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 TIME on politics Congressional Quarterly CNN/AllPolitics CNN/AllPolitics - Storypage, with TIME and Congressional Quarterly

House managers' memo in support of witnesses

January 26, 1999
Web posted at: 1:12 p.m. EDT (1312 GMT)

IN THE SENATE OF THE UNITED STATES

Sitting as a Court of Impeachment





In Re

Impeachment of

President William Jefferson Clinton



MEMORANDUM IN SUPPORT OF

MOTION OF THE UNITED STATES HOUSE OF REPRESENTATIVES

FOR THE APPEARANCE OF WITNESSES AT A DEPOSITION

AND TO ADMIT EVIDENCE NOT IN THE RECORD



Now comes the United States House of Representatives, by and through its duly authorized Managers, and respectfully submits to the United States Senate its Memorandum in support of its motion for the appearance of witnesses at a deposition and to admit evidence not in the record in connection with the Impeachment Trial of William Jefferson Clinton, President of the United States.

The House requests that subpoenas be authorized and issued by the Senate to the witnesses enumerated in the House's Motion because those witnesses possess information which contradicts the inferences argued by the President from the record during this Impeachment Trial. Individually and collectively, the witnesses will provide information concerning the specific instances in which the President lied under oath, encouraged others to lie under oath, or otherwise obstructed justice as part of a premeditated and calculated scheme to prevent a fellow American citizen from vindicating her rights in a court of law.

Some of the witnesses that the House seeks to depose are witnesses who are identified with the President. The House believes that even though these witnesses are identified with the President and therefore are subject to the principle set forth in Federal Rule of Evidence 611 governing witnesses identified with an adverse party and Rule 607 permitting any party to attack the credibility of a witness regardless of who calls the witness, these witnesses will, nevertheless, provide evidence and testimony favorable to the case-in-chief and the inferences urged by the House.

Because President Clinton continues to deny that he perjured himself or obstructed justice through his testimony or other actions, and because the President has proposed that the Senate draw inferences from the factual record which support his denials of the charges brought in the Articles of Impeachment being exhibited by the House, obtaining testimony from the witnesses named in the motion, and additionally from the President himself, will greatly assist the Senate in resolving credibility issues, and in its obligation to determine the proper inferences to be drawn from the facts. In turn, these witnesses will enable the Senate to decide whether the President has fulfilled his constitutional responsibility to take care that the laws be faithfully executed, to honor his oath before the grand jury and, consequently, whether he should be removed from office.

In sum, the testimony of the witnesses will lend greater coherence and understanding to the narrative of events leading to Impeachment, allowing this body to determine the truth. The testimony will demonstrate the gravamen of the House position: namely, that the chief law enforcement officer of the country committed perjury and obstructed justice in a calculated and premeditated manner warranting removal.

Monica Lewinsky

The House respectfully moves that the United States Senate authorize and issue a subpoena for the appearance at a deposition of Monica S. Lewinsky, to give testimony under oath.

Through the testimony of Monica Lewinsky, the House expects to prove, among other things, that:

  • The Senate may accept as true the testimony she gave in a deposition before the Office of Independent Counsel on August 26, 1998, and before the grand jury on August 6 and 20, 1998.
  • The Senate may accept as true the unsworn proffer she submitted to the Office of Independent Counsel on February 1, 1998.
  • The Senate may accept as true the notes of interviews and other unsworn statements taken in connection with the investigation of the Office of Independent Counsel.
  • On November 5, 1997, she met with Vernon Jordan to seek his help regarding employment opportunities in New York.
  • She did not receive much help from Mr. Jordan for over a month in her search for a job in New York.
  • On December 6, 1997, she called the President and he invited her to the White House.
  • That same day, she went to the White House pursuant to the President's invitation, and they discussed her job search. She complained that Mr. Jordan did not seem to be helping her much in her job search. The President told her that he would talk to Mr. Jordan and that he would "get on it."
  • On December 11, 1997, she again met with Mr. Jordan about her job search. He told her to send letters to three of his contacts in New York and to keep him informed of her progress.
  • On December 17, 1997, she was informed by President Clinton that her name had been placed on the witness list in the Jones case on December 5.
  • During that conversation on December 17, the President instructed her to contact Betty Currie if she were subpoenaed in the Jones case, and to invoke previously developed cover stories if questioned about her contact with the President (i.e., that she only had contact with the President when she went to the Oval Office Complex to visit Ms. Currie, or to deliver papers to him).
  • During that same conversation on December 17, the President suggested that she could avoid testifying by executing an affidavit in the Jones case.
  • She realized that in order to both invoke previously developed cover stories and file an affidavit in the Jones case to avoid having to be deposed, such an affidavit would have to contain false information regarding their relationship.
  • On December 18, 1997,she interviewed with two companies in New York City which were recommended by Mr. Jordan, including MacAndrews & Forbes, the parent company of Revlon.
  • On December 19, 1997, she was served with a subpoena to testify and to produce documents and gifts in the Jones case.
  • On that same day, she contacted Vernon Jordan about the subpoena. He put her in touch with Francis Carter, a Washington, DC, attorney. She retained the services of Mr. Carter.
  • On December 22, 1997, she met with Mr. Jordan. They discussed the subpoena she received in the Jones case and her concerns about the fact that she had engaged in telephone conversations of a sexual nature with the President and had received gifts from him.
  • She met with President Clinton in the Oval Office at about 8:30 a.m. on December 28, 1997, their first meeting alone since December 6, 1997. He gave her certain belated Christmas gifts. She mentioned her concern to the President that the subpoena she received required her to turn over gifts which she had received from the President. She stated at one point that, "[M]aybe I should put the gifts away outside my house somewhere or give them to someone, maybe Betty [Currie]." The President responded, "I don't know," or "Let me think about that."
  • After she left the White House that morning, Ms. Currie called her and stated "I understand you have something to give me, or, "The President said you have something to give me."
  • Understanding that the President had decided that she should give the gifts to Ms. Currie after "thinking about it," she placed many, but not all, of her gifts from the President in a box.
  • She talked with Ms. Currie several times that day (December 28, 1997). During one of those conversations, she learned that Ms. Currie's mother was in the hospital, and that Ms. Currie would stop by her apartment to pick up the gifts before going to the hospital.
  • She went to the grocery store in the basement of her apartment building to pick up a plant and a balloon for Ms. Currie to take to her mother.
  • After Ms. Currie left the White House, Ms. Currie called her from Ms. Currie's cell phone. She knew this because her "caller ID" indicated that a cell phone was being used.
  • Ms. Currie arrived at her apartment at the Watergate. She met Ms. Currie at the door and entered Ms. Currie's car. She gave Ms. Currie the box of gifts and the plant and balloon for Ms. Currie's mother.
  • On December 31, 1997,fearing that Linda Tripp, a former confidante, might be cooperating with the Jones attorneys, she met with Vernon Jordan and discussed the matter. She told Mr. Jordan that Linda Tripp may have learned of her relationship with the President through copies of notes at home which she had sent to the President, and Mr. Jordan advised her to "[g]o home and make sure they're not there." She understood his comments to mean that she should destroy the notes, which were the subject of production in the subpoena she received on December 19, 1998. She did so.
  • On January 5, 1998, she met with Francis Carter to discuss her proposed affidavit in the Jones case. Mr. Carter posed questions to her concerning her affidavit and deposition and told her he would have a draft for her to review the next day.
  • That same day, January 5, she called President Clinton to discuss the answers to questions posed by Mr. Carter and to ask if the President would like to review her affidavit before it was signed. He declined, saying he had already seen about 15 others. She understood that to mean that he had seen 15 other affidavits, rather than 15 prior drafts of her affidavit (which did not exist).
  • On January 6, 1998, she picked up the draft affidavit prepared by Mr. Carter.
  • That same day, she called Mr. Jordan to discuss the draft affidavit. She did so because she thought that obtaining Mr. Jordan's approval would be akin to having the affidavit "blessed" by the President. Changes to Mr. Carter's draft were discussed with Mr. Jordan who agreed to them. In particular, Mr. Jordan agreed to the removal of a statement implying she had been alone with the President. The signed affidavit declared that Ms. Lewinsky had "...never had a sexual relationship with the President."
  • On January 7, 1998, she signed the affidavit, knowing that parts of it were false.
  • On January 8, 1998, she interviewed again with a representative of MacAndrews & Forbes in New York City. She contacted Vernon Jordan thereafter and informed him that the interview went "very poorly."
  • Mr. Jordan called her later that evening and told her "not to worry."
  • She interviewed with Revlon, a subsidiary of MacAndrews & Forbes, on the morning of January 9, 1998, and was informally offered, and she informally accepted, a job offer. She contacted Mr. Jordan with the news.
  • On January 21, 1998, the story of her relationship with the President was made public.
  • She reached an Immunity/Cooperation Agreement with the OIC on July 28, 1998.

