623. Lewinsky 8/13/98 Int. at 4; Lewinsky 8/26/98 Depo. at 61-63.

624. Podesta 2/5/98 GJ at 40-41. See also Lewinsky 7/31/98 Int. at 10. As previously discussed, Ms. Currie had earlier asked Mr. Podesta to help Ms. Lewinsky obtain a White House job.⁽⁶²⁵⁾

625. See supra at [].

626. Podesta 2/5/98 GJ at 40-45; Richardson 4/30/98 Depo. at 28. On Sunday, October 12, 1997, the President traveled to Latin America for one week. United States President, Weekly Compilations of Presidential Documents at 1608, 1609, 1653. On that trip, the President was accompanied by, among others, then-U.N. Ambassador William Richardson and the Deputy Chief of Staff, John Podesta. Richardson 4/30/98 Depo. at 28-29; Podesta 2/5/98 GJ at 44. Ambassador Richardson recalled that Mr. Podesta had first made the request prior to the trip to Latin America. Richardson 4/30/98 Depo. at 28.

627. Podesta 2/5/98 GJ at 45; Richardson 4/30/98 Depo. at 32.

628. Richardson 4/30/98 Depo. at 160-61; Clinton 1/17/98 Depo. at 73.

629. Richardson 4/30/98 Depo. at 26.

630. Watkins 5/27/98 Depo. at 11-12, 18.

631. Podesta 2/5/98 GJ at 46.

632. 828-DC-00000012 (faxed copy of Ms. Lewinsky's resume, produced by the U.N.); Currie 5/6/98 GJ at 174.

633. 828-DC-00000004 (U.N. phone records).

634. Lewinsky 8/13/98 Int. at 3.

635. Lewinsky 8/26/98 Depo. at 63-64. See also Lewinsky 8/26/98 Depo. at 63-64; Lewinsky 7/31/98 Int. at 12; Lewinsky 7/27/98 Int. at 5.

636. Lewinsky 7/27/98 Int. at 5.

637. Richardson 4/30/98 Depo. at 47-48; Watkins 5/27/98 Depo. at 27-29. Ms. Watkins further testified that she often placed calls from the Ambassador's line. Watkins 5/27/98 Depo. at 37-38.

638. Lewinsky 8/13/98 Int. at 3-4.

639. Lewinsky 8/13/98 Int. at 4.

640. Lewinsky 8/13/98 Int. at 4. See also Lewinsky 7/31/98 Int. at 12.

641. Lewinsky 8/26/98 Depo. at 64-65; Lewinsky 7/31/98 Int. at 13.

642. Lewinsky 8/26/98 Depo. at 65. Ms. Lewinsky wrote an email to her friend Catherine Allday Davis: "It was nice; the big creep called Thursday night to give me a pep talk because I was so afraid I'd sound like an idiot." 1037-DC-00000022 (spelling corrected).⁽⁶⁴³⁾

643. 1037-DC-000000022 (spelling corrected).

644. Lewinsky 7/31/98 Int. at 13. See also Lewinsky 8/26/98 Depo. at 65.

645. Clinton 1/17/98 Depo. at 74.

646. 828-DC-00000023 (Ambassador Richardson's diary reflecting 7:30 a.m. meeting with Monica Lewinsky). See also Ambassador Richardson 4/30/98 Depo. at 66-68; Sutphen 5/27/98 Depo. at 7; Cooper 1/27/98 Int. at 1-2; Lewinsky 7/31/98 Int. at 13-14. After meeting with Ms. Lewinsky, Ambassador Richardson spent the remainder of the day meeting individually with Senators and Members of Congress. 828-DC-00000023 (Ambassador Richardson's itinerary for October 31).

