A. Introduction

This Referral presents substantial and credible information that President Clinton criminally obstructed the judicial process, first in a sexual harassment lawsuit in which he was the defendant and then in a grand jury investigation. The opening section of the Narrative provides an overview of the object of the President's cover-up, the sexual relationship between the President and Ms. Lewinsky. Subsequent sections recount the evolution of the relationship chronologically, including the sexual contacts, the President's efforts to get Ms. Lewinsky a job, Ms. Lewinsky's subpoena in Jones v. Clinton, the role of Vernon Jordan, the President's discussions with Ms. Lewinsky about her affidavit and deposition, the President's deposition testimony in Jones, the President's attempts to coach a potential witness in the harassment case, the President's false and misleading statements to aides and to the American public after the Lewinsky story became public, and, finally, the President's testimony before a federal grand jury.

B. Evidence Establishing Nature of Relationship

1. Physical Evidence

Physical evidence conclusively establishes that the President and Ms. Lewinsky had a sexual relationship. After reaching an immunity and cooperation agreement with the Office of the Independent Counsel on July 28, 1998, Ms. Lewinsky turned over a navy blue dress that she said she had worn during a sexual encounter with the President on February 28, 1997. According to Ms. Lewinsky, she noticed stains on the garment the next time she took it from her closet. From their location, she surmised that the stains were the President's semen.⁽¹⁾
 
 
 

180. Lewinsky 8/26/98 Depo. at 13-14.

181. Lewinsky 8/26/98 Depo. at 13-14; Lewinsky 7/30/98 Int. at 7. One friend understood that Ms. Lewinsky and the President kissed when she brought pizza, and that Ms. Lewinsky performed oral sex on him in a later encounter. Ungvari 3/19/98 GJ at 18-19, 20, 23. One of Ms. Lewinsky's counselors understood that the relationship with the President began at a pizza party. Estep 8/23/98 Int. at 2.

182. Lewinsky 7/30/98 Int. at 7. See also Lewinsky 8/26/98 Depo. at 15.

183. 1472-DC-00000015 (phone logs). Ms. Lewinsky said that this probably was the name she heard on that date. Lewinsky 8/11/98 Int. at 5. She testified that she could not recall whether the President was on the telephone the whole time that she performed oral sex. Lewinsky 8/26/98 Depo. at 14.

184. Clinton 1/17/98 Depo. at 58.

185. Clinton 8/17/98 GJ at 31-32.

186. 827-DC-00000011 (Epass records).

187. 1222-DC-00000179 (movement logs). The President had one telephone call during this period, from 12:53 to 12:58 p.m. 1506-DC-00000029 (phone logs).

197. Clinton 8/17/98 GJ at 31-32.

198. Clinton 8/17/98 GJ at 9-10.

199. Ms. Lewinsky understood that the President may have thought there was something improper in having a sexual relationship with an intern. Lewinsky 8/24/98 Int. at 5.

208. Lewinsky 8/26/98 Depo. at 19.

209. Lewinsky 8/26/98 Depo. at 20. They engaged in oral-anal contact as well. Id.
 

  (Thank you, Judge Starr, for saving America.)