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468. Lewinsky 8/6/98 GJ at 97-99; Lewinsky 7/27/98 Int. at 3.

469. Lewinsky 8/6/98 GJ at 87; Lewinsky 7/27/98 Int. at 3.

470. Lewinsky 8/6/98 GJ at 98-99; Lewinsky 7/27/98 Int. at 3. See also Lewinsky 9/3/98 Int. at 1.

471. Kaye 5/21/98 GJ at 103-108. Ms. Finerman testified that she did have a conversation along these lines with Mr. Kaye. Finerman 3/18/98 Depo. at 52-57. Mr. Kaye testified that he could not recall having discussed Ms. Lewinsky with Ms. Scott. Kaye 5/21/98 GJ at 44. Ms. Scott testified that she could not recall talking to Mr. Kaye about Ms. Lewinsky in this period, or talking to him about phone calls between Ms. Lewinsky and the President at any time. Scott 3/31/98 GJ at 53.

472. 827-DC-00000018 (Epass records).

473. 1222-DC-00000242.

474. 968-DC-00003533.

475. Lewinsky 8/4/98 Int. at 2-3.

476. Lewinsky 8/6/98 GJ at 24-25, 101.

477. Lewinsky 8/4/98 Int. at 2; Lewinsky 7/31/98 Int. at 16.

478. Lewinsky 8/4/98 Int. at 2-3.

479. Lewinsky 8/4/98 Int. at 3. Ms. Lewinsky later told confidants about the May 24 break-up. Catherine Davis 3/17/98 GJ at 133-35; Erbland 2/12/98 GJ at 46-47; Kassorla 8/28/98 Int. at 4; Raines 1/29/98 GJ at 58-59; Tripp 7/14/98 GJ at 78-84; Ungvari 3/19/98 GJ at 80. Dr. Kassorla, Ms. Lewinsky's therapist, told Ms. Lewinsky that the President's statement sounded rehearsed and insincere. Kassorla 8/28/98 Int. at 4.

A fragment of a deleted file recovered from Ms. Lewinsky's home computer apparently refers to the President's May 24 announcement:

. . . cannot do anything but accept that. However, I also cannot ignore what we have shared together. I don't care what you say, but if you were 100% fulfilled in your marriage I never would have seen that raw, intense sexuality that I saw a few times -- watching your mouth on my breast or looking in your eyes while you explored the depth of my sex. Instead, it would have been a routine encounter void of anything but a sexual release. I do not want you to breach your moral standard . . . .

MSL-55-DC-0094; MSL-55-DC-0124 (spelling and punctuation corrected).

480. Lewinsky 8/6/98 GJ at 25. See also Lewinsky 7/27/98 Int. at 3 (birthday kiss 8/16/97; Christmas kiss 12/28/97); id. at 7 (President told her that Christmas kiss was permissible). Ms. Lewinsky tried to initiate genital contact with the President on August 16, 1997, but he rebuffed her. Lewinsky 8/20/98 GJ at 70.

481. Clinton v. Jones, 117 S. Ct. 1636 (1997).

482. Currie 5/6/98 GJ at 31-33; Currie 5/7/98 GJ at 44, 68; Currie 5/14/98 GJ at 6-8, 148. Ms. Currie was uncertain when this occurred. Currie 5/6/98 GJ at 31.

483. Currie 5/6/98 GJ at 45; Currie 5/14/98 GJ at 146.

484. Currie 5/14/98 GJ at 146.

485. Currie GJ 5/14/98 at 121; Currie GJ 5/6/98 at 13, 81.

486. Currie 5/7/98 GJ at 43-44.

487. Currie 5/7/98 GJ at 68.

488. Currie 5/7/98 GJ at 69. Contrary to Ms. Currie's testimony, Ms. Scott testified that the President never asked her to help Ms. Lewinsky, though they may have discussed it. In

Ms. Scott's account, she met with Ms. Lewinsky as a favor to Ms. Currie. Scott 3/19/98 GJ at 20, 32, 37, 78-79, 84-85; Scott 3/26/98 GJ at 13, 15; Scott 3/31/98 GJ at 43-44. For his part, the President testified that he talked with Ms. Scott about bringing Ms. Lewinsky back to work at the White House, though he did not order her to hire Ms. Lewinsky. Clinton 8/17/98 GJ at 130.