647. Richardson 4/30/98 Depo. at 68; Cooper 1/27/98 Int. at 1-2.

648. Richardson 4/30/98 Depo. at 39; Sutphen 5/27/98 Depo. at 15-16; Cooper 1/27/98 Int. at 2.

649. The draft was retrieved from Ms. Lewinsky's computer in the course of a consensual search on January 22, 1998.

650. MSL-55-DC-0179 (punctuation added)(italics in original).

651. MSL-55-DC-0179.

652. MSL-55-DC-0179. Ms. Lewinsky concluded the letter, "I was pleased the UN interview went well, but I'm afraid it will be like being at the Pentagon in NY. . . YUCK!" MSL-55-DC-0179 (ellipsis in original).

653. Lewinsky 8/13/98 Int. at 4-5; Lewinsky 7/31/98 Int. at 14; Lewinsky 7/27/98 Int. at 5.

654. 828-DC-00000003.

655. Lewinsky 8/26/98 Depo. at 67; Lewinsky 7/27/98 Int. at 5; Lewinsky 7/31/98 Int. at 14; Lewinsky 8/13/98 Int. at 5.

According to Ambassador Richardson, the position offered to Ms. Lewinsky was not newly created. He testified that he intended to expand an open position in the U.N.'s Washington office and move it to New York. Richardson 4/30/98 Depo. at 39-40. Although Ambassador Richardson did not recall whether this opening was publicized, he testified that it would be common for the office not to post Schedule C (political appointment) positions. Richardson 4/30/98 Depo. at 71-72. Peter Aronsohn, who filled the position Ms. Lewinsky was offered, characterized the job as a "new position." Aronsohn 8/27/98 Int. at 2.

656. Sutphen 5/27/98 Depo. at 26.

657. Richardson 4/30/98 Depo. at 90-91; Sutphen 5/27/98 Depo. at 21-23.

658. Lewinsky 8/26/98 Depo. at 65-66; Lewinsky 8/13/98 Int. at 4.

659. Currie 5/6/98 GJ at 174-75, 181; Currie 5/14/98 GJ at 65-66.

660. Clinton 1/17/98 Depo. at 73.

661. Sutphen 5/27/98 Depo. at 32-33; Lewinsky 8/13/98 Int. at 5.

662. Sutphen 5/27/98 Depo. at 33. See also Richardson 4/30/98 Depo. at 110-11 (recalling Ms. Lewinsky's request for additional time to consider the offer).

663. Lewinsky 7/27/98 Int. at 5; Sutphen 5/27/98 Depo. at 38; 1013-DC-00000095 (toll records for Debra Finerman).

664. 921-DC-00000101 - 118 (Second Set of Interrogatories from Plaintiff to Defendant Clinton).

665. V002-DC-00000016; V002-DC-00000020-21.

666. See supra at IX.B. See also Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12.

667. MSL-55-DC-0179.

668. Lewinsky 7/31/98 Int. at 14.

669. Lewinsky 7/31/98 Int. at 14. Phone records reflect that on November 4 at 3:54 p.m., Ms. Lewinsky placed a three-and-a-half-minute call to Mr. Jordan's office; at 4:09 p.m., Mr. Jordan placed a one-minute call to Ms. Currie; and at 4:38 p.m., Mr. Jordan placed a one-minute call to Ms. Currie. 833-DC-00017875 (Ms Lewinsky's phone records); V004-DC-00000134 (Akin, Gump phone records).

670. T2 at 11-12. See also Lewinsky 7/31/98 Int. at 11.

671. Jordan 5/5/98 GJ at 47 (Mr. Jordan testified that he believed the President had told Ms. Currie to "[c]all Vernon and ask Vernon to help her").

672. Currie 5/6/98 GJ at 169-70, 176-78, 182-83, 198.

673. Clinton 1/17/98 Depo. at 81.

674. Clinton 1/17/98 Depo. at 82.

675. 1178-DC-00000011 (call logs).

676. Lewinsky 7/31/98 Int. at 14.

677. Lewinsky 7/31/98 Int. at 14-15.

678. Lewinsky 8/13/98 Int. at 3.

679. Lewinsky 8/6/98 GJ at 106; Lewinsky 7/31/98 Int. at 14-15; Lewinsky 7/27/98 Int. at 8, 10. Ms. Lewinsky later quoted the remark in email to a friend.⁽⁶⁸⁰⁾

680. 1037-DC-00000017 (email retrieved from Ms. Davis's computer). --

681. 1037-DC-00000017 (email retrieved from Catherine Davis's computer).

