Kenneth W. Starr - The Starr Report (Grounds for Impeachment, No. I) lyrics

I. There is substantial and credible information that President Clinton lied under oath as a defendant in Jones v. Clinton regarding his s**ual relationship with Monica Lewinsky. (1) He denied that he had a "s**ual relationship" with Monica Lewinsky. (2) He denied that he had a "s**ual affair" with Monica Lewinsky. (3) He denied that he had "s**ual relations" with Monica Lewinsky. (4) He denied that he engaged in or caused contact with the genitalia of "any person" with an intent to arouse or gratify (oral s** performed on him by Ms. Lewinsky). (5) He denied that he made contact with Monica Lewinsky's breasts or genitalia with an intent to arouse or gratify. On May 6, 1994, former Arkansas state employee Paula Corbin Jones filed a federal civil rights lawsuit against President Clinton claiming that he had s**ually hara**ed her on May 8, 1991, by requesting her to perform oral s** on him in a suite at the Excelsior Hotel in Little Rock. Throughout the pretrial discovery process in Jones v. Clinton, United States District Judge Susan Webber Wright ruled, over the President's objections, that Ms. Jones's lawyers could seek various categories of information, including information about women who had worked as government employees under Governor or President Clinton and allegedly had s**ual activity with him. Judge Wright's rulings followed the prevailing law in s**ual hara**ment cases: The defendant's s**ual relationships with others in the workplace, including consensual relationships, are a standard subject of inquiry during the discovery process. Judge Wright recognized the commonplace nature of her discovery rulings and stated that she was following a "meticulous standard of materiality" in allowing such questioning. At a hearing on January 12, 1998, Judge Wright required Ms. Jones to list potential trial witnesses. Ms. Jones's list included several "Jane Does."(1) Ms. Jones's attorneys said they intended to call a Jane Doe named Monica Lewinsky as a witness to support Ms. Jones's claims. Under Ms. Jones's legal theory, women who had s**ual relationships with the President received job benefits because of the s**ual relationship, but women who resisted the President's s**ual advances were denied such benefits.(2) On January 17, 1998, Ms. Jones's lawyers deposed President Clinton under oath with Judge Wright present and presiding over the deposition. Federal law requires a witness testifying under oath to provide truthful answers. The intentional failure to provide truthful answers is a crime punishable by imprisonment and fine.(3) At the outset of his deposition, the President took an oath administered by Judge Wright: "Do you swear or affirm . . . that the testimony you are about to give in the matter before the court is the truth, the whole truth, and nothing but the truth, so help you God?" The President replied: "I do."(4) At the beginning of their questioning, Ms. Jones's attorneys asked the President: "And your testimony is subject to the penalty of perjury; do you understand that, sir?" The President responded, "I do."(5) Based on the witness list received in December 1997 (which included Ms. Lewinsky) and the January 12, 1998, hearing, the President and his attorneys were aware that Ms. Jones's attorneys likely would question the President at his deposition about Ms. Lewinsky and the other "Jane Does." In fact, the attorneys for Ms. Jones did ask numerous questions about "Jane Does," including Ms. Lewinsky. There is substantial and credible information that President Clinton lied under oath in answering those questions. A. Evidence that President Clinton Lied Under Oath During the Civil Case 1. President Clinton's Statements Under Oath About Monica Lewinsky During pretrial discovery, Paula Jones's attorneys served the President with written interrogatories.(6) One stated in relevant part: Please state the name, address, and telephone number of each and every [federal employee] with whom you had s**ual relations when you [were] . . . President of the United States.(7) The interrogatory did not define the term "s**ual relations." Judge Wright ordered the President to answer the interrogatory, and on December 23, 1997, under penalty of perjury, President Clinton answered "None."