Ms. Lewinsky's contact with President Clinton is highly relevant within the context of the President's obstruction of the Jones lawsuit. Once she appeared on the witness list in that case, President Clinton, directly and through his subordinates and agents, sought her help to conceal the nature of their relationship by illegal means. The President meant to garner her cooperation by acting quickly on her request for help in obtaining a job in New York. When the false affidavit he encouraged Ms. Lewinsky to file did not succeed in precluding questions related to Ms. Lewinsky in the Jones case, the President obstructed the proceedings by lying in his civil deposition in using the cover story he had urged Ms. Lewinsky to use if she were called to testify personally. Additionally, he injected Ms. Currie into the proceeding by identifying her as the person with knowledge, even for matters about which he, not she, had personal knowledge. He then proceeded to obstruct justice by coaching others, including Ms. Currie, to corroborate his perjured testimony. He then perjured himself before the grand jury.

Ms. Lewinsky's testimony is relevant to resolve the discrepancies in the record and the different inferences drawn by the House and the President. Her live testimony will rebut the following inferences drawn by White House counsel on key issues, among others:

    • That President Clinton did not encourage Ms. Lewinsky to file a false affidavit.
    • That President Clinton did not lie about not having a "sexual affair," "sexual relations," or a "sexual relationship" with Ms. Lewinsky.

C. That President Clinton did not encourage Ms. Lewinsky to conceal any gifts he had given her.

    • That President Clinton did not instruct or encourage Ms. Currie to pick up the gifts he had given Ms. Lewinsky from her personal residence.
    • That President Clinton did not have an "understanding" with Ms. Lewinsky that the two would lie under oath. That President Clinton did not encourage Ms. Lewinsky to file a false affidavit.

In sum, given the almost complete disconnect between Ms. Lewinsky's testimony, offered under grant of immunity that would be lost if she committed perjury, and President Clinton's, and the inferences drawn by the parties from the factual record, Ms. Lewinsky's appearance would resolve the proper inferences surrounding the facts, assisting the Senators in fulfilling their constitutional duty to find the truth.

WHEREFORE, the United States House of Representatives respectfully requests that this Honorable Body issue a Subpoena for the appearance of Monica Lewinsky at a deposition and provide for the testimony of the witness as requested.



Vernon Jordan

The House respectfully moves that the United States Senate authorize and issue a subpoena for the appearance at a deposition of Vernon Jordan, to give testimony under oath.

Through the testimony of Vernon Jordan, the House expects to prove, among other things, that:

  • He is a close friend and advisor of President Clinton, and a partner in the Washington law firm Akin, Gump, Strauss, Hauer & Feld.
  • On December 19, 1997, Ms. Lewinsky was served with a subpoena in the Jones case. She met Mr. Jordan and they rode together to the office of her attorney, Mr. Frank Carter. En route to see Mr. Carter about the submission of an affidavit, she discussed the subpoena, the Jones case, and her ongoing job search with him.
  • On December 22, 1997, three days after Ms. Lewinsky had been served a subpoena to testify in the Jones case, she contacted him to discuss the subpoena. He, in turn, put her in touch with Francis Carter, a private attorney. Mr. Carter prepared an affidavit in which Ms. Lewinsky, among other things, denied having a sexual relationship with President Clinton.
  • Although Ms. Lewinsky claimed that he helped her to change the document on January 6 before she signed it, he recalled he only directed her to consult her attorney if she had concerns about its content.
  • The job search for Ms. Lewinsky continued into the New Year. On January 6, 1998, Ms. Lewinsky interviewed with MacAndrews & Forbes, the parent company of Revlon, in New York City. Sensing that her interview went "very poorly," Ms. Lewinsky spoke to him and told him that the interview went very poorly.
  • On or about January 7, the day Ms. Lewinsky signed the false affidavit, President Clinton and he talked about Ms. Lewinsky's job search. In response to his comments that he was still working his contacts, the President responded, "Good."
  • On January 8, 1998, Mr. Jordan then contacted Mr. Perelman, the Chairman and CEO of MacAndrews and Forbes, to "make things happen...if they could happen."
  • Ms. Lewinsky was granted a second interview at MacAndrews and Forbes on January 9, after which she accepted an informal offer to work for Revlon.
  • On January 9, Mr. Jordan notifies Betty Currie that the mission had been accomplished; a job in New York had been procured for Ms. Lewinsky. He asked that she tell this news to the President.
  • Later on January 9, Mr. Jordan himself notified the President of Ms. Lewinsky's New York job offer and the President replied, "Thank you very much."

