduction
B. Evidence Establishing Nature of Relationship

1. Physical Evidence
2. Ms. Lewinsky's Statements
3. Ms. Lewinsky's Confidants
4. Documents
5. Consistency and Corroboration

C. Sexual Contacts

1. The President's Accounts

a. Jones Testimony
b. Grand Jury Testimony

2. Ms. Lewinsky's Account

D. Emotional Attachment
E. Conversations and Phone Messages
F. Gifts
G. Messages
H. Secrecy

1. Mutual Understanding
2. Cover Stories
3. Steps to Avoid Being Seen or Heard
4. Ms. Lewinsky's Notes and Letters
5. Ms. Lewinsky's Evaluation of Their Secrecy Efforts


II. 1995: Initial Sexual Encounters

A. Overview of Monica Lewinsky's White House Employment
B. First Meetings with the President
C. November 15 Sexual Encounter
D. November 17 Sexual Encounter
E. December 31 Sexual Encounter
F. President's Account of 1995 Relationship


III. January-March 1996: Continued Sexual Encounters

A. January 7 Sexual Encounter
B. January 21 Sexual Encounter
C. February 4 Sexual Encounter and Subsequent Phone Calls
D. President's Day (February 19) Break-up
E. Continuing Contacts
F. March 31 Sexual Encounter


IV. April 1996: Ms. Lewinsky's Transfer to the Pentagon

A. Earlier Observations of Ms. Lewinsky in the West Wing
B. Decision to Transfer Ms. Lewinsky
C. Ms. Lewinsky's Notification of Her Transfer
D. Conversations with the President about Her Transfer

1. Easter Telephone Conversations and Sexual Encounter
2. April 12-13: Telephone Conversations


V. April-December 1996: No Private Meetings

A. Pentagon Job
B. No Physical Contact
C. Telephone Conversations
D. Public Encounters
E. Ms. Lewinsky's Frustrations


VI. Early 1997: Resumption of Sexual Encounters

A. Resumption of Meetings with the President

1. Role of Betty Currie

a. Arranging Meetings
b. Intermediary for Gifts
c. Secrecy

2. Observations by Secret Service Officers

B. Valentine's Day Advertisement
C. February 24 Message
D. February 28 Sexual Encounter
E. March 29 Sexual Encounter
F. Continuing Job Efforts


VII. May 1997: Termination of Sexual Relationship

A. Questions about Ms. Lewinsky's Discretion
B. May 24: Break-up


VIII. June-October 1997: Continuing Meetings and Calls

A. Continuing Job Efforts
B. July 3 Letter
C. July 4 Meeting
D. July 14-15 Discussions of Linda Tripp
E. July 16 Meeting with Marsha Scott
F. July 24 Meeting
G. Newsweek Article and Its Aftermath
H. August 16 Meeting
I. Continuing Job Efforts
J. Black Dog Gifts
K. Lucy Mercer Letter and Involvement of Chief of Staff
L. News of Job Search Failure


IX. October-November 1997: United Nations' Job Offer

A. October 10: Telephone Conversation
B. October 11 Meeting
C. October 16-17: The "Wish List
D. The President Creates Options
E. The U.N. Interview and Job Offer
F. The U.N. Job Offer Declined


X. November 1997: Growing Frustration

A. Interrogatories Answered
B. First Vernon Jordan Meeting
C. November 13: The Zedillo Visit
D. November 14-December 4: Inability to See the President


XI. December 5-18, 1997: The Witness List and Job Search

A. December 5: The Witness List
B. December 5: Christmas Party at the White House
C. December 6: The Northwest Gate Incident

1. Initial Visit and Rejection
2. Ms. Lewinsky Returns to the White House
3. "Whatever Just Happened Didn't Happen"

D. The President Confers with His Lawyers
E. Second Jordan Meeting
F. Early Morning Phone Call
G. Job Interviews


XII. December 19, 1997 - January 4, 1998: The Subpoena

A. December 19: Ms. Lewinsky Is Subpoenaed
B. December 22: Meeting with Vernon Jordan
C. December 22: First Meeting with Francis Carter
D. December 23: Clinton Denials to Paula Jones
E. December 28: Final Meeting with the President
E. December 28: Concealment of Gifts
D. December 31: Breakfast with Vernon Jordan
E. January 4: The Final Gift


