This report, which contains explicit material, was
forwarded by the Office of the Independent Counsel, and is reprinted
verbatim.
Table of Contents
The Principals
The First Family
Presidential Aides/Advisors/Assistants
Other White House Personnel
Department of Defense Employees
Monica Lewinsky's Friends/Family/Acquaintances
Monica Lewinsky's New York Employment Contacts
Secret Service
Lawyers and Judges
Media
Foreign Dignitaries
Other
Factual Background
The Investigation
The Significance of the Evidence of Wrongdoing
The Scope of the Referral
The Contents of the Referral
I. Nature of President Clinton's Relationship
with Monica Lewinsky
II. 1995: Initial Sexual Encounters
III. January-March 1996: Continued Sexual
Encounters
IV. April 1996: Ms. Lewinsky's Transfer to
the Pentagon
V. April-December 1996: No Private Meetings
VI. Early 1997: Resumption of Sexual Encounters
VII. May 1997: Termination of Sexual Relationship
VIII. June-October 1997: Continuing Meetings
and Calls
IX. October-November 1997: United Nations'
Job Offer
X. November 1997: Growing Frustration
XI. December 5-18, 1997: The Witness List
and Job Search
XII. December 19, 1997 - January 4, 1998:
The Subpoena
XIII. January 5-January 16, 1998: The Affidavit
XIV. January 17, 1998-Present: The Deposition
and Afterward
There is Substantial and Credible Information
that President Clinton Committed Acts that May Constitute Grounds for
an Impeachment
Introduction
I. There is substantial and credible information
that President Clinton lied under oath as a defendant in Jones v.
Clinton regarding his sexual relationship with Monica Lewinsky.
A. Evidence that President Clinton
Lied Under Oath During the Civil Case
1. President Clinton's Statements
Under Oath About Monica Lewinsky
2. Monica Lewinsky's Testimony
(i) Wednesday, November 15, 1995
(ii) Friday, November 17, 1995
(iii) Sunday, December 31, 1995
(iv) Sunday, January 7, 1996
(v) Sunday, January 21, 1996
(vi) Sunday, February 4, 1996
(vii) Sunday, March 31, 1996
(viii) Sunday, April 7, 1996
(ix) Friday, February 28, 1997
(x) Saturday, March 29, 1997
(xi) Two Subsequent Meetings
3. Phone Sex
4. Physical Evidence
5. Testimony of Ms. Lewinsky's
Friends, Family Members, and Counselors
6. Summary
II. There is substantial and credible
information that President Clinton lied under oath to the grand
jury about his sexual relationship with Monica Lewinsky.
III. There is substantial and credible
information that President Clinton lied under oath during his civil
deposition when he stated that he could not recall being alone with
Monica Lewinsky and when he minimized the number of gifts they had
exchanged.
IV. There is substantial and credible
information that the President lied under oath during his civil
deposition concerning conversations he had with Monica Lewinsky
about her involvement in the Jones case.
V. There is substantial and credible
information that President Clinton endeavored to obstruct justice
by engaging in a pattern of activity to conceal evidence regarding
his relationship with Monica Lewinsky from the judicial process
in the Jones case. The pattern included:
VI. There is substantial and credible
information that
VII. There is substantial and credible
information that President Clinton endeavored to obstruct justice
by helping Ms. Lewinsky obtain a job in New York at a time when
she would have been a witness against him were she to tell the truth
during the Jones case.
VIII. There is substantial and credible
information that the President lied under oath in describing his
conversations with Vernon Jordan about Ms. Lewinsky.
IX. There is substantial and credible
information that President Clinton endeavored to obstruct justice
by attempting to influence the testimony of Betty Currie.
A. Evidence
1. Saturday, January 17, 1998, Deposition
2. Sunday, January 18, 1998, Meeting
with Ms. Currie
3. Conversation Between the President
and Ms. Currie on Tuesday, January 20, 1998, or Wednesday, January
21, 1998.
B. The President's Grand Jury Testimony
C. Summary
X. There is substantial and credible
information that President Clinton endeavored to obstruct justice
during the federal grand jury investigation. While refusing to testify
for seven months, he simultaneously lied to potential grand jury
witnesses knowing that they would relay the falsehoods to the grand
jury.
XI. There is substantial and credible
information that President Clinton's actions since January 17, 1998,
regarding his relationship with Monica Lewinsky have been inconsistent
with the President's constitutional duty to faithfully execute the
laws.
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