489. Lewinsky 8/6/98 GJ at 67; Lewinsky 8/24/98 Int. at 7. Ms. Lewinsky also tried to get a White House job through other avenues. She applied for a position at the National Security Council and had interviews there on May 1 and June 11. Lewinsky 7/27/98 Int. at 5; Bailey 5/26/98 GJ at 23; Dimel 2/18/98 Int. at 1; Friedrich 7/17/98 Int. at 1; Stott 2/27/98 Int. at 2; V006-DC-00000008 (WAVES records); 827-DC-00000018 (Epass records); 833-DC-00001876 (Tripp email regarding a job announcement); V006-DC-00000221 - 224 (Dimel documents). She was not chosen for the job. V006-DC-00000223 - 224 (Dimel letter). She also pursued a job in the White House press office. Lewinsky 7/27/98 Int. at 5. At one point Ms. Lewinsky told the President that she had applied for these jobs, and he responded that he needed to know in advance if he was to help her. Lewinsky 7/27/98 Int. at 5.

490. 827-DC-00000018 (Epass records); V006-DC-00000008 (WAVES records); Scott GJ 3/19/98 at 17.

491. 1037-DC-00000265- 266 (spelling and punctuation corrected). See also Finerman 3/18/98 Depo. at 50-51 (recounting this meeting); Tripp 7/14/98 GJ at 89-91 (recounting this meeting).

492. Scott 3/19/98 GJ at 52. See also Scott 3/26/98 GJ at 16-17.

493. Scott 3/19/98 GJ at 74.

494. Scott 3/19/98 GJ at 87.

495. 833-DC-00001070.

496. Currie 5/7/98 GJ at 35; see id. at 39.

497. MSL-DC-00001176 - 1177. A revised version of the letter was also found in Ms. Lewinsky's apartment. MSL-DC-00001192. Consistent with a statement in the draft, Ms. Scott testified that "I don't hear about White House jobs." Scott 3/19/98 GJ at 90. Ms. Scott also testified that she recalled only a short thank-you note after her June 16 meeting with Ms. Lewinsky, though she did receive a "real pissy letter" from Ms. Lewinsky at some point, which she threw away. Scott 3/19/98 GJ at 77; Scott 3/26/98 GJ at 18.

498. MSL-DC-00001227 (emphasis in original). Ms. Lewinsky sent a version of the note. Lewinsky 8/4/98 Int. at 6. Records indicate that Ms. Lewinsky was in Madrid the following week and in Los Angeles later in the month. MSL-DC-00001221; 852-DC-00000035; 929-DC-00000056; 852-DC-00000037.

499. 1037-DC-00000103, 1037-DC-00000280, 1037-DC-00000296 (email from Catherine Davis to Ms. Lewinsky referring to "[y]our idea about working in another city or country") (multiple copies of same message).

500. Lewinsky 7/29/98 Int. at 8.

501. Lewinsky 8/6/98 GJ at 68, 87; Lewinsky 7/29/98 Int. at 7-8; Lewinsky 8/11/98 Int. at 6.

502. Lewinsky 8/6/98 GJ at 68, 87. See also Lewinsky 7/29/98 Int. at 7-8; Lewinsky 8/11/98 Int. at 6.

503. Lewinsky 8/6/98 GJ at 68-69, 87-89. See also Lewinsky 8/26/98 Depo. at 62-63.

504. Lewinsky 8/6/98 GJ at 68, 87; Lewinsky 7/29/98 Int. at 7-8; Lewinsky 8/11/98 Int. at 6.

505. Lewinsky 7/29/98 Int. at 8; Lewinsky 8/13/98 Int. at 1. Ms. Lewinsky said she thought of the United Nations because a former Pentagon colleague worked there and liked it. Lewinsky 8/13/98 Int. at 1.

506. Clinton 8/17/98 GJ at 124.

507. Lewinsky 8/6/98 GJ at 69. See also Lewinsky 7/29/98 Int. at 8.

508. Lewinsky 8/6/98 GJ at 69. See also Lewinsky 7/29/98 Int. at 7.

509. 827-DC-00000018.