Mr. Jordan's live testimony will help to prove that President Clinton obstructed justice by encouraging Ms. Lewinsky to file a false affidavit and by helping her to obtain employment in the private sector at a time when she was a witness in the Jones case.

According to Ms. Lewinsky, the President informed her on December 17, 1997, that her name had been placed on a witness list for the Jones case (he had been notified through his attorney). (Lewinsky GJT 8/6/98, pp. 121-23, H. Doc. 105-311, pp. 841-43)To avoid having to testify, Ms. Lewinsky claimed the President suggested she execute an affidavit (Id, p. 123, H. Doc. 105-311, p. 843)

In other words, Mr. Jordan's live testimony can effectively demonstrate that President Clinton knew the contents of her affidavit at least 10 days prior to his own deposition. This action was consistent with President Clinton's initial desire that Ms. Lewinsky file an affidavit in lieu of testifying, and, as Ms. Lewinsky's grand jury testimony reveals, that she coordinate her story with the President's by denying the existence of a sexual relationship. (See Lewinsky GJT 8/6/98, p.234, H. Doc. 105-311, p. 954). Ms. Lewinsky's false affidavit, in turn, permitted the President to lie in response to document requests answered two days before he testified and permitted the President to lie in his deposition without contradiction. President Clinton's manipulation of these events constitutes evidence to support both the perjury and obstruction Articles.

Mr. Jordan can also speak to another charge which helps to sustain the obstruction Article and which President Clinton's counsel disputes vigorously: the effort by the President to secure employment for Ms. Lewinsky in order to garner her cooperation in his efforts to suborn perjury and obstruct justice.

Although Ms. Lewinsky began her job search before December 7, 1997 - the day after President Clinton discovered her name had been placed on the Jones witness list - no effort to obtain private employment in New York had been made in earnest prior to the appearance of her name. His efforts to assist her intensified, however, after the appearance of her name on the Jones witness list.

The following time line is illustrative of how Ms. Lewinsky's appearance on a witness list in the Jones case drove White House efforts to obtain a job for Ms. Lewinsky. On December 11, 1997, the presiding Judge in the Jones case ordered President Clinton to answer certain interrogatories, including whether he had engaged in sexual relations with government employees. Five days later (December 16), his attorneys received a request for production of documents that mentioned Ms. Lewinsky by name. These events triggered the intensified efforts to accommodate Ms. Lewinsky in her job search, consistent with Mr. Jordan's anticipated testimony as set forth in points seven through 12, supra.

Mr. Jordan was the primary catalyst in obtaining Ms. Lewinsky's job in New York. It is expected that Mr. Jordan's testimony will lead to the reasonable and logical inference from the evidence that the timing and level of effort devoted to obtaining a desired job for Ms. Lewinsky - especially by powerful men such as Mr. Jordan - was intended to ensure Ms. Lewinsky's gratitude and thereby discourage her from providing any damaging information about her relationship with the President to the Jones attorneys. The live testimony of Mr. Jordan on this issue will therefore help the Senate as it considers the allegations against the President.

WHEREFORE, the United States House of Representatives respectfully requests that this Honorable Body issue a Subpoena for the appearance of Vernon Jordan at a deposition and provide for the testimony of the witness as requested.



Sidney Blumenthal

The House respectfully moves that the United States Senate authorize and issue a subpoena for the appearance at a deposition of Sidney Blumenthal, to give testimony under oath.

Through the testimony of Sidney Blumenthal, the House expects to prove, among other things, that:

  • He is an Assistant to the President.
  • On January 21, 1998, President Clinton told him in the wake of the Washington Post story that he had rebuffed Ms. Lewinsky and that she came at the President and made a sexual demand on the President. The President also stated to him that the President hadn't done anything wrong.
  • During this same conversation, President Clinton depicted Ms. Lewinsky as a "stalker." The President stated that Ms. Lewinsky "threatened" the President, and that she said she would tell people that "they'd had an affair."
  • The President also stated that Ms. Lewinsky was known as a stalker among her peers, that she hated it, and that if she had an affair or said that she had an affair with the President, then she wouldn't be the stalker anymore.

