following are those portions of President
deposition, conducted on January 17, 1998, in
the Paula Jones sexual harassment lawsuit that
made public. The entire deposition lasted about six hours.
MR. FISHER: Yes, Your Honor. What I'm
do is avoid having to ask the president a number of very salacious
questions and to make this as discreet as possible. This definition, I
think the Court will find, is taken directly from Rule 413, which I
believe President Clinton signed into law, with the exception that I
have narrowed subpart one to a particular section, which would be
covered by Rule 413, and I have that section here to give the president
so that there is no question what is intended. This will eliminate
confusion, not cause it.
MR. [ROBERT] BENNETT [the president's attorney]:
Your Honor, I have no objection where the appropriate predicates are
made for them to ask the president, did you know X, yes or no, what
happened, what did you do, what didn't you do. We are – we acknowledge
that some embarrassing questions will be asked, but then we all will
know what we're talking about, but I do not want my client answering
questions not understanding exactly what these folks are talking about.
Now, Your Honor, I told you that the president has
meeting at four o'clock and we've already wasted twenty minutes, and
Mr. Fisher has yet to ask him first factual question.
JUDGE [SUSAN WEBBER] WRIGHT: Well, I'm
prepared to rule, and I will not permit this definition to be
understood. Quite frankly, there's several reasons. One is that the
Court heretofore has not proceeded using these definitions. We have
used, we've made numerous rulings or the Court has made numerous
rulings in this case without specific reference to these definitions,
and so if you want to know the truth, I don't know them very well. I
would find it difficult to make rulings, and Mr. Bennett has made clear
that he acknowledges that embarrassing questions will be asked, and if
this is in fact an effort on, on the part of Plaintiff's Counsel to
avoid using sexual terms and avoid going into great detail about what
might or might not have occurred, then there's no need to worry about
that, you may go into the detail.
MR. BENNETT: If the predicates are met, we
have no objection to the detail.
MR. Fisher: Thank you, Your Honor.
JUDGE WRIGHT: It's just going to make it
difficult for me to rule, if you want to know the truth, and I'm not
sure Mr. Clinton knows all these definitions, anyway.
Q. Mr. Clinton, do you know a woman named
A. I do.
Q. When did you meet her for the first
A. I believe in the presidential campaign
of 1992 in Virginia.
Q. She was married to a man named Edward E.
Willey Jr., before he passed away, correct?
A. That's right.
Q. And she and her husband donated money to
your presidential campaign in 1992, correct?
A. That's correct.
Q. And Kathleen Willey and her husband also
did some fund-raising work for your campaign, correct?
A. I believe that's right. I'm not sure,
but I think they did.
Q. If she were to describe herself as a
Democratic party activist, would you disagree with that
characterization of her?
A. No. I believe she was actually
working very closely with Gov. Wilder in Virginia in 1992 at the time I
was running for president.
Q. All right, sir. On election night in
November 1992, did Kathleen Willey and her husband travel to Little
A. I have no idea.
Q. You don't recall seeing them in Little
Rock that night?
A. No. But, you know, we stayed up
late and there were hundreds, thousands of people there. I don't know
whether they were there or not.
Q. Do you recall that after the
election you personally called Kathleen Willey and, to thank her for
helping you to be elected president?
A. No, I don't remember that.
Q. After you became president, she got a
job working in the White House, correct?
A. I believe she worked in the
social office. I seem to remember she started as a volunteer. I'm not
sure, but I think she was a volunteer.
Q. All right, sir. Do you recall
that she was living in Richmond, Virginia, at that time and commuting
all the way to Washington?
A. Yeah, I knew that she and Ed lived in
Q. Do you recall approximately when she was
working in the White House as a volunteer?
A. No, I don't even – I don't know how many
days a week she worked and what hours she worked.
Q. Have you read any part of the deposition
testimony given by Kathleen Willey in this case?
A. No, but I have seen a summary of it.
Q. Not ever?
Q. Did she tell you that she and her
husband had some large debts to pay?
A. I don't remember that. What I remember
is that she was
very – she was obviously agitated, and I'd never really had a
conversation with her before so I, you know, except in public, I'd see
her, and she always seemed sort of shy, you know, upbeat, positive, but
this day she was clearly concerned, but I don't remember going into any
great detail. What I remember her saying is that her family, that there
was some family financial issues she had to deal with, and she needed
to earn some money to work there, and I had, I don't remember her going
into any great detail about it. I don't think she stayed long enough to
go into any great detail, but she was clearly upset.
Q. Do you recall, sir, that she said that
one reason she was upset was that her husband was missing?
A. No, I didn't know anything about her
husband being missing until I learned that, that he was dead.
Q. Do you recall how many days passed
before you learned that he had passed away?
A. I don't. I don't think it was very long,
but I don't remember.
Q. She took a leave of absence after her
husband died, correct?
A. I don't know what she did. When I heard
that he was
dead and that he apparently killed himself, I called her and expressed
my condolences and said that she could take whatever time she needed.
It was a brief call, but I remember that call and I don't know exactly
what she did, when she came back, or what the other facts are.
Q. Do you recall telling anyone in the
White House that as soon as she did come back, you wanted to meet with
A. No, but I, I might well have said
something like that,
I mean, when something that traumatic happens in someone's family, I
might have wanted to say something, I just had one of my speech
writers' wife just had a stroke. When he came back to work, I said
something to him. I might have done it, but I don't remember.
Q. So if someone in the White House
testified that you
told them you wanted to see Kathleen Willey as soon as she returned
from her bereavement, you wouldn't find that implausible testimony?
A. It might well have happened. I just
Q. All right. Having read a summary of her
you aware that she has testified that you kissed her in the hallway
between the Oval Office and the private kitchen?
A. I am aware of that.
Q. And you're aware that she testified that
you took her hand and put it on your penis?
A. I'm aware of that.
Q. All right, and you deny that testimony?
A. I emphatically deny it. It did not
Q. Do you know why she would tell a story
like that if it weren't true?
A. No, sir, I don't. I don't know. She'd
been through a
lot, and apparently the, the financial difficulties were even greater
than she thought they were at the time she talked to me. Her husband
killed himself, she's been through a terrible time. I have – I can't
say. All I can tell you is, in the first place, when she came to see me
she was clearly upset. I did to her what I have done to scores and
scores of men and women who have worked for me or been my friends over
the years. I embraced her, I put my arms around her, I may have even
kissed her on the forehead. There was nothing sexual about it. I was
trying to help her calm down and trying to reassure her. She was in
difficult condition. But I have no idea why she said what she did, or
whether she now believes that actually happened. She's been through a
terrible, terrible time in her life, and I have nothing else to say. I
don't want to speculate about it.
Q. Has she ever asked you to pay her money
in return for her not disclosing this story?
A.. Not to my knowledge.
Q. Do you recall at any time in that
meeting with Kathleen Willey saying to her, "I wanted to do that for a
A. No, sir. Let me remind you, Kathleen
Willey asked for
this meeting with me. I didn't ask for the meeting with her. I didn't
say anything like that.
Q. Do you recall meeting with her again in
the Oval Office after she returned from her bereavement?
A. I remember that, it seems to me that she
came in there
once with a friend of hers who was sick, who had cancer, and we had a
picture taken. I think you have a copy of that picture. She, she may
have come in and said goodbye briefly and had another picture taken
when she left, but that's all I remember.
Q. All right. Do you recall any
conversation with her about obtaining a paying job after she returned
from her absence?
A. I don't.
Q. I'm talking about the absence caused by
her husband's death?
A. I understand. No, I don't. I don't know
if one occurred. I don't remember one.
Q. Do you recall, though, that at some
point she did receive a job that was a paid position at the White
A. Yes, I believe that she went to work in
the counsel's office.
Q. What was the process by which she
received that job?
A. I don't know the answer to that. After
she came to see
me, and she was, as I said, clearly quite agitated, when she walked out
I said to someone, maybe it was Nancy Hernreich was there who knew her
MR. BENNETT: Keep your voice up, Mr.
A. Maybe it was Nancy Hernreich who was
there and who
knew her, perhaps it was someone else, that we ought to see if we could
do something for her, and that's all I heard about it. I don't think I
was notified when she got the job at the counsel's office, and I'm not
aware of what she did there exactly, but I know that she did get a job
in the counsel's office, which she held for some time.
Q. Who in the White House would be
receiving applications for that job and making the decision who would
A. I'm not sure. The – Bob Nash runs the
operation, but I'm not sure that it would have gone through him. It
might have gone to the person, might have gone to someone in the
administrative line, like a deputy chief of staff or someone like that.
I really don't know. Perhaps we can find out for you, but I just don't
Q. Is Mr. Nash's title Director of
A. I don't think so. I think his title is
Appointments. I honestly don't know what his direct title is, but when
I deal with him, we're dealing with appointments to boards and
commissions and things like that.
Q. All right.
A. Ambassadorships, Cabinet, subcabinet.
Q. Now, you appointed Kathleen Willey to
Copenhagen to serve on the official delegation of the United States of
America at a world summit for social development, true?
A. She went as a White House appointee. I'm
not sure I
knew in advance of her going that she was on the delegation. I don't
believe I did. But I don't have any reason to know one way or the
other. I'm not sure I knew who was on that delegation.
Q. She did in fact attend that world summit
in March of 1995, correct?
A. I don't know if she did, but it, it, if
that's what the record reflects, then she did.
Q. And then –
A. I have no direct knowledge of that. I
don't remember who went for the United States.
Q. Was she appointed to serve on the
of the United States of America at a convention on biological diversity
in Jakarta, Indonesia?