682. Jordan 3/3/98 GJ at 13.

683. V004-DC-00000135 (Akin, Gump phone records).

684. Jordan 5/5/98 GJ at 54.

685. 1178-DC-00000026 (WAVES record). Ms. Lewinsky would learn of the meeting between the President and Mr. Jordan. In email to a friend dated November 6, Ms. Lewinsky wrote that Mr. Jordan had "[seen] the big creep yesterday afternoon." 1037-DC-00000017 (spelling corrected) (email to Catherine Davis).

686. Jordan 5/5/98 GJ at 34.

687. 833-DC-00000980 (letter retrieved from Ms. Lewinsky's Pentagon computer)(spelling corrected).

688. 1037-DC-00000017 (email retrieved from Catherine Davis's computer). Ms. Lewinsky wrote that she was "a little nervous to do the whole name of the BF. His first name is Vernon." Id. According to her aunt, Debra Finerman, Ms. Lewinsky used the code name "Gwen" when discussing Mr. Jordan because "he's an important person" and Ms. Lewinsky "always had the feeling somebody was listening in" on their phone conversations, they did not want an eavesdropper to know that Mr. Jordan was helping her find a job. Finerman 3/18/98 Depo. at 60. See also Lewinsky 8/5/98 Int. at 3; Lewinksy 8/3/98 Int. at 9.

689. Jordan 3/3/98 GJ at 50.

690. Jordan 5/5/98 GJ at 26-30, 34.

691. Epass records reflect that Ms. Lewinsky entered the White House at 6:20 p.m., admitted by Ms. Currie. 827-DC-00000018. Secret Service Movement logs show that the President entered the State Floor at 5:23 and moved to the Oval Office at 6:34. V006-DC-00002156.

692. 1037-DC-00000318 (email retrieved from Catherine Davis's computer).

693. Lewinsky 8/13/98 Int. at 5.

694. Lewinsky 8/13/98 Int. at 5. Many of Ms. Lewinsky's previous visits with the President had occurred on holidays. See, e.g., Lewinsky 7/30/98 Int. at 3, 13, 17 (describing visits on New Year's Eve, Presidents' Day, Easter Sunday, and July 4).

695. 837-DC-00000008(courier receipt).

696. DB-DC-00000022. Ms. Lewinsky produced a draft of this letter to the OIC on July 31, 1998. See also Lewinsky 7/31/98 Int. at 1 (confirming that she delivered a substantially similar note).

697. DB-DC-00000022.

698. Lewinsky 8/13/98 Int. at 5-6. On November 12, 1997, the President responded to Paula Jones's Third Set of Interrogatories. In response to an interrogatory that asked the President to provide information about all individuals who have discoverable and relevant information regarding the disputed facts at issue in the case, the President provided a list of names that did not include Ms. Lewinsky. 849-DC-0000090 - 97.

699. 1037-DC-00000318 (email retrieved from Catherine Davis's computer).

700. 1037-DC-00000318 (spelling corrected). Lewinsky 8/13/98 Int. at 6. On November 13, Ms. Hernreich was testifying before Congress. Walsh, "Democratic Donor Chung Invokes 5^th Amendment; House Members Informally Interview Businessman Edward Walsh," Washington Post, November 15, 1997, at A6.

701. MSL-1249-DC-0140; Lewinsky 8/13/98 Int. at 6.

702. 1037-DC-00000318 (email retrieved from Catherine Davis's computer).

703. Lewinsky 8/13/98 Int. at 6; 1234-DC-00000050 (movement log); 986-DC-00003799 (Kearney Diary).

704. Lewinsky 8/13/98 Int. at 6.

705. Lewinsky 8/13/98 Int. at 6; 1037-DC-00000318 (email to Catherine Davis).

706. In a note to the President the next week, Ms. Lewinsky would write of the gifts: "I forgot to tell you: . . . The Gingko Blowjoba or whatever it is called and the Zinc lozenges were from me." MSL-55-DC-0140 (spelling and grammar corrected).