Mr. Blumenthal's live testimony on these points would provide evidence that the President lied to his aides knowing that they may be called to testify before the grand jury. In addition, his testimony proves that President Clinton embellished his previous explanations to the public, his aides, and authorities, by depicting Ms. Lewinsky as a "stalker," thereby attacking her character in an effort to exculpate himself. This evidence is an important component of the obstruction charges set forth in Article II.

WHEREFORE, the United States House of Representatives respectfully requests that this Honorable Body issue a Subpoena for the appearance of Sidney Blumenthal at a deposition and provide for the testimony of the witness as requested.



Sworn Declaration of Barry Ward



The House respectfully moves that the United States Senate admit into evidence the sworn declaration of Barry Ward, Law Clerk to the Honorable Susan Webber Wright, United States District Judge for the Eastern District of Arkansas.

The sworn declaration of Mr. Ward will prove that:

  • Barry Ward is a law clerk to United States District Judge Susan Webber Wright of the Eastern District of Arkansas. He assisted in the adjudication of Jones v. Clinton, which was filed in the Eastern District of Arkansas in 1994.
  • One of the disputed issues during the Jones litigation governed the extent to which President Clinton would be required to disclose information about his alleged advances toward or relationships with other women who were either State or Federal employees. The Judge ruled that the request was relevant for purposes of pretrial discovery.
  • Subsequent to this ruling, the President was deposed on January 17, 1998. He was present at the deposition. At one point in the questioning, the President's attorney, Robert Bennett, urged the Judge to preclude inquiries pertaining to alleged "sexual relations" between Monica Lewinsky, a former White House intern, and President Clinton. The basis for Mr. Bennett's argument was that Ms. Lewinsky had executed an affidavit "saying that there is absolutely no sex of any kind of any manner, shape or form, with President Clinton."
  • Mr. Bennett further represented that President Clinton was "... fully aware of Ms. Lewinsky's affidavit, so I have not told him a single thing he doesn't know ...."
  • President Clinton did not contradict Mr. Bennett's assertion.
  • The questioning continued after the presiding Judge rejected Mr. Bennett's argument.
  • Mr. Bennett later read a portion of the affidavit to President Clinton in which Ms. Lewinsky denied having a "sexual relationship" with him.
  • Mr. Bennett then asked President Clinton whether the statement was true and accurate, to which he replied, "That is absolutely true."
  • On July 28, 1998, the OIC and Ms. Lewinsky reached an Immunity/Cooperation Agreement. On August 6, she admitted before the grand jury that her affidavit was false as to the nature of her relationship with President Clinton.
  • When confronted with Ms. Lewinsky's admission during his grand jury appearance on August 17, President Clinton did not repudiate his January 17 testimony regarding the veracity of the Lewinsky affidavit.
  • Among other justifications, President Clinton stated that he did not correct Mr. Bennett's characterization of the affidavit as true and accurate because he did not pay "any attention" to the colloquy between Mr. Bennett and the presiding Judge.
  • In contrast, a videotape of President Clinton during the January 17 deposition clearly shows him looking directly at Mr. Bennett while he told the presiding Judge that there was "absolutely no sex of any kind in any manner, shape or form, with President Clinton."
  • From his seat at the conference table next to the Judge, he saw President Clinton listening attentively to Mr. Bennett's remarks ("absolutely no sex of any kind ...," etc.) while the exchange between Mr. Bennett and the Judge occurred.

Mr. Ward's declaration would lend even greater credence to the argument that President Clinton lied on this point during his grand jury testimony and obstructed justice by allowing his attorney to utilize a false affidavit in order to cut off a legitimate line of questioning. Mr. Ward's declaration proves that Mr. Ward saw President Clinton listening attentively while the exchange between Mr. Bennett and the presiding Judge occurred. Such testimony would offer greater support for the obstruction charge in Article II.



Sworn Declaration of T. Wesley Holmes and Attachments

The House respectfully moves that the United States Senate admit into evidence the sworn declaration of T. Wesley Holmes, one of the counsels for Paula C. Jones in the case of Jones v. Clinton.

Attached to the sworn declaration of T. Wesley Holmes is a photocopy of a subpoena issued to Betty Currie on January 22, 1998, and served on her on January 27, 1998. Also attached is a supplemental witness list filed in the case of Jones v. Clinton, containing the name of Betty Currie. His declaration and the photocopy of the subpoena and supplemental witness list will prove that:

  • T. Wesley Holmes was retained as counsel for Paula C. Jones in her suit against William Jefferson Clinton in the case of Jones v. Clinton.
  • During his January 17, 1998, deposition in the case of Jones

v. Clinton, President Clinton made a number of references to Ms. Currie, his Personal Secretary. In effect, the President was suggesting that Ms. Currie, in certain instances, could corroborate his testimony. (OIC Referral, H. Doc. 105-310, nn. 386-89, p. 190)

  • It therefore became clear to Mr. Holmes that Ms. Currie was an important potential witness, and that she should be called to testify in the case.