A. I don't have any direct knowledge of
that. Since, in
preparing for this deposition, I have been informed that she was, but I
don't believe that I knew about it at the time she went.
Q. Do you know who made the decision to
place her on that delegation?
A. I don't. She had – was this after she
had left the White House?
Q. Yes, sir.
A. She had friends in the White House who
may well have
recommended her for it. I don't believe that I did, but I just, I don't
know anything about that.
Q. Can you shed any light on the process by
which she was selected to serve on the delegation?
A. No. I'm sure there's someone in the
White House who put that delegation together who could do so, but I
can't. I don't know.
Q. If you wanted to find out the answer to
that question, who would you go ask?
A. I would ask either the, probably my
deputy chief of
staff, John Podesta, to find out. If it was a foreign trip, perhaps
the, Mr. Nash. Katie McGinney, I don't know. But I have no idea how
that particular delegation was put together.
Q. Are you aware that she was appointed to
on the Board of Governors of the United Service Organizations Inc.,
also known as the USO?
A. I am now. When I was told about her, I
remember appointing her, but that was a direct presidential
appointment, so I assume at some point that I actually checked a piece
of paper which had her name on it, perhaps some others, but I didn't
remember it at the time until I learned it.
Q. That position on the USO Board of
Governors has a three-year term, does it not?
A. I don't know. I make hundreds of those
and all those recommendations are put together by Mr. Nash. If I wanted
to know why he was – literally in 90 percent, perhaps more, of the
cases of all presidential appointments, they're sent to me on a piece
of paper which says here's the appointment, here's the name of the
person, and there's a brief description of the position and who has
recommended the person and then accept or reject, and 90 percent of the
time I just get the files and I look at the position and I check it off
and go on, unless it's something that I know something about or care a
great deal about. I just trust the staff to handle it, so I would have
no idea why she was recommended or why she was appointed.
Q. Well, you would not check off someone's
approving the appointment if you had some reason to question the
trustworthiness of the individual, would you?
Q. And to your own knowledge, did Kathleen
Willey have a
reputation while working in the White House with respect to her
character for truthfulness?
A. No. I only know, the only thing that,
conversation I ever had with her that amounted to anything was this
conversation which lasted about 10 minutes, maybe a little more, and I
didn't doubt that she was telling the truth about what she was talking
about, but I didn't know her well enough to draw a final conclusion
about whether she was generally truthful or not.
Q. Was that the first conversation that you
ever had with her?
A. I think it was the first – I mean I had
talked to her
in passing, you know. She was, as I said, she was in Virginia when I
was there in the campaign, and I'd had conversations with her, but
that's the first time I'd ever actually sat and talked with her, to the
best of my knowledge. She was around when we did the presidential
debate in Richmond. She was around that, you know, working in that, and
I would talk to her, and she was always very friendly and very nice,
but that conversation, I remember this conversation very vividly
because she was so agitated and she seemed to be in very difficult
Q. But you don't remember any earlier
conversation other than just casual conversation?
A. Yeah, I'm sure I had casual conversation
with her. I knew who she was and she was always there when we were
there in Virginia.
Q. Let me hand you what has been marked
Deposition Exhibit 5.
MR. FISHER: I'm afraid I only have one
extra copy of this one, but if you'll send it back to me, you can look
at that copy.
MR. BENNETT: Do you have a copy for the
MR. FISHER: No, but I'll send that one
I ask only one or two questions. If you have an objection so that she
needs to see it, I'll pass that down.
MR. BENNETT: I could make a suggestions. If
have a series of documents you're going to be questioning about, out of
courtesy to the other lawyers and the Court, I would be happy to take
those and reproduce them so there's enough copies for everyone.
MR. FISHER: I think there are only one or
two letters for which I only have one copy.
JUDGE WRIGHT: Why don't we take him up on
offer and make a copy for the Court and one for Mr. Ruff and I'd, I
don't know who else. Mr. Bristow might like to have a copy.
MR. BENNETT: Could you give me, maybe you
on to another area or some direct questions to the president, and give
me everything that you want copied, and I'll have several copies made.
JUDGE WRIGHT: Actually you can give them to
Ward, if you don't want Mr. Bennett to see them until you present them,
and so you don't mind if Barry takes them?
MR. BENNETT: No, Your Honor, I'm just
trying to expedite things.
JUDGE WRIGHT: Sure.
MR. FISHER: The things that I have only
of are things that were produced just in the last day or so, and with
travel arrangements here and everything, I had a hard time coordinating
THE WITNESS: I know what this document is.
MR. BENNETT: Wait until he asks you a
MR. FISHER: At the next break I'll do
JUDGE WRIGHT: All right.
MR. BENNETT: Okay, fine. Okay. What's your
question to the president?
MR. FISHER: Did you have an objection
about this particular –
MR. BENNETT: No, I don't have an
Q. Is this a copy of a sexual harrassment
policy that you signed when you were the governor of the state of
A. It is. I signed it in 1987, and I'm
that I was, we were the first or one of the very first states to
actually have a clearly defined sexual harassment policy.
MR. FISHER: Objection, nonresponsive
beginning with the words, "I'm fairly sure."
Q. Mr. President, the criteria there under
numeral III were actually federal guidelines that you were adopting as
the policy in the state, correct?
MR. BENNETT: Well, Mr. President, read,
if he's going to ask you about little pieces of that, read the
A. Roman numeral III, it says that the
specified by the federal guidelines is, so assuming that, that the
staff person I had do this up accurately, that's correct.
Q. And after you became president, did you
come to believe that the federal guidelines were any different after
you became president than they were at the time you signed this policy?
MR. [Bill] BRISTOW [attorney for Clinton
co-defendant Danny Ferguson]:
Your Honor, I'm going to object to this. Is this a question of law, is
this like a, some sort of law school exam? It's supposed to be to find
factual evidence or factual evidence that will lead to the discovery of
other relevant factual evidence. To ask this witness, even though he is
a lawyer, do you think that the federal guidelines or the federal law
is the same as this state law, that's unfair. I object.
JUDGE WRIGHT: Overruled. The president has
testified that he signed this, he was familiar with it, and the case
concerns alleged activity when he was governor, and this is a cause of
action under Section 1983 and 1985 and that is state action, and I
think it is relevant what the governor knew about the state's sexual
harassment policy, or it could be relevant.
MR. BRISTOW: I'm not objecting to the
about the sexual harassment policy. I understood the question to be
that he wants to compare present federal law with the state law that
was in Arkansas when he was governor, and I think that is an academic
exercise. It's not a discovery issue.
JUDGE WRIGHT: I misunderstood the
MR. BENNETT: Your Honor, my view of this
Mr. Fisher wants to use his time with the president of the United
States to ask these kinds of questions, I personally have no objection.
But at three o'clock, I don't want to hear that we have ten major
integral areas that you haven't gone into.
JUDGE WRIGHT: All right, Mr., Mr. Fisher,
state the question again. I just, I misunderstood it, apparently.
MR. FISHER: The question, Your Honor, is
whether he ever came to the understanding that any of these guidelines
JUDGE WRIGHT: Well, you may ask, go ahead.
A. I don't think that question every
mind one way or the other. I have no knowledge of, that there has been
any change in the federal law. If there has been, if there hasn't been,
I have no knowledge of that.
Questions regarding Monica Lewinsky
Q. Now, do you know a woman named Monica
A. 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
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
A. I don't know when she started working at
the White House.
Q. Do you recall when you met her for the
A. It would be sometime, I'd think, in
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?
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.
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
Q. And you never talked to anyone about
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
affair 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's 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 officer 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.
JUDGE WRIGHT: I want to interrupt because I
want a break. I also
wanted to ask about the luncheon break. We're not, we're not too far
from 12. I personally don't care when we take it, but has Skadden
lawyers arranged for lunch to be brought up to us?
MR. BENNETT: I've arranged for lunch, Your
Honor. We can have it
– I don't know if it's there right now. We were thinking 12:30, but
JUDGE WRIGHT: That's great. That's
MR. BENNETT: And we have a room set aside
for you and your law
clerk where you can eat privately, and we have a separate room for
their side of the table, and our side.
JUDGE WRIGHT: All right, let's take a
Q. Mr. President, before the break, we were
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
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: 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
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. BENNETT: Fine.
MR. FISHER: I would welcome an opportunity
to explain to the Court what our good faith basis is in an in camera
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
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
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
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.
JUDGE WRIGHT: Go ahead.
MR. FISHER: Thank you, Your Honor.
THE WITNESS: What was your question again,
MR. FISHER: I've forgotten, Mr. President,
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
A. Well, let me try to describe the facts
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
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
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
Now, to go back to your question, my recollection
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
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
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 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
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
A. Well, I don't know, because normally I'm
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
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
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
A. I'm trying to remember. Probably sometime
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
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
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.
THE WITNESS: Okay.
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
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
Q. Did you talk to Mr. Lindsey about what
action, if any, should be taken as a result of her being served with a
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.
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?
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
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
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?
Q. What's his title?
A. He's the ambassador to the U.N.
JUDGE WRIGHT: I'm sorry, I didn't hear
THE WITNESS: He's the ambassador to the
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
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
A. I don't recall. Do you know what they
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
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
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
A. Once or twice. I think she's given me a
book or two.
Q. Did she give you a silver cigar box?
Q. Did she give you a tie?
A. Yes, she had given me a tie before. I
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?
Q. If she told someone that she had a
sexual affair with you beginning in November of 1995, would that be a
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
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
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?