707. Lewinsky 8/6/98 GJ at 183-85; Lewinsky 8/2/98 Int. at 4. Ms. Lewinsky also saw a clipping of the Valentine's Day ad she had placed in the Washington Post on the President's desk. Lewinsky 8/6/98 GJ at 183-84. In a document composed soon after this visit, Ms. Lewinsky wrote: "When I was hiding out in your office for a half-hour, I noticed you had the new Sarah McLachlan CD. I have it, too, and it's wonderful. Whenever I listen to song #5 I think of you. That song and Billie Holiday's version of 'I'll be Seeing You' are guaranteed to put me to tears when it comes to you!" MSL-1249-DC-0140-41 (deleted file from Ms. Lewinsky's home computer) (spelling and grammar corrected).

708. 1037-DC-00000318 (email to Catherine Davis).

709. Lewinsky 8/13/98 Int. at 6.

710. OIC 8/27/98 Memo.

711. 968-DC-00000187 (presidential schedule); 968-DC-00000303 (Kearney Diary). Ms. Currie initially testified that she could not recall Ms. Lewinsky's November 13 visit. Currie 5/6/98 GJ at 12, 15. After viewing documentary evidence, she recalled that this was the only time she surreptitiously escorted Ms. Lewinsky into the White House. Id. at 85.

712. Lewinsky 8/11/98 Int. at 1; Lewinsky 7/31/98 Int. at 1-2; 837-DC-00000011 (courier receipt); MSL-1249-DC-0140-41 (document recovered from Ms. Lewinsky's home computer).

On November 17, 1997, the President responded to Paula Jones's First Set of Requests for Production of Documents and Things. One request sought documents sent to President Clinton by any woman (other than Mrs. Clinton) with whom President Clinton had sexual relations. V002-DC-00000056 - 92. President Clinton objected to this request as one designed "solely to harass, embarrass, and humiliate the President and the Office he occupies." V002-DC-00000075. Nonetheless, the President answered that he did not have any documents responsive to that request.

713. Lewinsky 8/6/98 GJ at 105.

714. Lewinsky 8/6/98 GJ at 105. Phone and pager records corroborate these contacts. 1205-DC-00000016; V004-DC-00000143; 831-DC-00000011. (Note that Ms. Lewinsky's pager records reflect Pacific Time; throughout this referral, time has been adjusted to Eastern Standard Time.)

715. MSL-1249-DC-0140 (spelling and punctuation corrected).

716. MSL-1249-DC-0139 (spelling and punctuation corrected).

717. 849-DC-00000128.

718. 849-DC-00000121-37

719. See infra at Section XI.F. See also Lewinsky 8/6/98 GJ at 121-26.

720. Clinton 8/17/98 GJ at 84-85. In his Jones deposition, the President acknowledged that he may have heard of the witness list before he actually saw it. Clinton 1/17/98 Depo. at 70.

721. 833-DC-00003207 (Travel Voucher DOD).

722. Lewinsky 8/6/98 GJ at 107; Lewinsky 7/31/98 Int. at 1.

723. V006-DC-00000521 (guest list); VOO6-DC-00001859 (photograph of Ms. Lewinsky and the President at the reception).

724. Lewinsky 7/31/98 Int. at 1.

725. Lewinsky 7/31/98 Int. at 2; MSL-55-DC-0177. The wording of the letter resembles, in part, a message on a cassette found during the consensual search of Ms. Lewinsky's apartment: "Hi. [Sniffling, crying.] I was so sad seeing you last night. I was so angry with you that once again you had rejected me. . . . I wanted to feel the warmth of you and the smell of you and the touch of you. And it made me sad. And I -- you confuse me so much. I mean I [sigh]. I thought I -- I thought I fell in love with this person that -- that I really felt was such a good -- such a good person, such a good heart, someone who's had a life with a lot of experiences.⁽⁷²⁶⁾

