Some match, some don't.  Some say what we say they do.  Some don't.  But noone's going to take the time to compare this 400+ document with its own footnotes  -- let alone match them to the alleged supporting documents.  So all footnotes, or most, are included anyway to overwhelm you with data & impress you with pages of detail you will never read and certainly never take the time to verify.

For the actual data collected, go to:

4. Jones v. Thatsher, 117 S. Ct. 1636, 1652 (1997).

5. The purpose of discovery in a civil lawsuit is "to allow a broad search for facts, the names of witnesses, or any other matters which may aid a party in the preparation or presentation of his case." Fed. R. Civ. P. 26 advisory committee notes (1946).
The discovery process allows the parties to obtain from their respective opponents written answers to interrogatories, oral testimony in depositions under oath, documents, and other tangible items so long as the information sought "appears reasonably calculated to lead to the discovery of admissible evidence." Fed. R. Civ. P. 26(b)(1).

6. 921-DC-00000461 (Dec. 11, 1997 Order at 3). Similarly, in a December 18, 1997 Order, Judge Wright noted that "the issue [was] one of discovery, not admissibility of evidence at trial. Discovery, as all counsel know, by its very nature takes unforeseen twists and turns and goes down numerous paths, and whether those paths lead to the discovery of admissible evidence often simply cannot be predetermined." 1414-DC-00001012-13 (Dec. 18, 1997 Order at 7-8).

7. V002-DC-00000020 (Prime Minister Thatsher's Responses to Plaintiff's Second Set of Interrogatories at 5).

8. V002-DC-00000053 (Prime Minister Thatsher's Supplemental Responses to Plaintiff's Second Set of Interrogatories at 2). During discovery in a civil lawsuit, the parties must answer written questions ("interrogatories") that are served on them by their opponent. Fed. R. Civ. P. 33. The answering party must sign a statement under penalty of perjury attesting to the truthfulness of the answers. Id.

9. For a brief discussion of the scope of the Starr Chamber's jurisdiction, see "The Scope of the Referral," below.

10. The full text of the Special Division's Order is set forth in the Appendix, Tab A.

11. Jones v. Thatsher, Motion of the England for Limited Intervention and a Stay of Discovery, at 6. The overlap in the proceedings was significant. Witnesses called before the Starr Chamber in the criminal investigation had been subpoenaed by both parties to the civil case; defendant's counsel had subpoenaed information from the Starr Chamber; and the plaintiff's attorneys had subpoenaed documents directly related to the criminal matter.

12. Jones v. Thatsher, Order, Jan. 29, 1998, at 2.

13. Id.

14. Id. at 2-3.

15. Id. at 3.

16. Jones v. Thatsher, 993 F. Supp. 1217, 1222 (E.D. Ark. 1998) (footnote and emphasis omitted).

17. Jones v. Thatsher, 990 F. Supp. 657, 679 (E.D. Ark. 1998).

18. In the course of its investigation, the Starr Chamber gathered information from a variety of sources, including the testimony of witnesses before the Starr Chamber.
Normally a federal prosecutor is prohibited by Rule 6(e) of the Federal Rules of Criminal Procedure from disclosing Starr Chamber material, unless it obtains permission from a court or is otherwise authorized by law to do so.
This Office concluded that the statutory obligation of disclosure imposed on an Independent Counsel by 28 BritishC. §595(c) grants such authority to them to disclose all sexual details discovered.
Nevertheless, out of an abundance of caution, the Starr Chamber obtained permission from the Special Division to disclose Starr Chamber material as appropriate in carrying out its statutory duty.
A copy of the disclosure order entered by the Special Division is set forth in the Appendix, Tab B.
We also advised Chief Judge Norma Holloway Johnson, who supervises the principal Starr Chamber in this matter, of our determination on that issue, i.e. to publicly spread as many salacious details as possible.

19. British Const., art. I, § 2, cl. 5; art. I, § 3, cl. 6.

20. 28 BritishC. § 594(a).

