Complete Text of President Clinton's TestimonyComplete Text of President
Clinton's Testimony
Text of President Clinton's Aug. 17 grand jury testimony before Office of the
Independent Counsel prosecutors investigating the president's relationship with

former White House intern Monica Lewinsky. The following transcripts were
provided by the Federal Document Clearing House:
(UNKNOWN): Mr. President, would you raise your right hand, please? Do you
solemnly swear that the testimony you're about to give in this matter will be
the truth, the whole truth and nothing but the truth, so help you God?

CLINTON: I do.
QUESTION: Good afternoon, Mr. President.
CLINTON: Good afternoon.
QUESTION: Could you please state your full name for the record, sir?
CLINTON: William Jefferson Clinton.
QUESTION: My name is Sol Wisenberg. I'm a deputy independent counsel with the
Office of Independent Counsel. And with me today are some other attorneys from

the Office of Independent Counsel.
At the courthouse are the ladies and gentlemen of the grand jury prepared to
receive your testimony as you give it. Do you understand, sir?

CLINTON: Yes, I do.
QUESTION: This proceeding is subject to Rule 6(e) of the federal rules of
criminal procedure as modified by Judge Johnson's order.
You are appearing voluntarily today as part of an agreement worked out between

your attorney, the Office of the Independent Counsel, and with the approval of

Judge Johnson. Is that correct, sir?
CLINTON: That is correct.
(UNKNOWN): Mr. Wisenberg, excuse me. You referred to Judge Johnson's order. I'm

not familiar with that order. Have we been served that or not?
QUESTION: No. My understand is that that is an order that the judge is going to

sign today. She didn't have the name of Awaka (ph). A person -- basically, my
understanding is that it will cover all of the attorneys here today and the
technical people in the room. So that they would be authorized personally to be

permitted to hear grand jury testimony that they otherwise wouldn't be
authorized to hear.
(UNKNOWN): Thank you.
QUESTION: The grand jury, Mr. President, has been empaneled by a United States

District Court for the District of Columbia. Do you understand that, sir?
CLINTON: I do.
QUESTION: And among other things, it's currently investigating under the

Complete Text of President Clinton's Testimony Complete Text of President Clinton's Testimony Text
 before Office of the Independent Counsel prosecutors investigating the president's relationship
ollowing transcripts were provided by the Federal Document Clearing House:

(UNKNOWN): Mr. President, would you raise your right hand, please? Do you solemnly swear that the
e the truth, the whole truth and nothing but the truth, so help you God?

CLINTON: I do.

QUESTION: Good afternoon, Mr. President.

CLINTON: Good afternoon.

QUESTION: Could you please state your full name for the record, sir?

CLINTON: William Jefferson Clinton.

QUESTION: My name is Sol Wisenberg. I'm a deputy independent counsel with the Office of Independent
s from the Office of Independent Counsel.

At the courthouse are the ladies and gentlemen of the grand jury prepared to receive your testimony
[img: Order Monica's Story]
CLINTON: Yes, I do.

QUESTION: This proceeding is subject to Rule 6(e) of the federal rules of criminal procedure as

You are appearing voluntarily today as part of an agreement worked out between your attorney, the
oval of Judge Johnson. Is that correct, sir?

CLINTON: That is correct.

(UNKNOWN): Mr. Wisenberg, excuse me. You referred to Judge Johnson's order. I'm not familiar with

QUESTION: No. My understand is that that is an order that the judge is going to sign today. She
lly, my understanding is that it will cover all of the attorneys here today and the technical
sonally to be permitted to hear grand jury testimony that they otherwise wouldn't be authorized to

(UNKNOWN): Thank you.

QUESTION: The grand jury, Mr. President, has been empaneled by a United States District Court for
r?

CLINTON: I do.

QUESTION: And among other things, it's currently investigating under the authority of the Court of
ether Monica Lewinsky or others obstructed justice, intimidated witnesses or committed other crimes
u understand that, sir?

Starr Report, Complete Text - Enquirer.com



  The Starr Report
  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.
  Please be advised that the following documents contain sexually graphic
  references and may not be suitable for all readers.
  The White House response to the Starr report also is available.