726. Search.001 transcript at 2. [get cite for tape itself]

727. MSL-55-DC-0177 (punctuation corrected).

728. MSL-55-DC-0177 (punctuation corrected).

729. MSL-DC-55-0177 (punctuation corrected).

730. MSL-55-DC-0177 (punctuation corrected).

731. Lewinsky 8/6/98 GJ at 108-09; Lewinsky 8/6/98 GJ at 27-29 & Exh. ML-7. The cigar holder, the tie, the mug, and the book have been produced to the OIC. V002-PHOTOS-0011 (holder, tie, and book); V002-PHOTOS-0005 (mug).

732. Lewinsky 8/6/98 GJ at 111-12.

733. Bryan Hall 5/21 98 Int. at 2; Bryan Hall 7/23/98 GJ at 10-11, 15-16; Niedzwiecki 7/30/98 GJ at 12-13; Lewinsky 8/6/98 GJ at 109-11.

734. Lewinsky 8/6/98 GJ at 110-11; Niedzwiecki 7/30/98 GJ at 13-14.

735. Byran Hall 7/23/98 GJ at 12-13; Niedzwiecki 7/30/98 GJ at 13, 15. Officer Hall recognized Ms. Lewinsky from a previous occasion, when she was greeted by, and delivered something to, Ms. Currie. Byran Hall 7/23/98 GJ at 6-10.

736. Tyler 7/28/98 GJ at 40; Chinery 7/23/98 GJ at 8.

737. Lewinsky 8/6/98 GJ at 111-12. Ms. Mondale recalled visiting the President that morning. Mondale 7/16/98 Int. at 1. See also 843-DC-00000004 (Epass records reflect that Ms. Mondale entered the White House at 9:33 a.m.).

738. Lewinsky 8/6/98 GJ at 111-12. See also Currie 7/22/98 GJ at 88-89. Ms. Lewinsky suspected that Ms. Mondale was romantically involved with the President. ⁽⁷³⁹⁾

739. In a conversation on November 11, Ms. Lewinsky speculated that Ms. Mondale was and the President were starting a "relationship." Ms. Lewinsky noted with bitterness: "Maybe she's not sleeping with him yet. Anyway, there's the excitement. It's the President." LT16 at 91. -

740. Lewinsky 8/6/98 GJ at 112-13. Ms. Currie testified that Ms. Lewinsky angrily told her: "'You had lied to me, that the President is in the office, and he's meeting with someone.' And I said, 'Yeah, you're right.' She was not too happy about it, and words were exchanged." Currie 1/27/98 GJ at 37.

741. Keith Williams 7/23/98 GJ at 24. See also Chinery 7/23/98 GJ at 10; Purdie 7/23/98 GJ at 13.

742. Keith Williams 7/23/98 GJ at 12. Some testimony indicates that the President directly told Sergeant Williams about the Northwest Gate incident. Three officers testified that Sergeant Williams told them that the President had spoken to him and had indicated that he wanted the officer responsible for the disclosure of information fired. Niedzwiecki 7/30/98 GJ at 29, 37; Byran Hall 7/23/98 GJ at 25-26; Porter 8/13/98 GJ at 16-18. For example, Officer Niedzwiecki testified that soon after the incident, Sergeant Williams came to the Northwest Gate and said, "[t]he President wants somebody's job." Niedzwiecki 7/30/98 GJ at 29. Sergeant Williams testified, however, that the President did not speak to him directly about the incident. Keith Williams 7/23/98 GJ at 31-32. According to Sergeant Williams, when he met alone with Ms. Currie, he noticed that the door leading to the Oval Office was at first shut but then was cracked open. Keith Williams 7/23/98 GJ at 22, 30. Sergeant Williams testified that he heard what he assumed to be a male voice coming from within the Oval Office saying "[t]his person needs to be fired." Keith Williams 7/30/98 GJ at 10-11. Sergeant Williams told the officers at the gate that he spoke to the President only to get their attention. Keith Williams 7/30/98 GJ at 16-17. However, Sergeant Williams also told the supervisor who replaced him that afternoon that the President had spoken to him directly about the incident at the Northwest Gate. Deardoff 9/3/98 Depo. at 8-9.