(8) At the January 17, 1998, deposition of the President, Ms. Jones's attorneys asked the President specific questions about possible s**ual activity with Monica Lewinsky. The attorneys used various terms in their questions, including "s**ual affair," "s**ual relationship," and "s**ual relations." The terms "s**ual affair" and "s**ual relationship" were not specially defined by Ms. Jones's attorneys. The term "s**ual relations" was defined: For the purposes of this deposition, a person engages in "s**ual relations" when the person knowingly engages in or causes . . . contact with the genitalia, an*s, groin, breast, inner thigh, or bu*tocks of any person with an intent to arouse or gratify the s**ual desire of any person. . . . "Contact" means intentional touching, either directly or through clothing.(9) President Clinton answered a series of questions about Ms. Lewinsky, including: Q: Did you have an extramarital s**ual affair with Monica Lewinsky? WJC: No. Q: If she told someone that she had a s**ual affair with you beginning in November of 1995, would that be a lie? WJC: It's certainly not the truth. It would not be the truth. Q: I think I used the term "s**ual affair." And so the record is completely clear, have you ever had s**ual relations with Monica Lewinsky, as that term is defined in Deposition Exhibit 1, as modified by the Court? Mr. Bennett:(10) I object because I don't know that he can remember -- Judge Wright: Well, it's real short. He can -- I will permit the question and you may show the witness definition number one. WJC: I have never had s**ual relations with Monica Lewinsky. I've never had an affair with her.(11) President Clinton reiterated his denial under questioning by his own attorney: Q: In paragraph eight of [Ms. Lewinsky's] affidavit, she says this, "I have never had a s**ual relationship with the President, he did not propose that we have a s**ual relationship, he did not offer me employment or other benefits in exchange for a s**ual relationship, he did not deny me employment or other benefits for rejecting a s**ual relationship." Is that a true and accurate statement as far as you know it? WJC: That is absolutely true.(12) 2. Monica Lewinsky's Testimony Monica Lewinsky testified under oath before the grand jury that, beginning in November 1995, when she was a 22-year-old White House intern, she had a lengthy relationship with the President that included substantial s**ual activity. She testified in detail about the times, dates, and nature of ten s**ual encounters that involved some form of genital contact. As explained in the Narrative section of this Referral, White House records corroborate Ms. Lewinsky's testimony in that the President was in the Oval Office area during the encounters. The records of White House entry and exit are incomplete for employees, but they do show her presence in the White House on eight of those occasions.(13) The ten incidents are recounted here because they are necessary to a**ess whether the President lied under oath, both in his civil deposition, where he denied any s**ual relationship at all, and in his grand jury testimony, where he acknowledged an "inappropriate intimate contact" but denied any s**ual contact with Ms. Lewinsky's breasts or genitalia. When reading the following descriptions, the President's denials under oath should be kept in mind. Unfortunately, the nature of the President's denials requires that the contrary evidence be set forth in detail. If the President, in his grand jury appearance, had admitted the s**ual activity recounted by Ms. Lewinsky and conceded that he had lied under oath in his civil deposition, these particular descriptions would be superfluous. Indeed, we refrained from questioning Ms. Lewinsky under oath about particular details until after the President's August 17 testimony made that questioning necessary. But in view of (i) the President's denials, (ii) his continued contention that his civil deposition testimony was legally accurate under the terms and definitions employed, and (iii) his refusal to answer related questions, the detail is critical. The detail provides credibility and corroboration to Ms. Lewinsky's testimony. It also demonstrates with clarity that the Pres ident lied under oath both in his civil deposition and to the federal grand jury.(14) There is substantial and credible information that the President's lies about his relationship with Ms. Lewinsky were abundant and calculating. (i) Wednesday, November 15, 1995 Ms. Lewinsky testified that she had her first s**ual contact with the President on the evening of Wednesday, November 15, 1995, while she was an intern at the White House. Two times that evening, the President invited Ms. Lewinsky to meet him near the Oval Office.