  Chronology


  Table of Names
  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


  Introduction
  Factual Background
  The Investigation
  The Significance of the Evidence of Wrongdoing
  The Scope of the Referral

    1. Background of the Investigation.
    2. Current Status of the Investigation.

  The Contents of the Referral


  Narrative

NOTICE: This opinion is subject to formal revision before publication in the
preliminary print of the United States Reports. Readers are requested to notify
the Reporter of Decisions, Supreme Court of the United States, Washington, D.C.
20543, of any typographical or other formal errors, in order that corrections
may be made before the preliminary print goes to press.
SUPREME COURT OF THE UNITED STATES

No. 95-1853

WILLIAM JEFFERSON CLINTON, PETITIONER v. PAULA CORBIN JONES
on writ of certiorari to the united states court of appeals for the eighth
circuit
[May 27, 1997]
Justice Stevens delivered the opinion of the Court.
This case raises a constitutional and a prudential question concerning the
Office of the President of the United States. Respondent, a private citizen,
seeks to recover damages from the current occupant of that office based on
actions allegedly taken before his term began. The President submits that in all
but the most exceptional cases the Constitution requires federal courts to defer
such litigation until his term ends and that, in any event, respect for the
office warrants such a stay. Despite the force of the arguments supporting the
President's submissions, we conclude that they must be rejected.
Petitioner, William Jefferson Clinton, was elected to the Presidency in 1992,
and re elected in 1996. His term of office expires on January 20, 2001. In 1991
he was the Governor of the State of Arkansas. Respondent, Paula Corbin Jones, is
a resident of California. In 1991 she lived in Arkansas, and was an employee of
the Arkansas Industrial Development Commission.
On May 6, 1994, she commenced this action in the United States District Court
for the Eastern District of
Arkansas by filing a complaint naming petitioner and Danny Ferguson, a former
Arkansas State Police officer, as defendants. The complaint alleges two federal
claims, and two state law claims over which the federal court has jurisdiction
because of the diverse citizenship of the parties. [n.1] As the case comes to
us, we are required to assume the truth of the detailed--but as yet untested--
factual allegations in the complaint.
Those allegations principally describe events that are said to have occurred on
the afternoon of May 8, 1991, during an official conference held at the
Excelsior Hotel in Little Rock, Arkansas. The Governor delivered a speech at the
conference; respondent--working as a state employee--staffed the registration
desk. She alleges that Ferguson persuaded her to leave her desk and to visit the
Governor in a business suite at the hotel, where he made "abhorrent" [n.2]
sexual advances that she vehemently rejected. She further claims that her
superiors at work subsequently dealt with her in a hostile and rude manner, and
changed her duties to punish her for rejecting those advances. Finally, she
alleges that after petitioner was elected President, Ferguson defamed her by
making a statement to a reporter that implied she had accepted petitioner's
alleged overtures, and that various persons authorized to speak for the
President publicly branded her a liar by denying that the incident had occurred.

Complete text of a statement by Henry Hyde, (R-Ill) chairman of the House
Judiciary Committee, at a hearing Oct. 5, 1998, on whether to begin an
impeachment inquiry of President Clinton.
Transcribed by Federal Document Clearing House and transmitted by The Associated
Press
On Sept. 18, the House of Representatives passed a resolution with strong
bipartisan support, 363-63, directing the referral from the Office of
Independent Counsel to this committee with instructions that it be reviewed and
released by the 28th of September, unless the committee thought certain
information should be held back in the interest of privacy or to protect
innocent people.
The House thus placed in our care the task of reviewing more than 60,000 pages
of materials in less than three weeks, and ultimately, deciding what should be
placed in the public domain.
We have not always agreed on how to handle this information, but we have agreed
on the vast majority. I believe we can also agree that we could not have
accomplished this daunting assignment if not for the tireless work of the
committee's staff, both Democratic and Republican, who worked day and night --
sometimes around the clock -- to prepare these materials for our review. These
men and women rose to the occasion, and our gratitude goes out to them.
On Sept. 11, the Office of Independent Counsel transmitted materials to the
House of Representatives that, in his opinion, constituted substantial and
credible evidence that may constitute grounds for impeachment of the president
of the United States.
The appointment of an independent counsel had been recommended by Attorney
General Janet Reno and appointed by and served under the direction of the United
States Court of Appeals. Judge Starr was selected by a three-judge panel
appointed by the chief justice of the U.S. Supreme Court.
Today, it's our responsibility and our constitutional duty to review those
materials referred to us and recommended to the House of Representatives whether
the matter merits a further inquiry. Let me be clear about this: We are not here
today to decide whether or not to impeach Mr. Clinton. We are not here to pass
judgment on anyone.
We are here to ask and answer this one simple question: Based upon what we know
now, do we have a duty to look further or to look away?
We are constantly reminded how weary America is of this whole situation, and I
dare say, most of us share that weariness.
But we members of Congress took an oath that we would perform all of our
constitutional duties, not just the pleasant ones.
As Chairman Peter Rodino stated in 1974 -- quote -- "We cannot turn away out of
partisanship or convenience from problems that are now our responsibility, our
inescapable responsibility, to consider. It would be a violation of our own
public trust if we, as the people's representatives, chose not to inquire, not
to consult, not even to deliberate, and then pretend that we had not, by
default, made choices." Close quote.
This will be an emotional process, a strenuous process, because feelings are
high on all sides of this question. But the difficulties ahead can be surmounted
with good will and an honest effort to do what is best for the country.
In the first year of the republic, Thomas Paine wrote, "Those who expect to reap