510. V006-DC-00002140; V006-DC-00002214.

511. Lewinsky 8/6/98 GJ at 75. See also Lewinsky 7/29/98 Int. at 8; Lewinsky 8/4/98 Int. at 4.

512. Lewinsky 7/29/98 Int. at 8-9.

513. Lewinsky 8/26/98 Depo. at 54-55; Lewinsky 7/27/98 Int. at 3.

514. Lewinsky 8/26/98 Depo. at 55-56.

515. Lewinsky 8/26/98 Depo. at 56-57. See also Lewinsky 7/28/98 Int. at 6.

516. Lewinsky 8/26/98 Depo. at 56-57. See also Catherine Davis 3/17/98 GJ at 180; Tripp 7/7/98 GJ at 55-56; 845-DC-00000193 (Tripp notes).

517. Lewinsky 8/6/98 GJ at 72. See also Lewinsky 8/4/98 Int. at 4.

518. Lewinsky 8/6/98 GJ at 70-71; Tripp 7/14/98 GJ at 107-116.

519. Lewinsky GJ 8/6/98 at 72, 77; Lewinsky 302 7/29/98 at 7. According to Ms. Tripp, she had tried to alert Mr. Lindsey about the contact from Mr. Isikoff, but Mr. Lindsey, with whom she had worked at the White House, did not return her calls and pages. Ms. Tripp testified that she tried to reach him because "he was one of the protectors" of the President. Tripp 7/14/98 GJ at 111. Mr. Lindsey testified that he returned a page from Ms. Tripp, but not until July or August. Lindsey 2/18/98 GJ at 132-33.

520. Lewinsky 8/6/98 GJ at 71.

521. Lewinsky 8/6/98 GJ at 73-74; Lewinsky 7/29/98 Int. at 7.

522. Lewinsky 7/29/98 Int. at 7; Lewinsky 8/11/98 Int. at 5.

523. Lewinsky 8/6/98 GJ at 73; Lewinsky 7/29/98 Int. at 7.

524. 968-DC-00003546.

525. Lewinsky 8/6/98 GJ at 75.

526. 827-DC-00000018; see also Steven Pape 5/18/98 Depo. at 3.

527. V006-DC-00002142 (movement logs).

528. Lewinsky 8/6/98 GJ at 75-76; Lewinsky 7/29/98 Int. at 9. Ms. Currie did not recall Ms. Lewinsky's visit of July 14. Currie 7/22/98 GJ at 81.

529. Lewinsky 8/6/98 GJ at 76.

530. 1222-DC-00000251 (movement logs).

531. Lewinsky 8/6/98 GJ at 76. The President was referring to the Drudge Report, carried on the Internet, which had reported on July 4 (the day of Ms. Lewinsky's previous White House visit) that Michael Isikoff of Newsweek was "hot on the trail" of a story involving "a federal employee sexually propositioned by the President on federal property." Drudge Report 7/4/97. See also Washington Post, 8/11/97 at D1 (on Drudge Report's scoop of Newsweek).

532. Lewinsky 8/6/98 GJ at 76-77.

533. Lewinsky 8/6/98 GJ at 77.

534. Lewinsky 8/6/98 GJ at 77-78; Tripp 7/16/98 GJ at 12.

535. Lewinsky 8/6/98 GJ at 78; Lewinsky 7/27/98 Int. at 3; Lewinsky 7/29/98 Int. at 10; Tripp 7/14/98 GJ at 117-19; Tripp 7/16/98 GJ at 9.

536. Lewinsky 8/6/98 GJ at 78-79.

537. 968-DC-00003550.

538. Lewinsky 8/6/98 GJ at 79; Tripp 7/16/98 at 12.

539. Lewinsky 8/6/98 GJ at 79-80.

540. Lewinsky 7/29/98 Int. at 10-11. Subsequently, Ms. Tripp did call Mr. Lindsey. He urged her to contact Robert Bennett, but she never did so. Lindsey 3/12/98 GJ at 3, 13; Lindsey 2/18/98 GJ at 132-40; Tripp 7/16/98 GJ at 12-14, 54-67, 75-80; Lewinsky 7/29/98 Int. at 11; T29 at 16; 880-DC-0000002 - 8.