(15) On the first occasion, the President took Ms. Lewinsky back into the Oval Office study, and they kissed.(16) On the second, she performed oral s** on the President in the hallway outside the Oval Office study.(17) During this encounter, the President directly touched and kissed Ms. Lewinsky's bare breasts.(18) In addition, the President put his hand down Ms. Lewinsky's pants and directly stimulated her genitalia (acts clearly within the definition of "s**ual relations" used at the Jones deposition).(19) (ii) Friday, November 17, 1995 Ms. Lewinsky testified that she met with the President again two days later, on Friday, November 17, 1995.(20) During that encounter, Ms. Lewinsky stated, she performed oral s** on the President in the private bathroom outside the Oval Office study.(21) The President initiated the oral s** by unzipping his pants and exposing his genitals. Ms. Lewinsky understood the President's actions to be a sign that he wanted her to perform oral s** on him.(22) During this encounter, the President also fondled Ms. Lewinsky's bare breasts with his hands and kissed her breasts.(23) (iii) Sunday, December 31, 1995 Ms. Lewinsky testified that she met with the President on New Year's Eve, Sunday, December 31, 1995, after the President invited her to the Oval Office.(24) Once there, the President lifted Ms. Lewinsky's sweater, fondled her bare breasts with his hands, and kissed her breasts. She stated that she performed oral s** on the President in the hallway outside the Oval Office study.(25) (iv) Sunday, January 7, 1996 Monica Lewinsky testified that she performed oral s** on the President in the bathroom outside the Oval Office study during the late afternoon on Sunday, January 7, 1996.(26) The President arranged this encounter by calling Ms. Lewinsky at home and inviting her to visit.(27) On that occasion, the President and Ms. Lewinsky went into the bathroom, where he fondled her bare breasts with his hands and mouth. During this encounter, the President stated that he wanted to perform oral s** on Ms. Lewinsky, but she stopped him for a physical reason.(28) (v) Sunday, January 21, 1996 Ms. Lewinsky testified that she and the President had a s**ual encounter on the afternoon of Sunday, January 21, 1996, after he invited her to the Oval Office.(29) The President lifted Ms. Lewinsky's top and fondled her bare breasts.(30) The President unzipped his pants and exposed his genitals, and she performed oral s** on him in the hallway outside the Oval Office study.(31) (vi) Sunday, February 4, 1996 Ms. Lewinsky testified that she and the President had s**ual contact in the Oval Office study and in the adjacent hallway on the afternoon of Sunday, February 4, 1996.(32) That day, the President had called Ms. Lewinsky.(33) During their encounter, the President partially removed Ms. Lewinsky's dress and bra and touched her bare breasts with his mouth and hands. He also directly touched her genitalia.(34) Ms. Lewinsky performed oral s** on the President.(35) (vii) Sunday, March 31, 1996 Ms. Lewinsky testified that she and the President had s**ual contact in the hallway outside the Oval Office study during the late afternoon of Sunday, March 31, 1996.(36) The President arranged this encounter by calling Ms. Lewinsky and inviting her to the Oval Office. During this encounter, Ms. Lewinsky did not perform oral s** on the President. The President fondled Ms. Lewinsky's bare breasts with his hands and mouth and fondled her genitalia directly by pulling her underwear out of the way. In addition, the President inserted a cigar into Ms. Lewinsky's vagina.(37) (viii) Sunday, April 7, 1996 Ms. Lewinsky testified that she and the President had s**ual contact on Easter Sunday, April 7, 1996, in the hallway outside the Oval Office study and in the study itself.(38) On that occasion, the President touched Ms. Lewinsky's breasts, both through her clothing and directly. After the President unzipped his pants, Ms. Lewinsky also performed oral s** on him.(39) This was their last in-person s**ual encounter for over nine months. (ix) Friday, February 28, 1997 Ms. Lewinsky testified that her next s**ual encounter with the President occurred on Friday, February 28, 1997, in the early evening.