Q. What did he say that she had said to him
A. He just said she seemed like a bright,
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?
MR. FISHER: Sure.
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
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
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
Q. My question, though, is focused on the
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
JUDGE WRIGHT: Are you suggesting we take a
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
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
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
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
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
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 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
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
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.
Pages 89 to 103 missing
... down time, that is, if I was waiting between
appearances, or I got there a little early or they were running a
little late, and I had something I needed to do, some work I needed to
do, there were, over the years, best I can remember, roughly I did, one
of three things happened. Either, if I had four or five minutes, I'd
just go to the standard pay phones on the second floor of the
convention floor and make phone calls. If I had more time, or I needed
some desk space or some privacy, sometimes they would give me a little
office-like space, or sometimes when conventions were there, they would
let me use a, a suite that they had set aside for the convention.
And frequently I remember, when that happened –
didn't happen too many times, five or six times over time, but, you
know, there'd be, often be people coming in and out of there, they'd be
bringing hors d'oeuvres or something, or people would be coming in and
out setting up meetings because they'd set aside for the convention,
but it was still nice enough for me, because they always, there was a
desk there, and a phone, I could write and make notes, and they never
bothered me any when they were coming in and out, so I just didn't,
that wasn't – so it is possible that they made available such a space
for me, but I do not believe in the whole time I was governor they ever
gave me a, a suite that was not already set aside for the use of the
convention. At least I wouldn't have known it if they did. That's my
But I was there several time sort of in between
where I had a little drag time and those were the three different
things I remember doing during those time. I don't have any specific
recollection of what happened on May the 8th, but over a ten year
period, that kind of thing happened.
Q. Do you recall ever, at one of the
Quality Conferences, asking a state trooper to make arrangement to have
a suite or a room made available to you at the Excelsior Hotel?
Q. Do you recall whether any of the
Quality Conferences at the Excelsior Hotel you ever met a woman in a
suite or a room other then the room where the conference was taking
A. No, I, you know, over the years I met a
of people at a lot of these meetings. I don't. Let me just say, with
regard to your previous question, if, when the Excelsior, if they let
me use a room, the trooper went up for it, to the best of my knowledge
the only time they ever did that is they had the room set aside already
for the use of the convention people, but I don't have any specific
recollection of that on May the 8th.
Q. When they did have a room set aside, as
you just described, do you recall where in the hotel it was located?
A. Well, they, I don't know that it was the
place. I was – many times I'd be at reception for these convention and
they'd, they had them in suites, you know, up near the top of the
hotel. I don't know what the room numbers were or where they were on
the floors or anything like that.
Q. But do you remember that at least some
of them were up on one of the upper levels of the hotel?
A. Yes, I do. I think that's what suites
are in the Excelsior. I'm not sure they have them on every floor.
Q. Now, seated to my right two chairs down
is Ms. Paula Jones. Do you recall ever having met her before today?
A. No. I've said that many times. I don't.
Q. Do you recall ever having seen her
before early 1994 when she first made public her accusations against
A. No, I, I actually saw her on television
just by accident. I just happened to be walking by a television in the
office, and I remember I asked Bruce Lindsey to come there. I said
Bruce, do we know this lady, who is this person? That was my first
Q. Before you saw Paula Jones on
television, do you have any recollection of ever seeing her before?
A. No, sir, I don't have any memory of it.
you have to remember, I've met well over a hundred thousand people
since 1991, maybe over two hundred thousand. Maybe more that that. I
MR. FISHER: Objection, non-responsive,
beginning with the words, "But you have to remember."
Q. Have you ever said to any of the state
troopers who were on your security detail when you were governor that
any woman had, quote, "that come-hither look," close quote?
A. I might well have done that. That's a
I have used. I might well – I don't have a specific recollection of
doing it, but it wouldn't surprise me if I'd said that to a trooper.
Q. What does the phrase "that come-hither
A. It means either in look or dress a sort
of a suggestive appearance from the look or dress.
Q. Sexually suggestive?
Q. On any of the – strike that.
During any of the Governor's Quality Conferences
you attended, do you recall ever saying to anyone that you needed to go
to a suite because you were expecting a call from the White House?
A. No, sir, I don't. I got calls from the
House from time to time. I got other calls. I had other business in
Washington from time to time. I took calls in difference places than
the governor's office from time to time, but I don't have any specific
recollection of it.
Q. Can you think of any
reason why you would
have received a call from the White House in May of 1991?
A. I don't remember if I did. First of all,
I don't know if I
did. If I did, I don't know what it was about. If you're asking me can
I think of any reason, there were many issues on which I basically
represented the Democrats and sometimes the governor of the whole with
the Bush administration. But I, I have no specific recollection. I was
one of the senior governors in the country at the time, and I worked
with them on a lot of things, and I had people call me all the time,
but I don't remember what specific issue was going on then.
Q. You don't have a recollection of
receiving a call from the White House when you were at the Excelsior
A. No, sir, I don't, I don't remember
anything about that.
Q. Now, Danny Ferguson was a member of your
security detail for several years?
A. Yes, he was.
Q. He was guarding your life and the life
of your wife and your daughter, correct?
A. He was on the security detail.
Q. And while you were governor and he was
working on your security detail, did you ever form any opinion as to
his character for truthfulness?
A. While I was governor, I had no reason –
was around him quite frequently, and I thought his work was entirely
satisfactory, and there was no – I had nothing happen while I was
governor that would cause me to question his truthfulness, if that's
what you're asking.
Q. Has your opinion as to Danny Ferguson's
character for truthfulness changed?
Q. Did you ever ask Danny Ferguson to pick
up a gift you were giving to a woman other than your wife or a
A. I don't recall doing that. It's possible
that I did. Sometimes if they were going to be out and around, I'd,
might ask them to do something like that, but normally I didn't, but I
might have done that.
Q. While you were governor, was there a
store in Little Rock names Barbara Ann's?
A. Barbara Jean's.
Q. Barbara Jean's?
Q. Do you recall –
A. Isn't that right?
MR. BENNETT: Barbara Jean's is correct.
THE WITNESS: I think that's right.
MR. BENNETT: But you should no feel a moral
obligation to correct his errors.
THE WITNESS: Go ahead. Go ahead.
Q. Do you recall ever sending any of the
troopers who were on your security detail to Barbara Jean's to pick up
a gift that you were going to give to a woman other than your wife or a
A. No, sir, I don't, and I don't remember
giving a gift to anyone other than a member of my family from that
store. I knew the woman who owned it, and it's possible that I did, but
I don't remember it.
Q. Her name is what? The woman that owned
A. Barbara – I don't know.
JUDGE WRIGHT: I'm not here to testify. I
believe it's Barbara Baber.
MR. BENNETT: I object. No, I'm just
A. I think that's right. In other words I
met her so I knew who she was, so I, I guess what, the reason I said
that is, I believe I shopped there rarely, but on occasion, over a
ten-year period, but I have no recollection of buying a gift for anyone
other than a member my family there.
Q. Did you ever send a state trooper who
member of your security detail to any store to pick up a gift for a
woman other than your wife or a relative?
A. I have no specific recollection of doing
that. I wouldn't – it's possible that it happened, but I don't
Q. Now, after you took office as president,
did you ever have any telephone conversations with Danny Ferguson?
A. Yes, I did.
Q. How many?
A. I'm not sure. I think two or three. I
have some noted there, which I know you've been given, but I'm not –
MR. BENNETT: Just answer the question –
A. I'm not sure.
MR. BENNETT: – Mr. President.
Q. Without consulting your notes, do you
any independent recollection of anything that was said in any of those
conversations with Danny Ferguson?
A. I sure do.
Q. Okay. What is that recollection.
A. Well, he called me secretary in Little
Rock. Linda Dixon, and asked me to call him, and I was afraid, you
know, I thought there was something, he had a personal problem. I
didn't have any ideas what he wanted to talk to me about.
MR. BENNETT: Mr. President, excuse me, keep
your voice up, please, so the Judge hears you.
A. I didn't have any idea what he wanted to
talk to me about, and when I called him he wanted to talk to me about
the, what have now become famous as the so-called trooper stories to
The American Spectator. And he said, he acknowledged either at some
point during these conversations that he had been a part of the, at
least had met with one or two reporters and a Republican lawyer in
Arkansas. He said that the troopers had been offered seven hundred
thousand dollars in hundred thousand dollar a year increments for jobs
that they would take as soon as they could leave the state police out
of the state of Arkansas, plus whatever other money they could earn in
books and incomes up to a million dollars if they would trash me. He
further said that they were told in no uncertain terms that what they
said about me did not have to be true, it's just that two of them had
to tell the same sorry, and if three of them told the story they could
get it printed anywhere, whether it was true or not.
He then said that the troopers who talked to them,
principally Patterson and Perry, obviously didn't know anything, and
that basically, I remember very well, he said there's basically two
kinds of lies in these stories, there's stuff we just made up out of
whole cloth, and he said then there's the stuff that happened that we
twisted to make it look as bad as possible. And he said I'm out of
here, I'm not going to do this, and I said well, why don't you say it's
not true? He said I can't do that, they'll get to me if I do. I don't
know what he meant by that. But that's the summary of what he said. And
that's consistent with my experience with The American Spectator types
over the last six years, and what I was told would happen if I ran for
MR. FISHER: Objection, non-responsive
beginning with the words –
JUDGE WRIGHT: Let me, I have not been
on your objections because this is a deposition, I didn't think you
wanted me to rule, you were just making your record, but since I am
here, I will say that this is improper for the witness to go on and
comment such as he just did. It's also of course improper for you to
make comments, so to that extent that objection would have been
sustained, and that's all I'm going to say. Go ahead.