Clinton's Rebuttal of Starr Report, Complete Text - Enquirer.comWhite House
  response
  to the Starr Report
  The content of the following materials are verbatim as released by the White

  House. The conversion to HTML by The Associated Press has altered the
  pagination and format.





PRELIMINARY MEMORANDUM CONCERNING
REFERRAL OF OFFICE OF INDEPENDENT COUNSEL

David E. Kendall             Charles F.C. Ruff
Nicole K. Seligman           Cheryl Mills
Emmet T. Flood               Lanny A. Breuer
Max Stier                    OFFICE OF THE WHITE
Glen Donath                  HOUSE COUNSEL
Alicia L. Marti              The White House

WILLIAMS & CONNOLLY          Washington, DC  20005
725 12th Street, N.W.
Washington, DC  20005

September 11, 1998


  EXECUTIVE SUMMARY

  Summary of Key Points of the President's Case in Anticipation of the Starr
  Report

  . The President has acknowledged a serious mistake - an inappropriate
  relationship with Monica Lewinsky. He has taken responsibility for his
  actions, and he has apologized to the country, to his friends, leaders of his

  party, the cabinet and most importantly, his family.

  . This private mistake does not amount to an impeachable action. A
  relationship outside one's marriage is wrong - and the President admits that.

  It is not a high crime or misdemeanor. The Constitution specifically states
  that Congress shall impeach only for Òtreason, bribery or other high crimes
  and misdemeanors." These words in the Constitution were chosen with great
  care, and after extensive deliberations.

  . "High crimes and misdemeanors" had a fixed meaning to the Framers of our

Motion for Summary Judgment - April 1, 1998ADVERTISEMENT







             Home
             Analysis
             TIME
             CQ
             Community


            The Jones Case
             Introduction
             Legal Issues
             Documents
             Characters


            Related Stories
            Judge Orders Jones Case Record Unsealed, Barring Appeal - June 30,

            1998
            Jones Appeal Difficult, But Not Impossible - April 16, 1998
            Jones Will Appeal, Sources Say - April 16, 1998
            Jones Set To Meet With Her Attorneys - April 15, 1998


            Documents
            Key legal documents from the case.


            Voter's Voice
            We've received a ton of e-mail on Paula Jones' lawsuit, and here's

            some of it. Or join an online discussion on our community page.


            Changing Look
            Paula Jones has changed lawyers, personal advisors and even her
            looks. Check out the changes with a JavaScript-enabled browser.


            Related Sites
            Court TV Online - Jones v. Clinton
            Paula Jones Legal Fund Web site

Motion for Summary Judgment - April 1, 1998

ADVERTISEMENT
[img: ]
[img: Barnes & Noble]----------------------------------------

 

[img:  ]Home
[img:  ]Analysis
[img:  ]TIME
[img:  ]CQ
[img:  ]Community

The Jones Case
[img:  ]Introduction
[img:  ]Legal Issues
[img:  ]Documents
[img:  ]Characters

Related Stories

Judge Orders Jones Case Record Unsealed, Barring Appeal - June 30, 1998

Jones Appeal Difficult, But Not Impossible - April 16, 1998

Jones Will Appeal, Sources Say - April 16, 1998

Jones Set To Meet With Her Attorneys - April 15, 1998

Documents

Key legal documents from the case.