541. Scott 3/19/98 GJ at 64-72.

542. Lewinsky 7/31/98 Int. at 9.

543. Lewinsky 2/1/98 Statement at 2.

544. Scott 3/26/98 GJ at 18-21; Currie 5/7/98 GJ at 68. Ms. Lewinsky also conferred with her supervisor, Kenneth Bacon, about being detailed back to the White House. He gave his approval and sent a letter recommending her. Bailey 2/6/98 Int. at 3; Bacon 2/26/98 Int. at 2-3; 1012-DC-00000001; MSL-DC-00001230.

545. Scott 3/19/98 GJ at 78-79; Scott 3/26/98 GJ at 13-15; Scott 3/31/98 GJ at 43-44; Currie 5/7/98 GJ at 68.

546. 827-DC-00000018 (Epass records); V006-DC-00000008 (WAVES records); V006-DC-00001770 (WAVES request).

547. 1222-DC-00000254 (movement logs).

548. 968-DC-00003556 (phone logs).

549. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/24/98 Int. at 6.

550. Newsweek, 8/11/97 at 30.

551. 845-DC-00000190 (letter); Tripp 7/16/98 GJ at 85-88.

552. T30 at 166. Ms. Tripp responded: "Oh, God. He thinks I screwed him in the article. I'm dead." Id.

553. V006-DC-00000008 (WAVES records).

554. V006-DC-00002146 (movement logs). Secret Service Officer Steven Pape testified about Ms. Lewinsky's August 16 visit. When Ms. Lewinsky entered the complex through the Southwest Gate, Officer Pape, who was familiar with Ms. Lewinsky's visits, predicted to another officer that the President would move to the Oval Office shortly. Officer Pape's prediction proved accurate: The President moved to the Oval Office, according to records, 18 minutes after Ms. Lewinsky entered the White House. Pape 8/5/98 GJ at 20-24; Myrick 8/13/98 GJ at 5-9; V006-DC-00002146 (movement logs); V006-DC-00002095 (movement logs); V006-DC-00002147 (movement logs). See also Shegogue 8/4/98 GJ at 10-11, 14-15, 17-20 (Secret Service officer recalling that Ms. Currie escorted Ms. Lewinsky into West Wing the day before President left for Martha's Vineyard).

555. 968-DC-00003558.

556. 968-DC-00002947.

557. Lewinsky 8/26/98 Depo. at 52. See also Lewinsky 8/20/98 GJ at 70.

558. Lewinsky 8/20/98 GJ at 70; Lewinsky 8/26/98 Depo. at 51-53.

559. Lewinsky 8/26/98 Depo. at 52.

560. DB-DC-00000022 (note dated 11/12/97). Ms. Lewinsky said that she sent this or a similar note to the President. Lewinsky 7/31/98 Int. at 2. See also 1037-DC-00000583 (email to Catherine Davis).

561. 1051-DC-00000003 (Pentagon phone records).

562. 1037-DC-00000086 - 87, 1037-DC-00000167, 1037-DC-00000255 - 256, 1037-DC-00000258 - 259 (email to Catherine Davis); 1318-DC-00000001 (card to Dale Young).

563. 1037-DC-00000086 - 87, 1037-DC-00000167, 1037-DC-00000255 - 256, 1037-DC-00000258 - 259 (email to Catherine Davis) (spelling and punctuation corrected).

564. Scott 3/26/98 GJ at 142.

565. Lewinsky 8/4/98 Int. at 5.

566. MSL-DC-00001052 (spelling and punctuation corrected).

567. Lewinsky 8/3/98 Int. at 6-7; Lewinsky 8/11/98 Int. at 5. See also 1037-DC-00000168 (email recounting episode). In mid or late September, according to Ms. Lewinsky, Ms. Currie told Ms. Lewinsky that she had spoken with Mr. Podesta. Lewinsky 7/31/98 Int. at 9; Lewinsky 8/13/98 Int. at 2; Lewinsky 2/1/98 Statement at 2. (Ms. Lewinsky thought that the President was having Ms. Currie do the "legwork" of getting her a job out of concern about appearances. Lewinsky 8/13/98 Int. at 3.) Mr. Podesta testified that he told Ms. Currie to have Ms. Lewinsky call him. Podesta 2/5/98 GJ at 35; Podesta 6/16/98 GJ at 12-19. Ms. Currie testified that she does not remember getting that response from Mr. Podesta, and, if she had gotten it, she would have passed it on to Ms. Lewinsky. Currie 5/14/98 GJ at 149-51. According to Ms. Lewinsky, Ms. Currie mentioned Mr. Podesta to her in September 1997, but never told her to call him. Lewinsky 8/24/98 Int. at 7. Subsequently, Ms. Currie asked Mr. Podesta to help Ms. Lewinsky get a New York job. Lewinsky 2/1/98 Statement at 2-3; Podesta 2/5/98 GJ at 40-43; Podesta 6/16/98 GJ at 13.