743. Purdie 7/23/98 GJ at 13, 18-19. Captain Purdie testified that he thought that the remedy of firing was "out of proportion to the incident . . . [e]specially without doing an investigation or a fact-finding mission."⁽⁷⁴⁴⁾

744. Purdie 7/23/98 GJ at 19.

745. Lewinsky 8/6/98 GJ at 113.

746. Lewinsky 8/6/98 GJ at 113-14.

747. Lewinsky 8/6/98 GJ at 114.

748. Lewinsky 8/6/98 GJ at 114.

749. 827-DC-00000018. Secret Service logs reflect that the President was in the area of the Oval Office throughout this period. V006-DC-00002158.

750. Lewinsky 8/6/98 GJ at 115-16. Specifically, Ms. Lewinsky told the President "that I was supposed to get in touch with Mr. Jordan the previous week and that things didn't work out and that nothing had really happened yet." Id.

751. Lewinsky 8/6/98 GJ at 116. The President also told Ms. Lewinsky that he had already gotten a Christmas present for her and that he would give that to her during another visit. Lewinsky 8/1/98 Int. at 2.

752. Lewinsky 8/6/98 GJ at 115.

753. 1037-DC-00000011 (spelling corrected).

754. Keith Williams 7/23/98 GJ at 25. Ms. Currie confirmed that she told an officer, "Okay. Fine. This never happened." However, she testified that she said this so that no officer would get in trouble. Currie 7/22/98 GJ at 91-92.

When Ms. Currie left work that day, she stopped by a Secret Service post and told an officer that "she spoke to the President . . . and . . . they decided that the incident never happened, they weren't going to pursue . . . discipline actions against them, that they just wanted it to go away." Chinery 7/23/98 GJ at 22-23. Later that week, Ms. Currie told that officer to inform one of his supervisors "that everything was okay and just to keep quiet about it." Keith Williams 7/23/98 GJ at 27-28.

755. Purdie 7/23/98 GJ at 32; Purdie 7/17/98 GJ at 3.

756. Purdie 7/17/98 GJ at 6; Bryan Hall 7/23/98 GJ at 31-32; Chinery 7/23/98 GJ at 21.

757. Porter 8/13/98 GJ at 12.

758. Niedzwiecki 7/30/98 GJ at 30-31.

759. Niedzwiecki 7/30/98 GJ at 31, 44. See also Niedzwiecki 8/5/98 GJ at 4-6 (text of Niedzwiecki notes).

760. Purdie 7/23/98 GJ at 35.

761. Purdie 7/23/98 GJ at 34-36. While Deputy Chief O'Malley testified that Captain Purdie notified him of the incident, Deputy Chief O'Malley did not recall Captain Purdie discussing with him, at any time, a decision not to generate an incident report or a memorandum. Charles O'Malley 9/8/98 Depo. at 44, 47-48.

762. O'Malley 9/8/98 Depo. at 22, 40-41.

763. Clinton 8/17/98 GJ at 84-85, 87. Ms. Mondale stated that she met with the President alone in the Oval Office study that day. Mondale 7/16/98 Int. at 1.

764. Clinton 8/17/98 GJ at 86.

765. Clinton 8/17/98 GJ at 88-89.

766. Clinton 8/17/98 GJ at 89-90.

767. Clinton 8/17/98 GJ at 91-92.

768. Lewinsky 8/6/98 GJ at 151-52; Lewinsky 2/1/98 Statement at 6. On December 23, Paula Jones's attorneys issued a subpoena to the Secret Service.

769. Lindsey 3/12/98 GJ at 64-66; Lindsey 2/19/98 GJ at 9-10. WAVES records reflect that Robert Bennett entered the White House at 4:39 p.m. on Saturday, December 6. 1407-DC-00000005.