(40) The President initiated this encounter by having his secretary Betty Currie call Ms. Lewinsky to invite her to the White House for a radio address. After the address, Ms. Lewinsky and the President kissed by the bathroom. The President unbu*toned her dress and fondled her breasts, first with her bra on and then directly. He touched her genitalia through her clothes, but not directly, on this occasion. Ms. Lewinsky performed oral s** on him.(41) On this day, Ms. Lewinsky was wearing a blue dress that forensic tests have conclusively shown was stained with the President's semen.(42) (x) Saturday, March 29, 1997 Ms. Lewinsky testified that she and the President had s**ual contact on the afternoon of March 29, 1997, in the Oval Office study.(43) On that occasion, the President unbu*toned Ms. Lewinsky's blouse and touched her breasts through her bra, but not directly. He also put his hands inside Ms. Lewinsky's pants and stimulated her genitalia.(44) Ms. Lewinsky performed oral s** on him, and they also had brief, direct genital-to-genital contact.(45) (xi) Two Subsequent Meetings Ms. Lewinsky testified that she met with President Clinton in the Oval Office study on the morning of Saturday, August 16, 1997. They kissed, and Ms. Lewinsky touched the President's genitals through his clothing, but he rebuffed her efforts to perform oral s**. No other s**ual acts occurred during this encounter.(46) On Sunday, December 28, 1997, three weeks before the President's civil deposition in the Jones case, the President and Ms. Lewinsky met in the Oval Office. In addition to discussing a number of issues that are an*lyzed below, they engaged in "pa**ionate" kissing -- she said, "I don't call it a brief kiss." No other s**ual contact occurred.(47) 3. Phone Sex Ms. Lewinsky testified that she and the President engaged in "phone s**" approximately fifteen times. The President initiated each phone s** encounter by telephoning Ms. Lewinsky.(48) 4. Physical Evidence Ms. Lewinsky produced to OIC investigators a dress she wore during the encounter on February 28, 1997, which she believed might be stained with the President's semen. At the request of the OIC, the FBI Laboratory examined the dress and found semen stains.(49) At that point, the OIC requested a DNA sample from the President. On August 3, 1998, two weeks before the President's grand jury testimony, a White House physician drew blood from the President in the presence of a senior OIC attorney and a FBI special agent.(50) Through the most sensitive DNA testing, RFLP testing, the FBI Laboratory determined conclusively that the semen on Ms. Lewinsky's dress was, in fact, the President's.(51) The chance that the semen is not the President's is one in 7.87 trillion.(52) 5. Testimony of Ms. Lewinsky's Friends, Family Members, and Counselors During her relationship with the President, Monica Lewinsky spoke contemporaneously to several friends, family members, and counselors about the relationship. Their testimony corroborates many of the details of the s**ual activity provided by Ms. Lewinsky to the OIC. (i) Catherine Allday Davis Catherine Allday Davis, a college friend of Monica Lewinsky's,(53) testified that Ms. Lewinsky told her in late 1995 or early 1996 about Ms. Lewinsky's s**ual relationship with the President.(54) According to Ms. Davis, Ms. Lewinsky told her that the relationship included mutual kissing and hugging, as well as oral s** performed by Ms. Lewinsky on the President. She also stated that the President touched Monica "on her breasts and on her vagina."(55) Ms. Davis also described the cigar incident discussed above.(56) Ms. Davis added that Monica said that she had "phone s**" with the President five to ten times in 1996 or 1997.(57) (ii) Neysa Erbland Neysa Erbland, a high school friend of Ms. Lewinsky's,(58) testified that Ms. Lewinsky told her in 1995 that she was having an affair with President Clinton.(59) According to Ms. Erbland, Ms. Lewinsky said that the s**ual relationship began when Ms. Lewinsky was an intern.(60) Ms. Lewinsky told Ms. Erbland that the s**ual contact included oral s**, kissing, and fondling.(61) On occasion, as Ms. Erbland described it, the President put his face in Ms. Lewinsky's bare chest.(62) Ms. Erbland also said that Ms. Lewinsky described the cigar incident discussed above.(63) Ms. Erbland also understood from Ms. Lewinsky that she and the President engaged in phone s**, normally after midnight.