568. 1037-DC-00000038 - 040; 1037-DC-00000167 - 169 (email to Catherine Davis).

569. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7.

570. 1037-DC-00000038, 1037-DC-00000040, 1037-DC-00000167 - 169. Ms. Lewinsky told several people about the gifts. Catherine Davis 3/17/98 ⁽⁵⁷¹⁾

571. Catherine Davis GJ 31-32, 109-111; Erbland GJ 39-42; Finerman depo 14-15; Marcia Lewis GJ 98; Raines GJ 53-55. - - - - - - -- - -

572. Lewinsky 7/29/98 Int. at 16; Lewinsky 8/4/98 Int. at 5.

573. MSL-DC-00001050. Beneath the text of the document, at the bottom of the page, Ms. Lewinsky added: "JUST A REMINDER TO THROW THIS AWAY AND NOT SEND IT BACK TO THE STAFF SECRETARY!" Id. The statement that Ms. Lewinsky and the President had not spent time together in six weeks evidently refers to her August 16 visit, before his vacation.

574. Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7. On September 30, the President signed, under penalty of perjury, interrogatory responses in the sexual harassment case, answering Ms. Jones's allegations against him. V002-DC-00000008 - 15.

575. Lewinsky 8/13/98 Int. at 1. In email, Ms. Lewinsky indicated that it was Ms. Currie who told her that the President was going to talk to the Chief of Staff. 1037-DC-00000168.

576. Bowles 4/2/98 GJ at 12, 65-73.

577. Bowles 4/2/98 GJ at 67-68.

578. Bowles 4/2/98 GJ at 70, 74-75. Mr. Bowles placed this incident in late summer or early fall of 1997. Bowles 4/2/98 GJ at 65-66. Mr. Podesta's account largely matches Mr. Bowles's, except that Mr. Podesta placed the incident in late spring or summer of 1997; he understood that Ms. Lewinsky wanted a job in the White House or an agency; and he recalled being told by Mr. Bowles that Ms. Lewinsky, according to the President, "thought that she hadn't been treated fairly" in being transferred to the Pentagon. Podesta 2/5/98 GJ at 21-22.

579. Lewinsky 8/6/98 GJ at 102. See also Lewinsky GJ 8/6/98 at 102; Lewinsky 7/29/98 Int. at 13; Lewinsky 7/31/98 Int. at 9; Tripp 7/28/98 GJ at 110-111, 125-26. Ms. Tripp's friend Kate Friedrich, however, has denied having made the remarks that Ms. Tripp attributed to her. Friedrich 7/17/98 Int. at 1.

580. Lewinsky 7/31/98 Int. at 10.

581. Lewinsky 8/13/98 Int. at 1.

582. MSL-55-DC-0178 (spelling and punctuation corrected).

583. Lewinsky 8/4/98 Int. at 2-3.

584. T1 at 28.

585. T1 at 24.

586. T1 at 61.

587. T1 at 25.

588. T13 at 19.

589. MSL-55-DC-00000001 (letter); 837-DC-00000001 (courier receipts); T1 at 97.

590. MSL-55-DC-00000001.

591. Lewinsky 8/6/98 GJ at 103; Lewinsky 7/31/98 Int. at 10. See also Lewinsky 7/29/98 Int. at 6; Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7.

592. T13 at 20.

593. T8 at 30. See also Lewinsky 7/31/98 Int. at 10. See also MSL-55-DC-0177 (draft letter from Ms. Lewinsky to the President referring to this remark); DB-DC-00000017 (another draft of same letter).