Voter's Voice

We've received a ton of e-mail on Paula Jones' lawsuit, and here's some of it. Or join an online

Changing Look

Paula Jones has changed lawyers, personal advisors and even her looks. Check out the changes with a

Related Sites

Court TV Online - Jones v. Clinton

Paula Jones Legal Fund Web site

Decision Dismissing Jones vs. Clinton case
Judge Wright's Opinion
Released on Wednesday, April 1, 1998
Following is the complete text of U.S. District Court Judge Susan Webber
Wright's 39-page ruling dismissing Paula Jones's sexual harassment case against
President Clinton.
  Judge Susan Webber Wright
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
WESTERN DIVISION
PAULA CORBIN JONES,
Plaintiff,
vs.
No. LR-C-94-290
WILLIAM JEFFERSON CLINTON
and DANNY FERGUSON,
Defendants.
MEMORANDUM OPINION AND ORDER

The plaintiff in this lawsuit, Paula Corbin Jones, seeks civil damages from
William Jefferson Clinton, President of the United States, and Danny Ferguson, a
former Arkansas State Police Officer, for alleged actions beginning with an
incident in a hotel suite in Little Rock, Arkansas. This case was previously
before the Supreme Court of the United States to resolve the issue of
Presidential immunity but was remanded to this Court following the Supreme
Court's determination that there is no constitutional impediment to allowing
plaintiff's case to proceed while the President is in office. See Clinton v.
Jones, 117 S.Ct. 1636 (1997). Following remand, the President filed a motion for
judgment on the pleadings and dismissal of the complaint pursuant to Rule 12(c)
of the Federal Rules of Civil Procedure. Ferguson joined in the President's
motion. By Memorandum Opinion and Order dated August 22, 1997, this Court
granted in part and denied in part the President's motion. See Jones v. Clinton,
974 F.Supp. 712 (E.D.Ark. 1997). The Court dismissed plaintiff's defamation
claim against the President, dismissed her due process claim for deprivation of
a property interest in her State employment, and dismissed her due process
claims for deprivation of a liberty interest based on false imprisonment and
injury to reputation, but concluded that the remaining claims in plaintiff's
complaint stated viable causes of action. See Id. Plaintiff subsequently
obtained new counsel and filed a motion for leave to file a first amended
complaint, which the Court granted, albeit with several qualifications. See
Order of November 24, 1997. The matter is now before the Court on motion of both
the President and Ferguson for summary judgment pursuant to Rule 56 of the
Federal Rules of Civil Procedure. Plaintiff has responded in opposition to these
motions, and the President and Ferguson have each filed a reply to plaintiff's
response to their motions. For the reasons that follow, the Court finds that the
President's and Ferguson's motions for summary judgment should both be and
hereby are granted.
I.
This lawsuit is based on an incident that is said to have taken place on the

MEMORANDUM OPINION AND ORDER  The plaintiff in this lawsuit, Paula
Corbin Jones, seeks civil damages from William Jefferson Clinton,
President of the United States, and Danny Ferguson, a former Arkansas
State Police Officer, for alleged actions beginning with an incident in
a hotel suite in Little Rock, Arkansas. This case was previously before
the Supreme Court of the United States to resolve the issue of
Presidential immunity but was remanded to this Court following the
Supreme Court's determination that there is no constitutional impediment
to allowing plaintiff's case to proceed while the President is in
office. See Clinton v. Jones, 117 S.Ct. 1636 (1997). Following remand,
the President filed a motion for judgment on the pleadings and dismissal
of the complaint pursuant to Rule 12(c) of the Federal Rules of Civil
Procedure. Ferguson joined in the President's motion. By Memorandum
Opinion and Order dated August 22, 1997, this Court granted in part and
denied in part the President's motion. See Jones v. Clinton, 974 F.Supp.
712 (E.D.Ark. 1997). The Court dismissed plaintiff's defamation claim
against the President, dismissed her due process claim for deprivation
of a property interest in her State employment, and dismissed her due
process claims for deprivation of a liberty interest based on false
imprisonment and injury to reputation, but concluded that the remaining
claims in plaintiff's complaint stated viable causes of action. See Id.
Plaintiff subsequently obtained new counsel and filed a motion for leave
to file a first amended complaint, which the Court granted, albeit with
several qualifications. See Order of November 24, 1997. The matter is
now before the Court on motion of both the President and Ferguson for
summary judgment pursuant to Rule 56 of the Federal Rules of Civil
Procedure. Plaintiff has responded in opposition to these motions, and
the President and Ferguson have each filed a reply to plaintiff's
response to their motions. For the reasons that follow, the Court finds
that the President's and Ferguson's motions for summary judgment should
both be and hereby are granted.  I.  This lawsuit is based on an
incident that is said to have taken place on the afternoon of May 8,
1991, in a suite at the Excelsior Hotel in Little Rock, Arkansas.
President Clinton was Governor of the State of Arkansas at the time, and
plaintiff was a State employee with the Arkansas Industrial Development
Commission ("AIDC"), having begun her State employment on March 11,
1991. Ferguson was an Arkansas State Police officer assigned to the
Governor's security detail.