(64) (iii) Natalie Rose Ungvari Ms. Lewinsky told another high school friend, Natalie Rose Ungvari,(65) of her s**ual relationship with the President. Ms. Lewinsky first informed Ms. Ungvari of the s**ual relationship on November 23, 1995. Ms. Ungvari specifically remembers the date because it was her birthday.(66) Ms. Ungvari recalled that Ms. Lewinsky said that she performed oral s** on the President and that he fondled her breasts.(67) Ms. Lewinsky told Ms. Ungvari that the President sometimes telephoned Ms. Lewinsky late at night and would ask her to engage in phone s**.(68) (iv) Ashley Raines Ashley Raines, a friend of Ms. Lewinsky who worked in the White House Office of Policy Development Operations,(69) testified that Ms. Lewinsky described the s**ual relationship with the President. Ms. Raines testified that Ms. Lewinsky told her that the relationship began around the time of the government furlough in late 1995.(70) Ms. Raines understood that the President and Ms. Lewinsky engaged in kissing and oral s**, usually in the President's study.(71) Ms. Lewinsky also told Ms. Raines that she and the President had engaged in phone s** on several occasions.(72) (v) Andrew Bleiler In late 1995, Monica Lewinsky told Andrew Bleiler, a former boyfriend, that she was having an affair with a high official at the White House.(73) According to Mr. Bleiler, Ms. Lewinsky said that the relationship did not include s**ual intercourse, but did include oral s**. She also told Mr. Bleiler about the cigar incident discussed above, and s**ual activity in which the man touched Ms. Lewinsky's genitals and caused her to have an orgasm.(74) (vi) Dr. Irene Ka**orla Dr. Irene Ka**orla counseled Ms. Lewinsky from 1992 through 1997.(75) Ms. Lewinsky told her of the s**ual relationship with the President. Ms. Lewinsky said she performed oral s** on the President in a room adjacent to the Oval Office, that the President touched Ms. Lewinsky causing her to have orgasms, and that they engaged in fondling and touching of one another.(76) The President was in charge of scheduling their s**ual encounters and "became Lewinsky's life."(77) (vii) Linda Tripp When she worked at the Pentagon, Ms. Lewinsky told a co-worker, Linda Tripp, that she had a s**ual relationship with President Clinton.(78) Ms. Tripp stated that Ms. Lewinsky first told her about the relationship in September or October 1996. Ms. Lewinsky told Ms. Tripp that the first s**ual encounter with the President had occurred on November 15, 1995, when Ms. Lewinsky performed oral s** on him. Ms. Lewinsky told Ms. Tripp that, during the course of this s**ual relationship, she performed oral s** on the President, the President fondled Ms. Lewinsky's breasts, the President touched Ms. Lewinsky's genitalia, and they engaged in phone s**.(79) (viii) Debra Finerman Ms. Lewinsky's aunt, Debra Finerman, testified that Monica told her about her s**ual relationship with President Clinton.(80) Ms. Finerman testified that Ms. Lewinsky described a particular s**ual encounter with the President.(81) Ms. Finerman otherwise did not ask and was not told the specifics of the s**ual activity between the President and Ms. Lewinsky.(82) (ix) Dale Young Dale Young, a family friend, testified that Ms. Lewinsky told her that she had engaged in oral s** with President Clinton.(83) (x) Kathleen Estep Kathleen Estep, a counselor for Ms. Lewinsky,(84) met with Ms. Lewinsky on three occasions in November 1996.(85) Based on her limited interaction with Ms. Lewinsky, Ms. Estep stated that she considered Ms. Lewinsky to be credible.(86) During their second session, Ms. Lewinsky told Ms. Estep about her s**ual relationship with President Clinton.(87) Ms. Lewinsky told Ms. Estep that the physical part of the relationship involved kissing, Ms. Lewinsky performing oral s** on the President, and the President fondling her breasts.(88) 6. Summary The detailed testimony of Ms. Lewinsky, her corroborating prior consistent statements to her friends, family members, and counselors, and the evidence of the President's semen on Ms. Lewinsky's dress establish that Ms. Lewinsky and the President engaged in substantial s**ual activity between November 15, 1995, and December 28, 1997.(89) The President, however, testified under oath in the civil case -- both in his deposition and in a written answer to an interrogatory -- that he did not have a "s**ual relationship" or a "s**ual affair" or "s**ual relations" with Ms. Lewinsky. In addition, he denied engaging in activity covered by a more specific definition of "s**ual relations" used at the deposition.