XIII. January 5-January 16, 1998: The Affidavit

A. January 5: Francis Carter Meeting
B. January 5: Call from the President
C. January 6: The Draft Affidavit
D. January 7: Ms. Lewinsky Signs Affidavit
E. January 8: The Perelman Call
F. January 9: "Mission Accomplished"
G. January 12: Pre-Trial Hearing in Jones Case
H. January 13: References from the White House
I. January 13: Final Jordan Meeting
J. January 13-14: Lewinsky-Tripp Conversation and Talking Points
K. January 15: The Isikoff Call
L. January 15-16: Developments in the Jones Law Suit


XIV. January 17, 1998-Present: The Deposition and Afterward

A. January 17: The Deposition
B. The President Meets with Ms. Currie
C. January 18-19: Attempts to Reach Ms. Lewinsky
D. January 20-22: Lewinsky Story Breaks

1. "Clinton Accused"
2. Denials to Aides
3. Initial Denials to the American Public
4. "We Just Have To Win"




Grounds

There is Substantial and Credible Information that President Clinton Committed Acts that May Constitute Grounds for an Impeachment

Introduction

I. There is substantial and credible information that President Clinton lied under oath as a defendant in Jones v. Clinton regarding his sexual relationship with Monica Lewinsky.

(1) He denied that he had a "sexual relationship" with
(2) He denied that he had a "sexual affair" with Monica
(3) He denied that he had "sexual relations" with Monica
(4) He denied that he engaged in or caused contact with the
(5) He denied that he made contact with Monica Lewinsky's

A. Evidence that President Clinton Lied Under Oath During the Civil Case

1. President Clinton's Statements Under Oath About Monica Lewinsky
2. Monica Lewinsky's Testimony

(i) Wednesday, November 15, 1995
(ii) Friday, November 17, 1995
(iii) Sunday, December 31, 1995
(iv) Sunday, January 7, 1996
(v) Sunday, January 21, 1996
(vi) Sunday, February 4, 1996
(vii) Sunday, March 31, 1996
(viii) Sunday, April 7, 1996
(ix) Friday, February 28, 1997
(x) Saturday, March 29, 1997
(xi) Two Subsequent Meetings

3. Phone Sex
4. Physical Evidence
5. Testimony of Ms. Lewinsky's Friends, Family Members, and Counselors

(i) Catherine Allday Davis
(ii) Neysa Erbland
(iii) Natalie Rose Ungvari
(iv) Ashley Raines
(v) Andrew Bleiler
(vi) Dr. Irene Kassorla
(vii) Linda Tripp
(viii) Debra Finerman
(ix) Dale Young
(x) Kathleen Estep

6. Summary


II. There is substantial and credible information that President Clinton lied under oath to the grand jury about his sexual relationship with Monica Lewinsky.

A. Background
B. The President's Grand Jury Testimony
C. Summary


III. There is substantial and credible information that President Clinton lied under oath during his civil deposition when he stated that he could not recall being alone with Monica Lewinsky and when he minimized the number of gifts they had exchanged.

A. There is substantial and credible information that President Clinton lied under oath when he testified that he could not specifically recall instances in which he was alone with Monica Lewinsky.

1. The President's Civil Deposition Testimony
2. Evidence That Contradicts the President's Testimony
3. The President's Grand Jury Testimony
4. Summary

B. There is substantial and credible information that the President lied under oath in his civil deposition about gifts he exchanged with Monica Lewinsky.

1. The President's Civil Deposition Testimony About His Gifts to Monica Lewinsky
2. Evidence that Contradicts the President's Civil Deposition Testimony
3. President's Civil Deposition Testimony About Gifts from Monica Lewinsky to the President
4. Evidence that Contradicts the President's Testimony

(i) Monica Lewinsky's Testimony

5. Grand Jury Testimony of the President and Ms. Currie
6. Summary


IV. There is substantial and credible information that the President lied under oath during his civil deposition concerning conversations he had with Monica Lewinsky about her involvement in the Jones case.