Q. Approximately when did the conversation
you just described take place?
A. Well, it would have been, at least the
first conversation would have been sometime I guess in –- maybe my
notes reflect it, I don't really remember, but sometime in mid-1993,
late, summertime 1993, maybe something like that. It was before Ms.
Jones made her statement, because there was no discussion of her in it.
Q. Now, the testimony you just gave about
Danny Ferguson said, was that relating the content of one conversation,
or was that more than –
A. I don't remember. You, you've got the,
you've got the notes there, and they will, they probably reflect
whether it was one or two or three conversations.
MR. FISHER: Would you mark that please
(EXHIBIT 8 marked.)
Q. Sir, I am handing you what has been
as Deposition Exhibit 8. Ignoring the fax information at the top of
each page, can you identify the typed words on this document as a
transcription of your notes of conversations with Danny Ferguson?
A. That's what they appear to be. Have you
got a copy of the, my handwritten notes?
Q. I do, but not with me.
A. That's what it appears to me, I don't
remember verbatim what's in my handwritten notes.
Q. Did you look at the
your deposition today?
A. I'm not sure that I did, actually, but I
helped to prepare it
because there were a couple of words that the people who prepared the
transcription couldn't read. Or a couple of words I had trouble
reading. My handwriting's not very good, but –
Q. Look through Exhibit 8, if you would,
sir, and tell me
whether you see anything there that looks like it was not what you
A. No. This is – it looks very much like –
what is typed here
seems, is reminiscent of what I wrote in my handwriting. I just don't
have the handwriting here and can't be for sure.
Q. How many separate calls are reflected in
MR. BENNETT: Well, excuse me, Your Honor.
We have provided the
original of the notes, and if Your Honor even looks at this typed
transcription all of the words are not clear. I would suggest they show
the original notes to the witness or at least provide both to him
before they ask questions.
JUDGE WRIGHT: All right, go on and show him
the original notes,
but the question with respect to the number of conversations is all
right. That's –
A. I believe there were, I believe there
were two conversations,
although there could have been three, and I honestly don't recall. When
I looked at my notes, many, many months later, it appears to me that
there were two conversations.
(EXHIBIT 9 marked.)
A. Mr. Ferguson might have a better memory
than I do. I don't know what he said about it.
Q. Sir, I'm handing you what has been
marked as Deposition
Exhibit 9. As you can see it bears the caption of this case and is
entitled President Clinton's Responses to the Plaintiff's Third Set of
Q. Are your notes attached to the back of
A. Excuse me, let me see. Yes, they are.
Q. Okay. And there are four pages of notes,
A. Yes, that's correct.
Q. These are all in your handwriting?
A. Yes, they are.
Q. Upon examination of these notes, can you
tell us how many conversations with Danny Ferguson are reflected here?
A. It – as I said, it appears to me that
there are two, but the
last – but it is possible, I suppose, that there are three, because I'd
had to do a very neat job of enumerating the pages. I believe there are
two. I don't know for sure.
Q. Is there any document in your possession
that you're aware of
that would reveal the date on which each of the conversations took
A. Not unless the White House operator or
the – not unless we
have some White House document that reflected when that, when the call
was made. I just don't know if we do, but I know the first one was
sometime in the latter half of 1993, and I'm not – and the second one
was sometime thereafter, and apparently before the American Spectator
story was published.
Q. Who found these notes?
A. I think I had them. I just was sort of
scribbling them off and I, and I had them. I put them back somewhere.
Q. Where did you put them?
A. I'm not sure. I think I had them either
in a – I'm not sure where they were. I had them put away someplace.
Q. Were they in a file folder?
A. I believe they were.
Q. What was the title or label on the file?
A. I don't think there was a title or label
on the file. They
were just notes that I made to myself when I was scribbling off in a
hurry talking to Danny.
Q. Were there any other documents in the
file with these notes?
A. No. I had them separate. These are the
conversations I had like this. I gave them to my counsel some time ago,
so I just don't remember where I had them at the time I gave them to
Q. Where is the file from which the
original notes were taken currently located?
A. There wasn't – they were just in a
folder. I don't know what
happened to the folder. I don't know if they have the folder. I don't
know what happened to the folder. There was no file with a name and a
big file box or anything. I just put these notes aside.
Q. After you became president, did you have
any conversations with Danny Ferguson for which you kept no notes?
A. Not that I recall. I, I believe I ran
into him and said hello
at the, in Seattle at the, I believe he was with Governor Tucker in
Seattle at the Asian Pacific leaders meeting, at least he might have
been, whoever was there, whatever troopers were there with him, with
the governor, I stopped and said hi to them, but that was it, that was
the extent of it, so if he was one of those troopers, then I did say
that. I didn't keep a note of that. I don't believe there was any other
conversation for which I kept no note. If I did have one, I don't
Q. On that occasion in Seattle, did you
talk to Danny Ferguson about the lawsuit?
A. No, sir. I didn't.
Q. Did you talk to Danny Ferguson about
A. No. I don't have any recollection of
that. I think that was
before the Paula Jones matter came out. I believe it was. I don't
remember, but I don't, I don't have any recollection of talking to
Danny Ferguson about any of this. I think I just said – if he was there
I think I just said hello to whatever the security people that were
there with the governor.
Q. Did you talk to Danny Ferguson about
stories being told by any other state troopers who had been on your
A. In Seattle?
A. I don't believe so, no sir.
Q. So that possible conversation in Seattle
conversations reflected in your notes here, which are part of
Deposition Exhibit 9, those would be all the conversations you remember
having with Danny Ferguson since you became president, correct?
A. To the best of my memory. I would not –
but I could well have
talked to him another time, I'm just telling you what my memory is.
I've had several thousand phone calls. I'm giving you the best of my
Q. Do you recall Danny Ferguson ever
telling you that he had given an interview to a reporter with the Los
A. I recall Danny Ferguson saying that he
was, he met with a
lawyer and three other troopers, and I don't remember whether he said
that the reporters were there or not. You see that there's an L.A.
Times reporter mentioned in the second phone call there. I don't know
if I can tell from the notes whether he actually met with him or not.
Q. Which page of the notes are you looking
A. Page, third – the first page of the
Q. In the transcription, which of the four
pages is that?
A. The third.
Q. Okay, You're talking about the reference
to the L.A. Times reporter Bill Remmel (sic)?
Q. Did Danny Ferguson ever say to you that
he, Danny Ferguson, had made untrue statements to the L.A. Times
A. He said exactly what those notes
reflect. And you can draw
whatever inference from them you want. He said exactly what those notes
reflect. As I, if you look at page one, I said he was hedging on how
much he said but clearly shared rumors, made up stuff, talked about how
they were angry because I didn't give them jobs.
MR. BENNETT: Keep your voice up, Mr.
A. And had some other rumors. He said he
and his wife were
trying to stop the rumors. He said he went to the first meeting to see
what they were doing and he played along with them, that's what he said
to me. I said it's not true, he says he knows but he wants to stay out
of it. And I'm just, I just wrote down here what he said. Then he said
that he was threatened by the – that he felt threatened and under
pressure, and then he said that the L.A. Times reporter threatened him.
That's all, you know, I have no memory independent of these notes that
I took here.
Q. All right. Now, on the first page where
you wrote, and I
quote, "hedging on how much he said but clearly shared rumors, made
stuff up," end quote, did you understand that it was Danny Ferguson who
made stuff up?
A. I understood he said to me that they
made stuff up. It was
clear to me that he had at least gone to the meeting and at least in
silence gone along with whatever was done in the beginning, which he
later acknowledged doing, and all I can tell you is what he told me
there. He said, he said they were encouraged to be as negative as
possible, they were told they didn't have to tell the truth, they were
told all they had to do was to get two or more people to agree, and if
they got three people to say the same thing, anybody in the world would
print it, didn't matter if it was true or not, and there was a lot of
money in it for them if they did it, that's what he told me, and then
he said he just, he didn't, didn't want to be a part of it, didn't want
the money, wanted out, wished it had never happened, but he didn't feel
like he could ever contradict anything, which I gather meant that he
had participated. That's all I know.
Q. Did he ever tell you that he had talked
to a reporter named David Brock?
A. David Brock's name is mentioned here. He
never – he wasn't
specific with me about what he said to Brock or what he said to Remmel
(sic) or what he sat in the room and listened to others say and didn't
contradict. He was never specific about that.
Q. Now, Buddy Young was a state trooper who
was assigned to your security detail at some point, correct?
A. He was the head of governor's security.
Q. And after you became president, you
appointed him to a position in the federal government, correct?
A. He was appointed regional director of
the Federal Emergency
Management Agency, and most of those regional directorships are
presidential appointments, so I assume that was a White House
appointment. I'm not positive, but I assume it was. Most regional jobs
are with most departments.
Q. Before the appointment,
did he ever express
an interest to you in receiving a federal job?
A. Yes, he said he could take retirement
from the state police,
and he was ready to do so, that he'd put in his time and he would like
to get out.
Q. Did he say that to you before or after
you took office as president?
A. I believe after I – I believe it was
before I took office. I
was actually surprised. I think Buddy Young was the youngest captain in
the state police and a very able office. He probably could have become
the commander of the state police.
MR. FISHER: Objection, non-responsive
beginning with the words, "I was actually very surprised."
JUDGE WRIGHT: Okay, sustained.
Q. Do you have any notes of any
conversations with Buddy Young?