(90) In his civil case, the President made five different false statements related to the s**ual relationship. For four of the five statements, the President a**erts a semantic defense: The President argues that the terms used in the Jones deposition to cover s**ual activity did not cover the s**ual activity in which he engaged with Ms. Lewinsky. For his other false statements, the President's response is factual -- namely, he disputes Ms. Lewinsky's account that he ever touched her breasts or genitalia during s**ual activity.(91) The President's denials -- semantic and factual -- do not withstand scrutiny. First, in his civil deposition, the President denied a "s**ual affair" with Ms. Lewinsky (the term was not defined). The President's response to lying under oath on this point rests on his definition of "s**ual affair" -- namely, that it requires s**ual intercourse, no matter how extensive the s**ual activities might otherwise be. According to the President, a man could regularly engage in oral s** and fondling of breasts and genitals with a woman and yet not have a "s**ual affair" with her. Second, in his civil deposition, the President also denied a "s**ual relationship" with Ms. Lewinsky (the term was not defined). The President's response to lying under oath on this point similarly rests on his definition of "s**ual relationship" -- namely, that it requires s**ual intercourse. Once again, under the President's theory, a man could regularly engage in oral s** and fondling of breasts and genitals with a woman, yet not have a "s**ual relationship" with her. The President's claim as to his interpretation of "s**ual relationship" is belied by the fact that the President's own lawyer -- earlier at that same deposition -- equated the term "s**ual relationship" with "s** of any kind in any manner, shape or form." The President's lawyer offered that interpretation when requesting Judge Wright to limit the questioning to prevent further inquiries with respect to Monica Lewinsky. As the videotape of the deposition reveals, the President was present and apparently looking in the direction of his attorney when his attorney offered that statement.(92) The President gave no indication that he disagreed with his attorney's straightforward interpretation that the term "s**ual relationship" means "s** of any kind in any manner, shape, or form." Nor did the President thereafter take any steps to correct the attorney's statement. Third, in an answer to an interrogatory submitted before his deposition, the President denied having "s**ual relations" with Ms. Lewinsky (the term was not defined). Yet again, the President's apparent rejoinder to lying under oath on this point rests on his definition of "s**ual relations" -- that it, too, requires s**ual intercourse. According to President Clinton, oral s** does not constitute s**ual relations. Fourth, in his civil deposition, the President denied committing any acts that fell within the specific definition of "s**ual relations" that was in effect for purposes of that deposition. Under that specific definition, s**ual relations occurs "when the person knowingly engages in or causes contact with the genitalia, an*s, groin, breast, inner thigh, or bu*tocks of any person with an intent to arouse or gratify the s**ual desire of any person."(93) Thus, the President denied engaging in or causing contact with the genitalia, breasts, or an*s of "any person" with an intent to arouse or gratify the s**ual desire of "any person." Concerning oral s**, the President's sole answer to the charge that he lied under oath at the deposition focused on his interpretation of "any person" in the definition. Ms. Lewinsky testified that she performed oral s** on the President on nine occasions. The President said that by receiving oral s**, he would not "engage in" or "cause"(94) contact with the genitalia, an*s, groin, breast, inner thigh, or bu*tocks of "any person" because "any person" really means "any other person." The President further testified before the grand jury: "[I]f the deponent is the person who has oral s** performed on him, then the contact is with -- not with anything on that list, but with the lips of another person."(95) The President's linguistic parsing is unreasonable. Under the President's interpretation (which he says he followed at his deposition), in an oral s** encounter, one person is engaged in s**ual relations, but the other person is not engaged in s**ual relations.