A. Conversations with Ms. Lewinsky Regarding the Possibility of Her Testifying in the Jones Case

1. President Clinton's Testimony in His Deposition
2. Evidence that Contradicts the President's Civil Deposition Testimony

(i) Ms. Lewinsky's Testimony
(ii) The President's Grand Jury Testimony

3. Summary

B. There is substantial and credible information that President Clinton lied under oath in his civil deposition when he denied knowing that Ms. Lewinsky had received her subpoena at the time he had last talked to her.

1. Evidence
2. Summary


V. There is substantial and credible information that President Clinton endeavored to obstruct justice by engaging in a pattern of activity to conceal evidence regarding his relationship with Monica Lewinsky from the judicial process in the Jones case. The pattern included:

(i) concealment of gifts that the President had given Ms. Lewinsky and that were subpoenaed from Ms. Lewinsky in the Jones case; and
ii) concealment of a note sent by Ms. Lewinsky to the President on January 5, 1998.

A. Concealment of Gifts

1. Evidence Regarding Gifts
2. The President's Grand Jury Testimony
3. Summary of Gifts

B. January 5, 1998, Note to the President

1. Evidence Regarding the January 5, 1998 Note
2. President Clinton's Testimony
3. Summary on January 5, 1998, Note


VI. There is substantial and credible information that

(i) President Clinton and Ms. Lewinsky had an understanding that they would lie under oath in the Jones case about their relationship; and
(ii) President Clinton endeavored to obstruct justice by suggesting that Ms. Lewinsky file an affidavit so that she would not be deposed, she would not contradict his testimony, and he could attempt to avoid questions about Ms. Lewinsky at his deposition.

A. Evidence Regarding Affidavit and Use of Affidavit
B. Summary of President's Grand Jury Testimony
C. Evidence Regarding Cover Stories
D. The President's Grand Jury Testimony on Cover Stories
E. Summary


VII. There is substantial and credible information that 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 against him were she to tell the truth during the Jones case.

A. Evidence
B. Summary


VIII. There is substantial and credible information that the President lied under oath in describing his conversations with Vernon Jordan about Ms. Lewinsky.

A. President's Testimony in the Jones Case
B. Evidence That Contradicts the President's Civil Deposition
C. Summary


IX. There is substantial and credible information that President Clinton endeavored to obstruct justice by attempting to influence the testimony of Betty Currie.

A. Evidence

1. Saturday, January 17, 1998, Deposition
2. Sunday, January 18, 1998, Meeting with Ms. Currie
3. Conversation Between the President and Ms. Currie on Tuesday, January 20, 1998, or Wednesday, January 21, 1998.

B. The President's Grand Jury Testimony
C. Summary


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.

A. The Testimony of Current and Former Aides

1. John Podesta
2. Erskine Bowles
3. Sidney Blumenthal
4. Harold Ickes

B. The President's Grand Jury Testimony
C. Summary


XI. There is substantial and credible information that President Clinton's actions since January 17, 1998, regarding his relationship with Monica Lewinsky have been inconsistent with the President's constitutional duty to faithfully execute the laws.

A. Beginning on January 21, 1998, the President misled the American people and Congress regarding the truth of his relationship with Ms. Lewinsky.
B. The First Lady, the Cabinet, the President's staff, and the President's associates relied on and publicly emphasized the President's denial.
C. The President repeatedly and unlawfully invoked the Executive Privilege to conceal evidence of his personal misconduct from the grand jury.
D. The President refused six invitations to testify to the grand jury, thereby delaying expeditious resolution of this matter, and then refused to answer relevant questions before the grand jury when he testified in August 1998.
E. The President misled the American people and the Congress in his public statement on August 17, 1998, when he stated that his answers at his civil deposition in January had been "legally accurate."
F. Summary




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