A. No sir, I don't. I don't believe I do.
I've attempted to look
for any other relevant notes that might be relevant to my Counsel or
your request for discovery. I don't find any. I don't believe I do.
Q. Do you have any notes of any
conversation with any state trooper other than Danny Ferguson?
MR. BENNETT: About – I mean, objection.
It's too broad. I mean, he dealt with state troopers all the time.
JUDGE WRIGHT: Let me clarify this. Are you
talking about during his term as president?
MR. FISHER: Let me put a time limitation on
that, Your Honor.
JUDGE WRIGHT: All right.
Q. After you became president, do you
recall taking notes of any
conversation that you may have had with a state trooper other than
Q. Have you looked to see whether you have
any such notes?
A. I don't think I have any other notes.
I've tried to find any
notes that would be responsive to your request for production. We've
given you some other notes that I have. I don't, I don't think I have
anymore. And I have no recollection of taking any.
Q. After you became president, did you ever
ask Buddy Young to
talk to any of the state troopers who had been on your security detail
when you were governor?
A. I, I believe, actually I think I did.
No, wait a minute, after I became president?
A. Back up. I had a conversation with Buddy
Young in which I
asked him if he knew anything about this purported – this meeting that
Danny Ferguson described with himself and the other three troopers, the
two reporters, Cliff Jackson, and another Republican lawyer. I don't
recall asking him to speak to any of them. I think I was more
interested in asking if he knew anything about it or what it
precipitated, and I had a conversation like that.
Q. After that conversation, did Buddy Young
Pages 89 to 104 missing
... husband, was our ambassador to Switzerland,
and during that time
she undertook some appointment I gave her during, and it may have been
a paid appointment, she may have been. If you could ask me a question
or give me more information, maybe I could give you a better answer.
I'm just not sure whether it was an appointed position without pay or a
Q. If I could remember the position, I
would do that sir, but it
slips my mind at the moment. Did you appoint her to that position?
A. Well, she was appointed during my
presidency, and I'm sure
under my authority. I don't remember making the decision or, initially,
but I'm sire someone recommended it and I went along with it.
Q. Now, have you ever spent the night at a
home owned by Jane Doe 7?
A. Yes, I have.
Q. Was that in Jackson Hole, Wyoming?
Q. Where was it located?
A. It was located in San Diego, California.
Q. And was that while you were president of
the United States?
Q. Was it before or after her appointment
to the position that I can't remember?
A. I don't remember. My family and I
actually stayed at her home
for several days on vacation a couple years ago. I don't remember
whether it was before or after, and then there was at least one other
occasion when I spent the night there. I don't remember when it was or
whether it was before or after.
Q. Did you ever stay in the home of Jane
Doe 7 when your wife was not with you?
A. I believe I did once. I believe, I
believe I did. I do not
remember for sure. I believe I stayed there once when she was not with
Q. On – excuse me for interrupting.
A. I think Bruce Lindsey was with me.
Q. On that occasion did you have sexual
relations with Jane Doe 7?
A. Absolutely not.
Q. Have you ever at any time or any
location had sexual relations with Jane Doe 7?
Q. Did you ever attend a party at the Hotel
del Coronado which was attended by Jane Doe 7?
A. She and her husband owed the hotel, and
I went to several
events there, and I think they were there for most of the events I
Q. On any of those occasions were you in
one of the rooms of the hotel alone with her?
A. I don't believe so.
Q. And when you were governor of the state
of Arkansas, you
appointed Jane Doe 2 to the position of Judge on the Arkansas Court of
A. I did, yes.
Q. And she decided cases on the Court of
Appeals for two years, correct?
A. That's correct. It was a newly created
Court, and I appointed her to a position on it.
Q. Do you recall when that appointment was
Q. Now, if she testified that while you
were governor you
visited her home on more than one occasion when her husband was not
there, would that testimony be true?
Q. How many times did you visit the home of
Jane Doe 2 when her husband was not there?
A. I'm not sure. Probably, I don't know,
four or five, over a
ten-year period, maybe a few more, maybe a few less, I don't know,
Q. And on those occasions, on any of those
occasions, were you
alone in the house with Jane Doe 2, or were there other people there in
the house with you?
A. No those, are – I answered the question
you asked me, on those occasions she was there and I was alone.
Q. Were you driven to her house by a state
Q. On any occasions did the state trooper
come into the house with you?
A. I don't remember. Usually when state
troopers drove me places like the homes, they didn't go in with me.
Q. Okay. What would they typically do?
A. Stay outside, look around, see what was
going to happen. They normally didn't go inside with me.
Q. Did you ever send them off to run
errands on those occasions when you were in the house alone with Jane
A. I don't believe so. I don't remember
Q. What was the purpose of these visits to
Jane Doe 2's house when her husband was not there?
A. The fact that her husband was not there
was incidental. She
was a friend of mine, and I would go by and see her from time to time.
I hadn't been visiting with her in a long time. Sometimes I saw him
when she wasn't there. He was a friend of mine, too.
Q. So the purpose was purely social?
A. That's right.
Q. Did you ever –
A. I say the purpose was purely social,
there may have been
times when we discussed political issues or some other issues. I don't
know that they were purely social, but they were personal.
Q. Were any of the visits that you had with
Jane Doe 2 at her home when no one else was in the home with you at
A. You know, I don't remember going there
at night. I may have.
I couldn't say that I didn't. I believe the vast majority were in the
daylight hours. But I can't say that I was never there at night when
they weren't both there. I just don't remember.
Q. Did you ever have sexual relations with
Jane Doe 2?
Q. At any location?
Q. What were her qualifications to serve as
a Judge in the Court of Appeals?
A. She was an intelligent,
who was a good
friend and supporter of mine. And I thought she would make a good
judge. The evidence is that she did, I think.
MR. FISHER: Objection, non responsive
beginning with the words, "The evidence is."
JUDGE WRIGHT: I'll sustain. Go ahead.
Q. Had she ever argued even a single case
in the Court of Appeals before you appointed her?
A. I don't think there was a Court of
Appeals before I appointed
her, so the answer to that would be no, but that would put her in the
same boat with every other judge. The Court of Appeals was a newly
appointed court. The judges were to be elected but I had to appoint the
first batch so it could sit and begin to decide cases, and then there
was a system for electing them. After that they were all elected.
That's the way they are now, except when a vacancy occurs, and the
governor appoints just for the remainder of the term.
Q. Isn't it a fact that you appointed her
to fill the unexpired
term of another judge who was moving on to the Arkansas Supreme Court?
A. That could be. That could be. I didn't
remember. I was
thinking I did it at the beginning of the term, but you're probably,
but you're right about that. I'm sorry. I'd forgotten about that.
Q. Do you recall an occasion when you and
Jane Doe 2 drove together from the airport to the governor's mansion in
A. Yes, I remember that.
Q. And she let you drive the Jaguar,
A. She did.
Q. Was there a state trooper in another car
driving ahead of you?
A. Well, there must have been. I remember
the circumstances of
that day quite well, and so I, there would have been a trooper with me
all day, so if, if I got to drive the Jaguar, which I wanted to do –
MR. BENNETT: Keep your voice up.
A. If I got to drive the Jaguar, which I
wanted to do, then the
trooper would have been either behind or just ahead of me, that's what
they always did. I didn't drive much like that, but it was too good an
opportunity to pass up. I'd never driven a Jaguar before.
Q. You said you remembered the
circumstances of that day very well. What do you remember happening on
A. A good friend of hers and mine, Rudy
Moore, who was my first
chief of staff, son was killed in a tragic car accident in his senior
year of high school. I wanted to fly up and see him, and she wanted to
go with him, and they were very close, and my recollection is it was on
that trip when we got back to Little Rock after going up to see him
that either she said do you want to drive the Jaguar or I said can I do
it. We were both really profoundly sad, and we both cared a lot about
the guy and about his son, and it was a very sad day. I remember it
Q. Did you fly together in a, an airplane?
A. That's correct. She, she flew with me up
Q. Is that a commercial aircraft or a
A. I think it was a private airplane. I
think it was one we,
that we either chartered or borrowed to go up there. I don't believe it
was one of the state planes. It could have been. I don't remember which
plane it was, to be honest with you.
Q. Do you recall who was on the plane with
A. No, there would have been a trooper on
the plane. There might
have been other people on the plane as well. There were – Rudy had
other, a lot of other friends in Little Rock. I just don't remember
whether anyone else went.
Q. Do you know a woman named Jane Doe 1?
A. I do.
Q. Do you recall her visiting you at the
between the time that you were elected president and the time that you
moved to Washington to take office?
A. I do.
Q. On how many occasions in that time span
did she visit with you at the governor's mansion?
A. I believe she was there twice. I believe
she was there twice.
Q. Was one of those occasions the early
morning of the day that you left to go to Washington?
A. I don't – well, I don't know. She came
by early in the
morning, either the day I left or the day before that, sometime around
then. She wanted to come by and say goodbye, and she had to go
somewhere else. She came by early, I was up. I don't remember, I
honestly don't remember what exact day it was, but it was close to the
time I left.
Q. Do you recall that Danny Ferguson was
with you when she arrived?
A. I don't have an independent recollection
of that. I know what
the testimony was, but I don't actually have an independent memory of
Q. Where did you meet with her on that day?
A. I believe in the basement, which we were
sort of using as the
all-purpose office at the time, and which was full to the gills of all
kinds of things that were being sent in from all over America, but it
was kind of an around-the-clock office for us.