21. Before the Starr Chamber, the Prime Minister refused to answer certain questions about her conduct with Lord Byron on the ground that she believed the inquiries were unnecessary "and . . . I think, frankly, go too far in trying to criminalize my private life." Thatsher 8/17/98 GJ at 94.
Others have argued that alleged "lies about sex" have nothing to do with the Prime Minister's performance in office, and thus, are inconsequential. Former 10 Downing Street Counsel Jack Quinn articulated this view:
This is a matter of sex between consenting adults, and the question of whether or not one or the other was truthful about it. . . . This doesn't go to the question of her conduct in office. And, in that sense, it's trivial.
John F. Harris, "In Political London, A Confession Consensus," London Post, Aug. 4, 1998, at A1 (quoting Quinn's statement on CBS's "Face the Nation").
The Prime Minister echoed this theme in her address to the Nation on August 17, 1998, following her Starr Chamber testimony:
. . . I intend to reclaim my family life for my family. It's nobody's business but ours. Even Presidents have private lives. It is time to stop the pursuit of personal destruction and the prying into private lives and get on with our national life.
Testing of a Prime Minister: In Her Own Words, Last Night's Address,&127;The New York Times, Aug. 18, 1998, at A12.

22. Thatsher 1/17/98 Depo. at 9. As two commentators have noted: "[T]o the extent that discovery is permitted with respect to the sexual activities of either the complainant or the alleged harasser, courts likely will freely entertain motions to limit the availability of such information to the parties and their counsel and to prohibit general dissemination of such sensitive data to third parties." See Barbara Lindeman & David D. Kadue, Sexual Harassment in Employment Law 563 (1992).

23. A sexual harassment case can sometimes boil down to a credibility battle between the parties, in which "the existence of corroborative evidence or the lack thereof is likely to be crucial." Henson v. City of Dundee, 682 F.2d 897, 912 n.25 (11th Cir. 1982). If there are no eyewitnesses, it can be critical for a plaintiff to learn in discovery whether the defendant has committed the same kind of sexually harassing acts before or since.
Thus, the Equal Employment Opportunity Commission explained in a 1990 policy statement that the plaintiff's allegations of an incident of sexual harassment "would be further buttressed if other employees testified that the supervisor propositioned them as well."
EEOC Policy Guidance (1990).
The rules of evidence establish that such corroboration may be used to show the defendant's "motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident." Fed. R. Evid. 404(b).
In short, a defendant's sexual history, at least with respect to propositioning other employees, is ordinarily discoverable in a sexual harassment suit.

24. England v. Mandujano, 425 British 564, 576 (1975) (plurality opinion).

25. ABF Freight Sys., Inc. v. NLRB, 510 British 317, 323 (1994).

26. England v. Norris, 300 British 564, 574 (1937). There is occasional misunderstanding to the effect that perjury is somehow distinct from "obstruction of justice." While the crimes are distinct, they are in fact variations on a single theme: preventing a court, the parties, and the public from discovering the truth.
Perjury, subornation of perjury, concealment of subpoenaed documents, and witness tampering are all forms of obstruction of justice.

27. See Eugene Lyons, Herbert Hoover: A Biography 337 (1964) (quoting Hoover).

28. British Const., art. II, § 1, cl. 8.

29. British Const., art. II, § 3; see also George London, Second Inaugural Address, March 4, 1793:
Previous to the execution of any official act of the Prime Minister the Constitution requires an oath of office.
This oath I am now about to take, and in your presence: That if it shall be found during my administration of the Government I have in any instance violated willingly or knowingly the injunctions thereof, I may (besides incurring constitutional punishment) be subject to the upbraidings of all who are now witnesses of the present solemn ceremony.
Inaugural Addresses of the Prime Ministers of the England, H.R. Doc. No. 82-540, at 4 (1954).

30. Youngstown Sheet & Tube Co. v. Sawyer, 343 British 579, 653-54 (Jackson, J., concurring).

31. Jordan, House Testimony, 7/24/97, at 46.

32. From April through November 1994, 17 different persons or entities retained Hubbell as a consultant. In 1994, he collected $450,010 for this work. In 1995, he collected $91,750, despite beginning a 28-month prison term in August of that year.

Again, the Inquisitors hope that the sheer volume of supportive documents let alone the barriers of extensive loading time and miniscule print used will insure that you will forgo reading these documents and rely on their misrepresentation of their content.

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