The resulting subpoena for Ms. Currie, issued on January 22, and the supplemental witness list, become highly relevant in light of this factual background. Counsel for the President has repeatedly argued that Ms. Currie was not a potential witness in the Jones case and therefore that the President's January 18, 1998 statements to her were not intended to influence her anticipated testimony.

The subpoena and supplemental witness list undermine the President's claim and establish the House's position. That is, given the President's numerous references to Ms. Currie in his testimony, he knew that the Jones attorneys would want to depose her. She was, in fat, subpoenaed, thereby demonstrating that President Clinton's attempts to coach her to be a witness who would corroborate the President's lies

WHEREFORE, the United States House of Representatives respectfully requests that this Honorable Body admit into evidence the sworn declaration of T. Wesley Holmes, and the attachments thereto.



Telephone Records Which Document Certain Conversations Between

Monica S. Lewinsky and William Jefferson Clinton



The House respectfully moves that the United States Senate admit into evidence telephone records which document certain conversations between Monica S. Lewinsky and William Jefferson Clinton.

The telephone records will prove that:

  • On December 5, 1997, the attorneys for Paula C. Jones faxed a witness list in the case of Jones v. Clinton to President Clinton's attorney.
  • After seeing President Clinton at a Christmas reception on December 5, 1997, Ms. Lewinsky composed a letter to him in which she expressed her disappointment that he was distancing himself from her.
  • The next day, December 6, she went to the White House to deliver the letter and some gifts. Initially, Ms. Lewinsky planned to leave the items with Ms. Currie, who had said earlier that the President was meeting with his lawyers and could not see her.
  • Because Ms. Currie did not know that Ms. Lewinsky was coming to the White House, Ms. Lewinsky sought to gain admittance to drop off the letter and gifts. Ms. Currie sent word that the President was with another guest, and that Ms. Lewinsky should wait for 40 minutes.
  • Ms. Lewinsky waited in a guard booth with uniformed Secret Service officers. One of them mentioned that Eleanor Mondale was in the White House. Ms. Lewinsky correctly deduced that President Clinton was visiting with Ms. Mondale and not his lawyers. Ms. Lewinsky became "livid," left, placed a telephone call to Betty Currie in which she berated her, and went home.
  • Later that same day, President Clinton called her. While portions of their exchange were testy, the President invited Ms. Lewinsky back to the White House. During their meeting, Ms. Lewinsky mentioned that Mr. Jordan had done nothing to help her with her job search. The President promised he would speak to Mr. Jordan. Ms. Lewinsky characterized the visit as "really nice" and "affectionate." (Id)
  • The next day, December 7, Mr. Jordan met with the President in the White House. (Id, p. 93)
  • On December 11 Ms. Lewinsky met with Mr. Jordan to discuss her job search. After the meeting Mr. Jordan placed phone calls on Ms. Lewinsky's behalf to corporate officials with Young & Rubicam, MacAndrews & Forbes, and American Express. (Id)

Taken as a whole, these events establish that once President Clinton knew that Ms. Lewinsky was a named witness in the Jones litigation, he and his subordinates and agents made a concerted effort to obtain a job for her in New York.

In this context the House believes the 56-minute telephone conversation on December 6 is relevant evidence.

WHEREFORE, the United States House of Representatives respectfully requests that this Honorable Body admit into evidence the telephone records which document certain conversations between

Monica S. Lewinsky and William Jefferson Clinton.





Petition for the Request of the Appearance of President Clinton

Additionally, the House petitions the Senate to request the appearance of William Jefferson Clinton, President of the United States, at a deposition, for the purpose of providing testimony related to the Impeachment Trial.

The President is the one person who possesses direct and personal knowledge of the course of all of the events which together constitute the charges of perjury and obstruction of justice being exhibited by the House. His credibility is critical in order for the Senate to resolve different inferences from the factual record in his favor. It is only appropriate that the President appear so that the Senate, sitting as a Court of Impeachment, may compare his responses and credibility against that of the other witnesses who have given testimony and who the House now seeks to depose.


Investigating the President

MORE STORIES:

Tuesday, January 26, 1999

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