Q. Was that basement room sometimes
referred to as the game room>
Q. And while you were talking to Jane Doe
1, was anyone else in the game room with you?
A. No. I don't believe anybody was there.
Q. Was Danny Ferguson outside the game room
in an adjoining room?
A. I don't, I don't know where he was. I've
already said I don't
remember having an independent recollection who was there that day.
Q. Okay. You said you remembered you
thought two occasions when
you were president-elect that she visited you at the governor's
mansion. When was the first of them?
A. I don't remember exactly when it was,
but I just have a vague
memory that she came once before Christmas, and I gave her some gifts
for her children and herself. I believe that's right. I just – I've
been trying to think. I think, I'm almost positive there were only two
times, and I believe those, I think those were the two occasions. I'm
quite sure she was there early in the morning shortly before I left,
and I believe she was there one other time, and I believe, but I'm not
sure, that's why she was there. That's all I know about that.
Q. Okay. On the first of these two
occasions, what time of day did you meet?
A. I don't remember.
Q. Do you remember if it was dark outside?
Q. Where did you meet with her on that
A. I don't remember.
Q. Do you remember whether anyone else was
with you when you met with her?
A. No, but – I don't remember, I don't
remember. I, I assume not, but I don't remember really. I don't know.
MR. BENNETT: Don't assume, Mr. President.
Q. Did you ever meet with Jane Doe 1 at her
apartment? And I'm
not just asking about the time when you were president-elect, but any
time when you were governor?
A. I have been to her place.
Q. It was located at the Riviera
Apartments; is that correct?
A. I don't believe that's right.
Q. What were the apartments called where
A. I don't remember.
Q. When you visited her place, as you put
it, were you accompanied by a state trooper?
A. I don't remember. I'm not sure I was.
Q. Were you governor at the time?
Pages 145 to 160 missing
... to the time when you decided to run for
president in the
1992 election, did you take any action to try to suppress any rumors
about any particular women who allegedly had had sexual relationships
MR. BENNETT: Now, when you say – excuse me
– when he said –
objection to the form. When you say "suppress," do you mean him
personally? Do you mean him personally?
MR. FISHER: I asked whether he took any
MR. BENNETT: Okay, whether he personally
took any action. Okay, thank you.
A. Could you could you ask the question
again because –
Q. Yes, sir.
A. – I want to give you a completely
accurate answer. I want to make sure I understand the question.
Q. Between the time when you decided not to
run for president in
the '88 election and the time when you decided to run for president in
the '92 election, did you take any action to try to suppress any rumors
about women who allegedly had had extramarital affairs with you?
A. I believe the accurate answer is that
because of what
happened in the 1990 governor's race I took action to try to prevent
erroneous rumors from becoming public news.
Q. Alright, sir. What action did you take?
A. Well, if I could begin at the beginning.
A man named Larry
Nichols worked for the state of Arkansas, and while working there he
developed quite a grudge against me because he made six hundred long
distance phone calls to various right-wing groups with which he was
associated, and when it came out his boss thought the taxpayers
shouldn't pay for it and dismissed him. He was not reinstated. He
claimed that what he was doing was in the public interest. I won't go
through the details.
He subsequently directed his anger at me and
alleged that I had
had affairs with a number of women, so the first action I took that I
remember was, he did this on the steps of the Capitol one day in 1980,
'90. A few minutes after this press conference he had, I drove up to
the Capitol and a reporter confronted me with it. I said to the
reporter, this is the first I have ever heard of it, why don't you call
the women and ask them if it's true before you run the story. That's
the first action I took. I don't know if that qualifies as suppression,
but it, back then, you know, if you denied something like that, it
didn't get in the press. So that was the first thing that happened.
And then, then a lot of that, that was, as far as
that's about as far as it went in 1990. And then some of those were
recycled again in the '92 campaign.
Q. During the 1992 campaign, did you give
Betsey Wright the
responsibility to deal with rumors about alleged extramarital affairs
A. Along with the other charges that were
made against me.
A. Which I, some of which
I enumerated earlier
in my testimony.
Someone had to, someone who knew me, at least, had to deal with any
charges that came up and had to find the best way to respond to them.
THE WITNESS: Actually, Judge, could I have
a five-minute beak? I'd really like to go to the restroom.
JUDGE WRIGHT: Yes, you may. We'll be in
recess for five minutes.
(Exhibits 10 – 13 marked.)
JUDGE WRIGHT: All right, Mr. Fisher, you
MR. FISHER: Thank you, Your Honor.
Q. Sir, I'm handing you what has been
marked as Deposition
Exhibit 10. Do you recognize that as a copy of your responses to the
Plaintiff's First Set of Interrogatories in this lawsuit?
MR. [MITCHELL S.] ETTINGER [associate of Mr.
Bennett]: Mr. Fisher, do you have an extra copy?
MR. FISHER: I slid two over there.
A. Yes, sir. I do. I recognize this. It, it
appears to be signed by Mr. Bennett.
Q. Would you please just read over the
response to the
interrogatory number one, which is only three lines long, and tell me
whether it's still true and correct.
A. It is still true and correct.
Q. All right, thank you, sir. Now, would
you please turn to the last page of Deposition Exhibit 10?
A. Yes, sir.
Q. Is that a copy of a verification, which
A. It is.
Q. I'd like to direct your attention to the
words, four lines down, "to the best of my knowledge...
Pages 165 to 176 missing
Q. I was going to ask you that same
question. There was not a date on the copy produced to us.
A. I don't know. Let me say, at some point
remember running into Gennifer Flowers when she moved back to Arkansas.
She had been away for several years, and I, I ran into her. I didn't
know she was back, and she, at some time thereafter she wrote me
another letter. I know there were two letters. I don't know which one
this is. I'm not – I don't want to mislead you. I just, I don't know
which one this is.
Q. Let me show you another one that might
Q. I'm now handing you, sir Deposition
Exhibit 12. Is this another letter from Gennifer Flowers to you?
A. Yes. Now this says, this one has a stamp
on it, and a name. The stamp says February 25, 1991.
Q. So this would have been received after
she returned to Arkansas from Dallas?
A. That's correct. This one did. But I
think the other one was written some years before that, as I, as I
Q. All right. Let's talk about Exhibit 12,
the one that has a date on it.
A. And the, the answer to your – well, you
asked me a questions about 11, didn't you?
MR. BENNETT: Mr. President let him ask the
A. Go ahead.
Q. What if anything did you do in response
to Deposition Exhibit 12?
A. Well, there is a note up here in the
left-hand corner, though it is not in my handwriting, that says Gaddy
on it. Judy Gaddy, and it says Judy has not been very successful in the
job hunting area, that's that this letter says. That indicates to me
she's already been in touch with her. This letter was just forwarded to
her. Judy, Judy Gaddy worked in the governor's office and that was her
job, helping people get jobs.
Q. What, if anything, did you do in
response to this letter?
A. Well, the letter itself, the copy I have
doesn't indicate that I did anything. I have no recollection of doing
anything except giving it to Judy Gaddy to see if she could do
something to help Gennifer Flowers. She handled many cases like this
where people had some difficulties and needed some help.
Q. Eventually Gennifer Flowers was hired to
work as a state employee for the Arkansas Board of Review Appeals
A. That was – some months after this,
right. I believe that's right. I think several months after that she
did get a state job. Which was a few months after this and a few years
after the first letter.
Q. At the time Don Barnes was the Chairman
of the Board of Review, correct?
A. I don't remember that. It certainly may
be right. I don't remember who the Chairman of the Board of Review was
at that time.
Q. Did you ever talk to Don Barnes about
A. I don't remember doing so, sir.
Q. Randall Wright was the head of the
Appeals Tribunal; do you recall?
A. No, I know him. I didn't remember that
he was head of the Appeals Tribunal.
Q. Did you ever talk to Randall Wright
about Gennifer Flowers?
A. No, sir, I don't believe I did.
Q. You mentioned Judy Gaddy because she's
mentioned in Deposition Exhibit 12, correct?
A. Excuse me. Yes, her name's up there in
Q. Okay, and you think she's the person to
whom you gave this letter from Gennifer Flowers after you received it?
A. I do. You asked me about this
handwriting on 11, I think it's probably her handwriting, but I can't
A. She handled these matters for me, all
these kinds of request.
Q. And her husband was name Bill Gaddy,
A. That's correct.
Q. He also held a state employment
A. Yes, he did.
Q. What was his position in 1991?
A. I don't know what his position was in
He held more than one position when I was governor. If you think you
know, and you tell me I'll be grateful to know. I don't remember what
his position was in 1991, because he had more that one job when I was
Q. Did you ever talk to Bill Gaddy about
Gennifer Flowers getting a job?
A. I don't believe I did, no sir.
Q. After she received the job, did you ever
talk about Gennifer Flowers with anyone who was associated with the
Board of Review Appeals Tribunal?
A. I do not remember doing so.
Q. Are you aware that a State Grievance
Review Committee investigated a complaint concerning the hiring of
A. I have, I have a memory that there was
some, that there was a complaint filed against her. I don't remember
that is was about her hiring. I remember there was a complaint filed
Q. Generally, outside of the context of
Gennifer Flower, what was a State Grievance Review Committee?
A. I believe it was a committee set up to
review the complaints of one state, of a state employee who believed
that he or she had been subject to unfair treatment of some kind, and
it was sort of the first resort for someone who felt that they had not
been miss – that they had not been treated properly in connection with
Q. In the case of Gennifer Flower, an
named Charlotte Perry filed a grievance with the Grievance Review
Committee; is that right?