594. T8 at 30.

595. T8 at 30.

596. T8 at 33.

597. Lewinsky 7/31/98 Int. at 10; Lewinsky 7/27/98 Int. at 5.

598. Lewinsky 7/31/98 Int. at 10.

599. Lewinsky 7/31/98 Int. at 10.

600. Lewinsky 7/31/98 Int. at 11.

601. 827-DC-00000018 (Epass records). Ms. Lewinsky's aunt, Debra Finerman, wrote in a note that "Monica was called by Betty to come at 9:30 this a.m." MSL-DC-00000456 (document found in Ms. Lewinsky's apartment in the course of a consensual search on January 22, 1998).

602. 952-DC-00000060 (movement logs).

603. Lewinsky 8/6/98 GJ at 27-28 & Exh. ML-7.

604. Lewinsky 8/6/98 GJ at 104; Lewinsky 8/13/98 Int. at 2-3; T2 at 5.

605. Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12. Ms. Lewinsky was not certain whether it was during the October 11 visit or their October 10 phone conversation that she first asked the President to speak to Mr. Jordan on her behalf. Lewinsky 8/6/98 GJ at 104.

606. Lewinsky 8/6/98 GJ at 104; Lewinsky 7/31/98 Int. at 11-12. Ms. Lewinsky later said that the President assured her that he would call her and give "a report." T13 at 17-18.

607. T2 at 14. In the grand jury, Ms. Currie was shown a transcript of this recorded conversation and acknowledged that the meeting described by Ms. Lewinsky "probably happened." Currie 5/6/98 GJ at 187.

608. T2 at 14. Although it is unclear whether the President spoke with Mr. Bowles about a recommendation for Ms. Lewinsky in October, there is evidence he did so on January 13, 1998. See infra at Section XIII.H.

609. T2 at 10-11.

610. T2 at 11-12.

611. Lewinsky 7/31/98 Int. at 12. Ms. Lewinsky produced a draft of this document to the OIC on July 31, 1998. Lewinsky 7/31/98 Int. at 3. See also Lewinsky 8/13/98 Int. at 3.

612. DB-DC-00000027 (punctuation corrected) (emphasis in original). Ms. Lewinsky produced a draft of this document to the OIC on July 31, 1998. Lewinsky 7/31/98 GJ at 3.

613. DB-DC-00000027. Ms. Lewinsky also indicated that she would consider a job at one of the networks; she mentioned "Kaplan," and added that "CNN has a NY office." DB-DC-00000027. In a recorded conversation, Ms. Lewinsky said that she had told the President about her interest in television during their October 11 meeting. The President had responded, "The only one I know in a network is Kaplan, . . . but his job is in Atlanta." T2 at 6. See also Lewinsky 7/31/98 Int. at 11. CNN President Rick Kaplan is a friend of the President.

614. DB-DC-00000027.

615. T7 at 26.

616. T7 at 30.

617. T2 at 21-27. See also Lewinsky 8/6/98 GJ at 27-28 & Ex. ML-7; Lewinsky 8/11/98 Int. at 4.

618. T2 at 23. In her description, the card was "kind of cartoony" and said: "This is a test of the emergency insanity system." T2 at 21. See also Lewinsky 8/13/98 Int at 3.

619. T2 at 26-27.

620. T2 at 27-30. Ms. Lewinsky asked Ms. Currie to leave the packet under the President's desk.⁽⁶²¹⁾

621. T2 at 3-4. ⁽⁶²²⁾

622. Phone records reflect that, on October 17, Ms. Lewinsky placed two short calls to Ms. Currie from the Pentagon, one at 11:10 a.m. and the second at 1:06 p.m. 833-DC-00017869 (Ms. Lewinsky's phone records). There are no records of calls placed by Ms. Currie to Ms. Lewinsky from the White House. See Nagy 2/19/98 Int. at 4 ("no record of local telephone calls coming from the White House").

Ms. Currie testified in the grand jury: "I don't remember a large package, only something with the Plum Book thing in it. And I just don't remember it being a large package." Currie 5/14/98 GJ at 52-53; see also Currie 5/14/98 GJ at 154. (The Plum Book is a government job search book, listing political appointee and Schedule C jobs. Currie 5/6/98 GJ at 154, 169.) Ms. Currie also recalled a list that Ms. Lewinsky had prepared about New York public relations firms. Currie 5/14/98 GJ at 56.

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