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REFERRAL from INDEPENDENT COUNSEL KENNETH W. STARR in CONFORMITY with the REQUIRE- MENTS of TITLE 28, UNITED STATES CODE, SECTION 595(C)

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REFERRAL from INDEPENDENT COUNSEL KENNETH W. STARR in CONFORMITY with the REQUIRE- MENTS of TITLE 28, UNITED STATES CODE, SECTION 595(C) 105th Congress, 2d Session ± ± ± ± ± ± ± ± ± ± ± ± House Document 105±310 REFERRAL FROM INDEPENDENT COUNSEL KENNETH W. STARR IN CONFORMITY WITH THE REQUIRE- MENTS OF TITLE 28, UNITED STATES CODE, SECTION 595(c) COMMUNICATION FROM KENNETH W. STARR, INDEPENDENT COUNSEL TRANSMITTING A REFERRAL TO THE UNITED STATES HOUSE OF REPRESENTA- TIVES FILED IN CONFORMITY WITH THE REQUIREMENTS OF TITLE 28, UNITED STATES CODE, SECTION 595(c) SEPTEMBER 11, 1998.ÐReferred to the Committee on the Judiciary pursuant to H. Res. 525 and ordered to be printed REFERRAL FROM INDEPENDENT COUNSEL KENNETH W. STARR IN CONFORMITY WITH THE REQUIREMENTS OF TITLE 28, UNITED STATES CODE, SECTION 595(c) 1 105th Congress, 2d Session ± ± ± ± ± ± ± ± ± ± ± ± House Document 105±310 REFERRAL FROM INDEPENDENT COUNSEL KENNETH W. STARR IN CONFORMITY WITH THE REQUIRE- MENTS OF TITLE 28, UNITED STATES CODE, SECTION 595(c) COMMUNICATION FROM KENNETH W. STARR, INDEPENDENT COUNSEL TRANSMITTING A REFERRAL TO THE UNITED STATES HOUSE OF REPRESENTA- TIVES FILED IN CONFORMITY WITH THE REQUIREMENTS OF TITLE 28, UNITED STATES CODE, SECTION 595(c) SEPTEMBER 11, 1998.ÐReferred to the Committee on the Judiciary pursuant to H. Res. 525 and ordered to be printed U.S. GOVERNMENT PRINTING OFFICE 50±800 WASHINGTON : 1998 C O N T E N T S VOLUME I: REFERRAL Key Dates ................................................................................................................ V Table of Names ...................................................................................................... VI Introduction .......................................................................................................... 1 Narrative ................................................................................................................ 11 I. Nature of President Clinton's Relationship with Monica Lewinsky .......... 11 II. 1995: Initial Sexual Encounters ................................................................... 27 III. January±March 1996: Continued Sexual Encounters ................................ 34 IV. April 1996: Ms. Lewinsky's Transfer to the Pentagon ............................... 41 V. April±December 1996: No Private Meetings ............................................... 49 VI. Early 1997: Resumption of Sexual Encounters ........................................... 53 VII. May 1997: Termination of Sexual Relationship .......................................... 62 VIII. June±October 1997: Continuing Meetings and Calls .................................. 63 IX. October±November 1997: United Nations Job Offer ................................... 76 X. November 1997: Growing Frustration ......................................................... 83 XI. December 5±18, 1997: The Witness List and Job Search ........................... 88 XII. December 19, 1997ÐJanuary 4, 1998: The Subpoena ................................ 96 XIII. January 5±16, 1998: The Affidavit ............................................................... 106 XIV. January 17, 1998ÐPresent: The Deposition and Afterward ...................... 116 Acts That May Constitute Grounds for an Impeachment .......................... 129 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 .............................................. 131 II. There is substantial and credible information that President Clinton lied under oath to the grand jury about his sexual relationship with Monica Lewinsky ........................................................................................ 145 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 ............................... 151 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 160 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 .............................................. 165 VI. There is substantial and credible information that (i) President Clinton and Ms. Lewinsky had an understanding that they would lie under oath in the Jones case about their relationship; and (ii) President Clinton endeavored to obstruct justice by suggesting that Ms. Lewinsky file an affidavit so that she would not be deposed, she would not contradict his testimony, and he could attempt to avoid questions about Ms. Lewinsky at the deposition ..................................... 173 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 an adverse witness against him were she to tell the truth during the Jones case .............................................................................................................. 181 VIII. There is substantial and credible information that the President lied under oath in describing his conversations with Vernon Jordan about Ms. Lewinsky .............................................................................................. 186 (III) IV Page IX. There is substantial and credible information that President Clinton endeavored to obstruct justice by attempting to influence the testi- mony of Betty Currie ................................................................................. 190 X. There is substantial and credible information that President Clinton endeavored to obstruct justice during the federal grand jury investiga- tion. 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 ............................................................... 197 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 con- stitutional duty to faithfully execute the laws ......................................... 204 Conclusion .............................................................................................................. 211 VOLUME II: APPENDIX Statement of the OIC's Jurisdiction ....................................................................... Tab A Order Permitting Disclosure of Grand Jury Material........................................... Tab B Procedural Background and History of Jones v. Clinton...................................... Tab C Map of White House, West Wing............................................................................ Tab D Table of Monica Lewinsky White House Visits ..................................................... Tab E Table of Contacts between Monica Lewinsky and the President ......................... Tab F Tables of Phone Conversations ............................................................................... Tab G Litigation History .................................................................................................... Tab H Evidence Reference ................................................................................................... Tab I Legal Reference......................................................................................................... Tab J Monica Lewinsky Immunity Agreement ................................................................ Tab K VOLUME III: DOCUMENT SUPPLEMENT, PART A William J. Clinton Statements VOLUME IV: DOCUMENT SUPPLEMENT, PART B Monica S. Lewinsky Statements VOLUME V: DOCUMENT SUPPLEMENT, PART C Documents Cited in Referral: Tabs 1±46 VOLUME VI: DOCUMENT SUPPLEMENT, PART D Documents Cited in Referral: Tabs 47±83, Bates Numbers 812±968 VOLUME VII: DOCUMENT SUPPLEMENT, PART E Documents Cited in Referral: Bates Numbers 1000±V006 Key Dates November 1992................... William Jefferson Clinton elected President of the United States. May 1994 ............................ Paula Jones files lawsuit against President Clinton. July 1995 ............................ Monica S. Lewinsky begins White House internship. November 15, 1995 ............ President begins sexual relationship with Lewinsky. April 5, 1996 ....................... Lewinsky transferred from White House to Pentagon. November 1996 ................... President Clinton reelected. March 29, 1997 ................... Last intimate contact between President and Monica Lewinsky. December 5, 1997 ............... Lewinsky appears on Jones Witness List. December 19, 1997 ............. Lewinsky served with subpoena to appear at deposi- tion and produce gifts from President Clinton. December 24, 1998 ............. Lewinsky's last day of work at the Pentagon. December 28, 1997 ............. Lewinsky meets with the President and receives gifts; later gives box of gifts from the President to Betty Currie. January 7, 1998 ................. Lewinsky signs affidavit intended for filing in Jones case. January 13, 1998 ............... Lewinsky accepts job offer at Revlon in New York. January 16, 1998 ............... Special Division
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