A. I don't have a specific memory of it.
there was a grievance. I remember, I have a general memory that there
was a grievance.
Q. Do you recall that the committee found
the procedure used to hire Gennifer Flowers was, quote, "improper,"
MR. BENNETT: I'm sorry, was proper or
MR. FISHER: Improper.
A. No, I don't recall that.
Q. Do you recall that the Grievance Review
Committee found that Ms. Perry had been quote, "unjustly," close quote,
eliminated for consideration for the job that was awarded to Gennifer
A. No, I don't remember that.
Q. After the state grievance review
made its findings with regard to the procedure under which Gennifer
Flowers was hired, did you do anything in response to that finding?
A. I don't believe so.
Q. Do you remember talking to anyone about
A. I don't remember doing so. I don't – no.
sir, I don't remember. I can't deny that I did, I just – have no memory
of that at all.
Q. Did you take any action to try to
reverse the decision of the Grievance Review Committee?
A. Not that I remember. Did she have other
options? I don't remember what she did. I don't remember what the facts
were. I have no recollection of it at all.
Q. Did you ever travel outside of Little
Rock, Arkansas with Gennifer Flowers?
A. Not that I recall.
Q. Do you recall going to Los Angeles,
California with her?
A. No, sir. When was this? I don't recall.
MR. BENNETT: Don't assume that it happened.
A. I don't believe I ever took a trip
outside of Arkansas with Gennifer Flowers.
Q. Did you ever talk
to Dolly Kyle,
whose name is now Dolly Kyle Browning, about Gennifer Flowers?
A. Yes, I did.
Q. Did you tell Dolly Kyle that you had a
sexual relationship with Gennifer Flowers?
A. No, quite the reverse. I told her that I
did not have one. I
told her that – specifically what I said to Dolly Kyle, and I have, I
took notes on that, was that her story was not true, the story she had
told was not true.
Q. And when did that conversation with
Dolly Kyle take place?
A. It took place at my high school reunion,
which was sometime in the summer of 1994 or the late spring of 1994.
Q. I'm handing you what's been marked as
Deposition Exhibit 13.
Is this Exhibit a copy of notes that you made of something that
happened at that high school reunion?
A. It is.
Q. Toward the bottom of the second page, it
looks like the handwriting changes. Is that the handwriting of Marsha
A. It is.
Q. And then after the first three pages,
there's a typed transcription of the notes; is that right?
A. Yes, yes.
Q. Have you ever checked the transcription
to see if it's correct?
A. I read it over rather quickly. I think
it is generally
correct. I mean, if you have a specific question I'll double-check it
before I answer a specific question. I think is generally correct.
Q. How much time elapsed between the time
of the reunion and the time when you made these notes?
A. Oh, a few days. I did it as soon as I
got back to Washington,
shortly after I got back to Washington. I was in Arkansas that night,
that day obviously, and the next day, and then part of another day, and
so it was a few days later that I did that.
Q. Did you ask Marsha Scott to make some
notes as well?
A. No, I asked her, I said, I said, I asked
her to listen to the
conversation when it started, and she stood very close so she could
hear everything, and then as soon as the conversation was over, I asked
her if she had heard it, and I thanked her, and then I made these notes
and I asked her if, if they were consistent with my memory, and she
said yes, except I think that the, the conversation went on a little
longer then you said, which I think is reflected in her comment. Also
that's how this happened.
Q. Were the original notes made by Marsha
Scott on the same page
as your notes as is indicated by the second page of this exhibit?
A. I, I believe so, sir. I believe that's
Q. So you wrote your notes first and then
she made hers?
A. That's correct. I asked her to read it
and see if that was an
accurate and complete account of the conversation, and she said she
thought it was a very good account of the conversation, except she felt
that it had gone on a little longer than my notes indicated, and so she
indicated that in her comments.
Q. What was significant about this event
that made you want to write these notes about it when you got back to
A. Well, I think she was – first of all,
she was very upset.
Secondly, she was mad at me for not calling her back in 1992 when she
was the subject of a potential tabloid story, and she thought it
manifested a lack of trust in her. Thirdly, she was made about the
Gennifer Flowers story, and I told her it wasn't true, and she said
other people thought it was true, and Gennifer Flowers got a hundred
fifty thousand dollars, and she needed money too, now.
And then she told me about this book she was going
said if anybody ever asked her, she would say it was a fantasy, and I
pointed out on two or three occasions how we had been friends since she
was a young girl, and how I'd always tried to be her friend, and she
basically said she didn't want me to be her friend and she was mad at
me because I'd never been her lover, especially since she thoughts I
was no Gennifer Flowers' lover, and when I told her Gennifer Flowers'
story was bogus and that many, many problems with it had already been
proven – it's very hand to prove your innocence in a case like this,
but that we'd done it – you know, she just was very angry. That's
basically what these notes reflect. And I go through, I litanize here
what we said and how I tried to be a friend to her.
Q. Did she threaten to take some action
such that you thought you would need these notes to protect you?
A. No, she didn't threaten to take any
action but I knew she'd
been through a really tough time, and, and she said that she was
virtually desperate for money, her marriage had dissolved under very
difficult circumstances, and she had been a title lawyer making quite a
bit of money in Texas when the real estate market collapsed, and there
was a lot of lawyers lost their jobs that were doing that kind of work,
and I just thought for my protection when I saw the kind of look she
had in her eyes and the way she was behaving I should ask Marsha to
listen to it and then we should make notes after it was over. I wasn't
paranoid like this until things like this occurred.
Q. Where were the notes kept?
A. I kept them in a, in a briefcase that
was always either under
my desk in the White House or in my little private office. That's where
Q. Were they in a file folder?
A. They were. Nothing else, and they were
in a file folder.
Q. With anything else?
A. No nothing else was in there.
MR. BENNETT: Your Honor, may I ask how much
longer Counsel plans
to be? We had indicated a four o'clock meeting, I mean, there's a
little bit of flexibility there.
JUDGE WRIGHT: You may certainly ask. I'm
not, you know, I'm not making any ruling or saying anything until
you-all ask, you know, so –
MR. BENNETT: I'm not asking you to, Judge.
Do you have any sense –
MR. FISHER: Your Honor, it might be good if
you would give me a
couple of minutes, and we can probably make some decisions to cut out a
portion of this.
MR. BENNETT: Well, could we take a break
then, Your Honor, for five minutes?
JUDGE WRIGHT: Would a break be helpful to
MR. FISHER: I think it would.
JUDGE WRIGHT: All right, we'll take another
five minute break. That will be fine. We're in recess for five minutes.
JUDGE WRIGHT: Have you been able to make
some decisions, Mr. Fisher?
MR. FISHER: Yes, Your Honor, we can be done
in ten minutes.
JUDGE WRIGHT: You want to await Mr.
MR. BENNETT: I think we can proceed, Your
JUDGE WRIGHT: All right, let's proceed.
MR. FISHER: We're back on the record?
JUDGE WRIGHT: Yes, sir.
Q. Did you ever have sexual relations with
MR. BRISTOW: Your Honor, I want to object
to that on the basis
that there has not been proper predicate laid in that regard. The
questioning up to this point in time indicates that the only mention of
state employment came as testified to by the deponent. Your Honor has
probably had access to the testimony of Gennifer Flowers, who, putting
it like this, her allegations, even if believed, indicates that nothing
in the nature of a sexual relationship was occurring or occurred after
the time that she received any state employment, so the nexus that Your
Honor has been requiring in, or the predicate, is just simply not
there, and they've had ample opportunity to, you know, to develop that
nexus or that predicate today, but they have not done so, and putting
it like this, asking whether or not something occurred back in the
early seventies or early eighties within the state employment is, we're
talking about 1991, and Your Honor has previously made a ruling about
the scope, '86 forward, it's just one of those areas that they should
not be allowed to pursue.
JUDGE WRIGHT: All right and I'm sure Mr.
Bennett agrees with you; is that correct Mr.Bennett?
MR. BENNETT: I'll join in, Your Honor.
JUDGE WRIGHT: All right. The objection is
overruled. The Plaintiff's counsel may ask consistent with the Court's
prior rulings. Go ahead.
MR. BENNETT: You may ask the question.
A. The answer to your question, if sexual
relations are defined as –
MR. BENNETT: No, Mr. President
THE WITNESS: What?
MR. BENNETT: Go ahead.
A. That's right, that was upheld by the
court. The answer to
your question, if the definition is section one there in the first
piece of evidence you gave me, is yes.
Q. On how many occasions?
Q. In what year?
Q. Did you ever make sexual advances to
Gennifer Flowers after that occasion which did not culminate in sexual
Q. Did she make sexual advances to you
which did not culminate in sexual relations?
A. Yes. Once.
Q. When was that?
A. I don't remember. Sometime after she
came back, she invited me to come and see her.
Q. Did you ever visit her at her apartment?
A. I don't believe so. Let me say, I saw
her in the Quapaw
Tower. I've said this before, and let me explain how this happened that
I saw her. I never knew she was back in Arkansas. Contrary to her
protestations, I never saw her in Texas, I never knew what she was
doing there, I never had any contact with her except once in a while
she'd come back to Arkansas and call and say hello and how are you.