770. Lindsey 3/12/98 GJ at 65.

771. 964-DC-00000862 (Presidential mail notes).

772. Lindsey 3/12/98 GJ at 63-64. Mr. Lindsey refused to answer questions about his December 6 meeting with the President, claiming attorney-client privilege and Executive (presidential communications) Privilege.⁽⁷⁷³⁾

773. Lindsey 3/12/98 GJ at 66. The U.S. District Court for the District of Columbia Circuit rejected Mr. Lindsey's claim of privilege, In re Grand Jury Proceedings, 5 F. Supp.2d 21 (D.D.C. 1998), and the Court of Appeals denied Mr. Lindsey's appeal, In re Lindsey, __ F.3d __, 1998 WL 418780 (D.C. Cir. 1998). A petition for Supreme Court review is currently pending. __ U.S.L.W. __ (U.S. Aug. 21, 1998) (No. 98-316).

774. WAVES records reflect that Mr. Jordan entered the White House at 5:21 p.m. on Sunday, December 7. 1178-DC-00000026.

775. Jordan 5/5/98 GJ at 83. He later testified that the conversation was "[a]bsolutely not" about Ms. Lewinsky. Jordan 5/5/98 GJ at 116.

776. V004-DC-00000171 (Akin, Gump visitor records) (recording visit of "Malensky"). Ms. Lewinsky recalled arranging the meeting on December 8 or 9. Lewinsky 8/1/98 Int. at 3. See also 833-DC-00017886 (reflecting Ms. Lewinsky's call to Mr. Jordan on December 8).

On December 8, Ms. Lewinsky sent Mr. Jordan a hat, a box of chocolates, and a note gently reminding him of his promise to help her find a job. Lewinsky 7/31/98 Int. at 15. She also sent the President a note and some peach candies. Lewinsky 8/1/98 Int. at 2; Lewinsky 8/1/98 Int. at 2; 837-DC-00000017; 837-DC-00000020 (courier receipts).

777. Jordan 3/3/98 GJ at 41-42.

778. V004-DC-00000148 (Akin, Gump phone records). See also Jordan 3/3/98 GJ at 54, 62-63, 70.

Mr. Halperin testified that Mr. Jordan had told him that Ms. Lewinsky "was a bright young woman who was energetic and enthusiastic and . . . encouraged me to meet with her." Halperin 4/23/98 GJ at 13. Similarly, Ms. Fairbairn stated that Mr. Jordan had told her that he "would like to send [her] a resume of a talented young lady and see if she matches up with any company openings." Fairbairn 1/29/98 Int. at 1. Mr. Georgescu, however, stated that Mr. Jordan "did not engage in a 'sales pitch' about [Ms.] Lewinsky." Georgescu 3/25/98 Int. at 2.

779. Lewinsky 8/6/98 GJ at 121. Ms. Lewinsky left the meeting with Mr. Jordan on December 8 with the impression that Mr. Jordan was going to get her a job. Lewinsky 8/1/98 Int. at 4.

780. Lewinsky 8/6/98 GJ at 119.

781. Lewinsky 8/6/98 GJ at 120.

782. Lewinsky 8/6/98 GJ at 120.

783. Lewinsky 8/6/98 GJ at 120. In her handwritten proffer, Ms. Lewinsky gave a very similar account of her second meeting with Mr. Jordan: "Ms. L. met again with Mr. Jordan in the beginning of December '97, at which time he provided Ms. L. with a list of three people to contact and suggested language to use in her letters to them. At some point, Mr. Jordan remarked something about Ms. L. being a friend of the Pres. of the United States. Ms. L. responded that she never really saw him as "the President"; she spoke to him like a normal man and even got angry with him like a normal man. Mr. Jordan asked what Ms. L. got angry about. Ms. L. replied that the Pres. doesn't see or call her enough. Mr. Jordan said Ms. L. should take her frustrations out on him -- not the President.⁽⁷⁸⁴⁾