(96) Even a**uming that the definitional language can be manipulated to exclude the deponent's receipt of oral s**, the President is still left with the difficulty that reasonable persons would not have understood it that way. And in context, the President's semantics become even weaker: The Jones suit rested on the allegation that the President sought to have Ms. Jones perform oral s** on him. Yet the President now claims that the expansive definition devised for deposition questioning should be interpreted to exclude that very act. Fifth, by denying at his civil deposition that he had engaged in any acts falling within the specific definition of "s**ual relations," the President denied engaging in or causing contact with the breasts or genitalia of Ms. Lewinsky with an intent to arouse or gratify one's s**ual desire. In contrast to his explanations of the four preceding false statements under oath, the President's defense to lying under oath in this instance is purely factual. As discussed above, Ms. Lewinsky testified credibly that the President touched and kissed her bare breasts on nine occasions, and that he stimulated her genitals on four occasions.(97) She also testified about a cigar incident, which is discussed above. In addition, a deleted computer file from Ms. Lewinsky's home computer contained an apparent draft letter to the President that explicitly referred to an incident in which the President's "mouth [was] on [her] breast" and implicitly referred to direct contact with her genitalia.(98) This draft letter further corroborates Ms. Lewinsky's testimony. Ms. Lewinsky's prior consistent statements to various friends, family members, and counselors -- made when the relationship was ongoing -- likewise corroborate her testimony on the nature of the President's touching of her body. Ms. Lewinsky had no apparent motive to lie to her friends, family members, and counselors. Ms. Lewinsky especially had no reason to lie to Dr. Ka**orla and Ms. Estep, to whom she related the facts in the course of a professional relationship. And Ms. Lewinsky's statements to some that she did not have intercourse with the President, even though she wanted to do so, enhances the credibility of her statements. Moreover, the precise nature of the s**ual activity only became relevant after the President interposed his semantic defense regarding oral s** on August 17, 1998. By contrast, the President's testimony strains credulity. His apparent "hands-off" scenario -- in which he would have received oral s** on nine occasions from Ms. Lewinsky but never made direct contact with Ms. Lewinsky's breasts or genitalia -- is not credible. The President's claim seems to be that he maintained a hands-off policy in ongoing s**ual encounters with Ms. Lewinsky, which coincidentally happened to permit him to truthfully deny "s**ual relations" with her at a deposition occurring a few years in the future. As Ms. Lewinsky noted, it suggests some kind of "service contract -- that all I did was perform oral s** on him and that that's all this relationship was."(99) The President also had strong personal, political, and legal motives to lie in the Jones deposition: He did not want to admit that he had committed extramarital s** acts with a young intern in the Oval Office area of the White House. Such an admission could support Ms. Jones's theory of liability and would embarra** him. Indeed, the President admitted that during the relationship he did what he could to keep the relationship secret, including "misleading" members of his family and Cabinet.(100) The President testified, moreover, that he "hoped that this relationship would never become public."(101) At the time of his civil deposition, the President also could have presumed that he could lie under oath without risk because -- as he knew -- Ms. Lewinsky had already filed a false affidavit denying a s**ual relationship with the President. Indeed, they had an understanding that each would lie under oath (explained more fully in Ground VI below). So the President might have expected that he could lie without consequence on the belief that no one could ever successfully challenge his denial of a s**ual relationship with her. In sum, based on all of the evidence and considering the President's various responses, there is substantial and credible information that the President lied under oath in his civil deposition and his interrogatory answer in denying a s**ual relationship, a s**ual affair, or s**ual relations with Ms. Lewinsky.(102)