I was going into the Quapaw Tower one night to
see, I had three
very, very close friends, three of my closest friends lived there, and
I ran into Gennifer Flowers, and she told me she was back in town and
that she was singing, and her mother was ill, and she wanted to be near
her mother in southern Missouri, and I, I believe this was in the lobby
of the Quapaw tower, but it could have been on the floor where her
apartment was, and if so, I could have stuck my head in there for a
minute or two, but I don't believe so. I'm pretty sure it was in the
Q. Is it your testimony then that that's
the only occasion on which you ever saw Gennifer Flower at the Quapaw
A. Yes. Now I believe that I might have
heard her sing once
during the years she was back in Arkansas, and I don't remember whether
she was singing there at the place in the Quapaw Tower, or whether I
heard her sing somewhere else. I just had this vague memory that I also
heard her sing once, and it might have been there.
Q. But in an apartment –
A. That's correct.
Q. – or the hallway leading to the
A. That is my testimony.
Q. – there was only one time you saw her?
A. That's correct.
Q. Move up in time
to when you learned
that some of the state
troopers who had been your security detail were making public
statements and talking to reporters. Did you ask Betsey Wright to go
talk to Danny Ferguson?
A. After Danny Ferguson reached out to me,
I might have done
that. I can't remember, because Betsey Wright knew the most about all
these issues, so I might well have done that. I don't remember exactly
what I asked her to do, but I might, I might well have contacted her
and asked her for advice on this since she had dealt with it in the
Q. Did you talk to her about having Danny
Ferguson appear in a news conference?
A. Perhaps I did. I don't recall.
Q. Did she –
A. There's some reference to that in the
notes that I, that you and I went over a few moments ago.
Q. Did she ever report back to you that she
had asked Danny Ferguson to appear in a news conference?
A. I don't remember. I discussed that
directly with Danny
Ferguson. I mean I discussed his, possibility of his making a public
Q. And did he agree to do so?
Q. Did he say why he would not do so?
A. Yes. He said, he said, "I feel
threatened, they say they will
get me if I say anything about this, and I'm just going to try to do
what Ronnie Anderson says and keep my mouth shut."
From that I infer that he had gone along in hopes
the money and then thought better of it and didn't want to be
embarrassed for the contradictory statement.
Q. While you were governor was there ever a
time when you would
leave the governor's mansion by yourself in a car or truck owned by one
of the state troopers?
A. I don't believe I ever did that.
Q. Do you recall a time when the security
guards there at the
governor's mansion changed their procedure for keeping logs of who had
come to the governor's mansion?
Q. That was very awkwardly worded, I
apologize. For a time there
was a log made of every person who came to the governor's mansion while
you were governor, right?
A. I, I don't know.
Q. Okay. Do you recall any discussion about
changing the procedure for keeping track of who comes to the governor's
A. I don't remember. I don't remember how
they kept records, who kept them, who, where they were – what the
Q. Do you recall any discussion of the, of
the change in the
practice of keeping all of the old phone logs that would reflect all
the calls made to the governor's mansion?
A. No, I don't. Now, could you ask that
Q. Do you recall any discussions, sir,
about changing the
procedure with regard to keeping phone logs of phone calls made to the
A. Phone calls made to the governor's
mansion. No, sir, I don't, I don't recall that.
Q. Do you recall travelling to Denver,
Colorado, with L.D. Brown and staying in the Brown Palace Hotel?
A. When was that?
Q. I don't know.
A. I have no idea if L.D. Brown was there.
I went to the Brown
Palace in 1980 to the Governor's Conference. The Governor's Conference
was held in Denver in 1980, and I remember being in the Brown Palace.
I'm sorry, I don't remember if I actually stayed there, if that's where
we stayed, I remember being there.
Q. Do you recall a trip to Portland, Maine,
with L.D. Brown?
A. I have no idea if L.D. Brown was there.
I was in Portland,
Maine, at the Governor's Conference in 1993 with my family, 19 – excuse
me, 1983. 1983.
Q. All right. There was a state trooper
with you, you just don't remember if it was L.D. Brown?
A. There probably were two. Normally,
normally I think two of
them went when I went to the Governor's Conference because there was
more work to do.
Q. Let's go back to the trip to Denver. Do
you recall during
that trip ever asking a state trooper to get the name and phone number
of a woman that you had seen?
A. Absolutely not.
Q. And same questions for the trip to
Portland, Maine, did you
ever ask a trooper to get the name and phone number of a woman that you
A. Absolutely I did not. Are you asking me
about L.D. Brown?
Q. Any trooper that accompanied you on that
trip to Portland, Maine.
A. Well, I did not do that, but L.D. Brown
did a lot of things,
it was well known, for himself, that he tried to lay off on to other
people, and I think his reputation is legendary enough that if you talk
to enough people involved in security they will tell you the same
Q. Do you know a woman named Cathy Ford?
A. Cathy Ford? There's a woman named Cathy
Ford who use to work for me.
Q. Did you ever ask her to talk to L.D.
Brown about keeping quiet concerning anything?
A. Not, not that I remember. I might have
asked somebody to ask L.D. Brown not to lie, but that would be a
Q. Did you ever have a conversation with
Dolly Kyle in which she
told you that she had come to the conclusion that she had a sexual
A. I do not believe so.
MR. FISHER: At this time,Your Honor, we
have no further questions.
JUDGE WRIGHT: Very well. Mr. Bristow?
MR. BENNETT: Could I see Mr. Bristow? Could
we take a minute, please?
JUDGE WRIGHT: You may.
MR. BRISTOW: Can we go off the record,
JUDGE WRIGHT: You can go off the record.
We'll take a brief recess. I think they're probably trying to cut the
Examination by Bill Bristow
Q. Mr. President, I am Bill
Bristow, and I
represent Danny Ferguson. I have a very brief number of questions for
you. As you know, the Plaintiff in this case has alleged that Danny
Ferguson and yourself entered into some form of an agreement or a
conspiracy to violate the rights of Paula Corbin Jones, and I want to
ask you to tell me, and the jury may get to hear this testimony, I want
you to tell us in terms, very clear terms, whether you and Mr. Ferguson
ever had some sort of an agreement or a conspiracy with regard to
violating the rights of Paula, Paula Corbin Jones.
A. No, sir, we did not.
Q. You have, you have indicated that you
have any recollection of meeting Mrs. Jones on this particular day, but
if you and Mr. Ferguson had arrived at some sort of conversation, some
sort of an agreement, some sort of a conspiracy, that would be
something you would remember, would it not, Mr. President?
A. Well, of course, but I didn't do that.
Q. And the point is, are you able to
categorically say that there was never any sort of agreement, never any
sort of conspiracy between yourself and Mr. Ferguson with regard to his
bringing Paula Jones to meet you or anything like that?
Q. All right. Now, Mr. President, when you
were governor of Arkansas, or even as attorney general, before you ran
for president, from time to time when you would be at official
functions, did you not find that people wanted to meet you and to be
able to be in your presence just, just to meet you? Did you not find
that to be common?
A. Yes sir, it was quite common.
Q. And as someone who was in the political
arena, actually the fact that people had feelings about you where they
would express the right of express the desire to meet you as a person
who was holding elective office, was that something you would consider
a good thing, that people would want to, to meet you?
A. Yes, sir, I did.
Q. And insofar as those requests would be
made, if you were in a position to allow someone to talk to you to
fulfill that request to meet you, did you try to do that from time to
A. I did that many times.
Q. And not even talking about the number of
people that you would have met since you began running for president,
but in your time as governor of Arkansas up through May of 1991, would
you imagine that there are literally hundreds and thousands of people
that you met from time to time who they may remember a meeting with
you, but you were, as the governor, were just simply being nice and
talking to people that had expressed a desire to meet you?
A. I would think there were several people
would, many people who would remember that they met me, shook my hand,
talked to me for a few minutes, that I might not remember, yes.
Q. And a member of your security detail, a
state trooper such as Mr. Ferguson, if a constituent of the state of
Arkansas, if a, a taxpayer, a voter of the state of Arkansas expressed
a desire to meet you, to make your acquaintance, would you not want Mr.
Ferguson to bring that to your attention, or any other member of your
security detail, if a prospective voter or a taxpayer had made such a
A. Yes, or a child, or anybody from the
state, or course I would.
MR. BRISTOW: Mr. President, that's all the
questions I have, thank you.
Cross-examination by Robert Bennett
Q. Mr. President, all right, you recall
earlier today that Mr. Fisher asked you several questions about Miss
A. Yes, sir, I do.
Q. And do you recall there was a discussion
about an affidavit of Miss Lewinsky, generally?
A. Yes, sir, I remember that.
Q. I'm going to read you certain portions
Miss Lewinsky's affidavit, Miss Lewinsky, also known as Jane Doe Number
6, says as follows: "In the course of my employment at the White House
I met President Clinton several times. I also saw the president at a
number of social functions held at the White House. When I worked as an
intern, he appeared at occasional functions attended by me and several
other interns. The correspondence I drafted while I worked at the
Office of Legislative Affairs was seen and edited by supervisors who
either had the president's signature affixed by mechanism or, I
believe, had the president sign the correspondence itself."
Is that an accurate and true statement, to the
best of your knowledge?
Q. It's an accurate and true statement
how the correspondence is handled in the Congressional Affairs
Division. I can't – I know of no reason why the rest of it's not
MR. FISHER: Your Honor, excuse me –
A. I don't know directly whether it's all
MR. FISHER: Just wanted to make clear, Your
Honor, that since this is a discovery deposition, that hearsay
objections are reserved and need not be made.
MR. BENNETT: I agree with that.
JUDGE WRIGHT: Absolutely, and that's the
reason I was trying to say when I came back from lunch that even though
I'm permitting Mr. Bennett to do this, if this is ever used at trail,
the Rules of Evidence would apply, and as stated before, the Rules of
Evidence don't apply in this discovery deposition. Go ahead.