This mirror provided courtesy of
DownCity. For the original, see
See also the President's "Preliminary Memorandum" and the President "Initial Response"
(originals at www.whitehouse.gov).
Note: Minor technical errors were found in the original conversion process
that impacted the document footnotes; the file below is the corrected version.
Note: The original version of the President's response, which was available from the Whitehouse web site on 11 September, was written before
the text of the Independent Counsel's Referral was available. It was replaced
with a new text entitled "Initial Response" on 12 September.
The content of the following materials are verbatim as forwarded by the Office of the Independent Counsel. The conversion to HTML has altered the pagination and format. The original Table of Contents is not provided.
Table of Contents
The First Family
Other White House Personnel
Department of Defense Employees
Monica Lewinsky's Friends/Family/Acquaintances
Monica Lewinsky's New York Employment Contacts
Lawyers and Judges
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
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
3. Phone Sex
(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
4. Physical Evidence
5. Testimony of Ms. Lewinsky's Friends, Family Members, and Counselors
II. There is substantial and credible information that President Clinton lied under oath to the grand jury about his sexual relationship with
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
IX. There is substantial and credible information that President Clinton endeavored to obstruct justice by attempting to influence the testimony
of Betty Currie.
1. Saturday, January 17, 1998, Deposition
B. The President's Grand Jury Testimony
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.
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.