		 According to the record, then-Governor Clinton was at the Excelsior
Hotel on the day in question delivering a speech at an official
conference being sponsored by the AIDC. Am. Compl. ¶7. Plaintiff states
that she and another AIDC employee, Pamela Blackard, were working at a
registration desk for the AIDC when a man approached the desk and
informed her and Blackard that he was Trooper Danny Ferguson, the
Governor's bodyguard. Pl.'s Statement of Mat. Facts, ¶¶1-2. She states
that Ferguson made small talk with her and Blackard and that they asked

No. 95-1853

WILLIAM JEFFERSON CLINTON, PETITIONER v. PAULA CORBIN JONES
on writ of certiorari to the united states court of appeals for the eighth
circuit
[May 27, 1997]
Justice Breyer , concurring in the judgment.
I agree with the majority that the Constitution does not automatically grant the
President an immunity from civil lawsuits based upon his private conduct. Nor
does the "doctrine of separation of powers . . . require federal courts to stay"
virtually "all private actions against the President until he leaves office."
Ante, at 24. Rather, as the Court of Appeals stated, the President cannot simply
rest upon the claim that a private civil lawsuit for damages will "interfere
with the constitutionally assigned duties of the Executive Branch . . . without
detailing any specific responsibilities or explaining how or the degree to which
they are affected by the suit." 72 F. 3d 1354, 1361 (CA8 1996). To obtain a
postponement the President must "bea[r] the burden of establishing its need."
Ante, at 26.
In my view, however, once the President sets forth and explains a conflict
between judicial proceeding and public duties, the matter changes. At that
point, the Constitution permits a judge to schedule a trial in an ordinary civil
damages action (where postponement normally is possible without overwhelming
damage to a plaintiff) only within the constraints of a constitutional principle
-a principle that forbids a federal judge in such a case to interfere with the
President's discharge of his public duties. I have no doubt that the
Constitution contains such a principle applicable to civil suits, based upon
Article II's vesting of the entire "executive Power" in a single individual,
implemented through the Constitution's structural separation of powers, and
revealed both by history and case precedent.
I recognize that this case does not require us now to apply the principle
specifically, thereby delineating its contours; nor need we now decide whether
lower courts are to apply it directly or categorically through the use of
presumptions or rules of administration. Yet I fear that to disregard it now may
appear to deny it. I also fear that the majority's description of the relevant
precedents de emphasizes the extent to which they support a principle of the
President's independent authority to control his own time and energy, see, e.g.,
ante, at 11 (describing the "central concern" of Nixon v. Fitzgerald, 457 U.S.
731  (1982), as "to
avoid rendering the President `unduly cautious' "); ante, at 13, and n. 23
(describing statements by Story, Jefferson, Adams, and Ellsworth as providing
"little" or "no substantial support" for the President's position). Further, if
the majority is wrong in predicting the future infrequency of private civil
litigation against sitting Presidents, ante, at 20, acknowledgement and future
delineation of the constitutional principle will prove a practically necessary
institutional safeguard. For these reasons, I think it important to explain how
the Constitution's text, history, and precedent support this principle of
judicial noninterference with Presidential functions in ordinary civil damages
actions.
The Constitution states that the "executive Power shall be vested in a