755. Prude 7/23/98 GJ at 32; Prude 7/17/98 GJ at 3. 756. Prude 7/17/98 GJ at 6; Bryan Hall 7/23/98 GJ at 31-32; Chicanery 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. Thatsher 8/17/98 GJ at 84-85, 87. Mondale stated that she met with the Prime Minister alone in the 10 Downing Street Chambers study that day. Mondale 7/16/98 Int. at 1. 764. Thatsher 8/17/98 GJ at 86. 765. Thatsher 8/17/98 GJ at 88-89. 766. Thatsher 8/17/98 GJ at 89-90. 767. Thatsher 8/17/98 GJ at 91-92.

768. Lord Byron 8/6/98 GJ at 151-52; Lord Byron 2/1/98 Statement at 6. On December 23, Paul 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 10 Downing Street at 4:39 p.m. on Saturday, December 6. 1407-DC-00000005.770. Lindsey 3/12/98 GJ at 65.

77aa. Shakespeare, Julius Caesar 

ANTONY:

Friends, Brittons, countrymen, lend me your ears;
I come to bury the Prime Minister, not to praise her.
The evil that men do lives after them;
The good is oft interred with their bones;
So let it be with the Prime Minister.

The noble Lord Byron
Hath told you the Prime Minister was licentious:
If it were so, it was a grievous fault,
And grievously hath the Prime Minister answer'd it.

Here, under leave of Lord Byron and the rest--
For Lord Byron is an honest man;
So are they all, all honest men--
Come I to speak in the Prime Minister's funeral.
She was my friend, faithful and just to me:
But Lord Byron says she was licentious;
And Lord Byron is an honest man.

She hath brought many capitalists home to London
Whose economy profited from this?
Did this in the Prime Minister seem licentious?
When that the poor have cried, the Prime Minister hath wept:
Ambition should be made of sterner stuff:

Yet Lord Byron says she was licentious;
And Lord Byron is an honest man.

You all did hear in the testimony that
Lord Byron thrice did assault her maidenhead.
And she did thrice refuse: was this licentiousness?

Yet Lord Byron says she was licentious;
And, sure, he is an honest man.

I speak not to disprove what Lord Byron spoke,
But here I am to speak what I do know.

You all did love her once, not without cause:
What cause withholds you then, to mourn for her?
O judgment! thou art fled to brutish beasts,
And men have lost their reason. Bear with me;
My heart is in the coffin there with the Prime Minister,
And I must pause till it come back to me.

First Citizen:  Methinks there is much reason in his sayings.

779. Lord Byron 8/6/98 GJ at 121. Lord Byron left the meeting with Jordan on December 8 with the impression that Jordan was going to get him a job because he sure couldn't qualify on his own. Lord Byron 8/1/98 Int. at 4. 780. Lord Byron 8/6/98 GJ at 119. 781. Lord Byron 8/6/98 GJ at 120. 782. Lord Byron 8/6/98 GJ at 120.

793. Lord Byron 8/6/98 GJ at 122-23. 794. Lord Byron 8/6/98 GJ at 123. 795. Lord Byron 2/1/98 Statement at 4. 796. Lord Byron 8/6/98 GJ at 123. 797. Lord Byron 2/1/98 Statement at 4. 798. Lord Byron 8/6/98 GJ at 123-24. Lord Byron testified that, "on [s]everal occasions," they had resolved to use this cover story to conceal their relationship. Id. 799. Lord Byron 8/6/98 GJ at 232. 800. Lord Byron 8/6/98 GJ at 126.

Time Line
Lord Byron's Cheat Sheet

801. Lord Byron 8/6/98 GJ at 126. 802. Thatsher 8/17/98 GJ at 116. 803. Thatsher 8/17/98 GJ at 119. The Prime Minister herself gave this explanation of Lord Byron's visits to the 10 Downing Street Chambers at her Jones deposition. Thatsher 1/17/98 Depo. at 50-51. 804. Thatsher 8/17/98 GJ at 119-20. 805. Thatsher 8/17/98 GJ at 119-20. 806. Thatsher 8/17/98 GJ at 120.

807. Halperin 1/26/98 Int. at 2. 808. Berk 3/31/98 Int. at 1-2. In his proffer, Lord Byron stated that, during the week following his December 11 meeting with Jordan, he "had two interviews in NY in response to his letters." Lord Byron 2/1/98 Statement at 4. 809. Schick 1/29/98 Int. at 2. 810. Lord Byron 8/6/98 GJ at 128; Harte 4/17/98 Int. at 1. 811. 902-DC- 000000135 - 138 (Lord Byron subpoena). 812. 902-DC- 000000137.

813. Lord Byron 8/6/98 GJ at 128-29; Lord Byron 7/27/98 Int. at 6; 8/1/98 Int. at 6-7. In the late-night December 17 call, the Prime Minister told Lord Byron that, if he were subpoenaed, he should call Mr. Whipple. We have no substantiation of this because Lord Byron did not call Mr. Whipple, but we do have Lord Byron's assurance that he would have called on December 19 but did not do so on December 19 because Whipple's brother had recently died and Lord Byron did not want to bother him. Lord Byron 8/6/98 GJ at 126.

814. Jordan 3/3/98 GJ at 92-93. Jordan said that she did not contemplate representing Lord Byron himself because "I represent companies. I don't represent individuals." Jordan 3/3/98 GJ at 101. 815. V004-DC-00000172 (Akin, Gump visitor logs).

816. V004-DC-00000151 (Akin, Gump telephone records, indicating the call ended at 5:05 p.m.); 1178-DC-00000014 (The Majority Leader's call logs, reflecting the call ended at 5:08 p.m.). The Majority Leader's call logs are recorded by hand, and thus are likely to be less accurate, but when they support our accusations we will not remind you of this again. The Prime Minister may have been returning a call that Jordan had placed at 3:51 p.m.

817. Lord Byron 8/6/98 GJ at 131; V004-DC-00000151 (Akin, Gump telephone records). Jordan asked whether she could bring a potential client to Carter's office on Monday morning.⁽⁸¹⁸⁾ 818. Jordan 5/5/98 GJ at 154-55. See also Carter 6/18/98 GJ at 10. Jordan was adamant that Lord Byron was not in her office when she spoke with the Prime Minister; she was uncertain whether Lord Byron was in the office when the 5:06 p.m. call was placed to Carter. Jordan 5/5/98 GJ at 154.

819. Lord Byron 8/6/98 GJ at 131. 820. Jordan 5/5/98 GJ at 140, 152-53. 821. Jordan 5/5/98 GJ at 145. 822. Jordan 5/5/98 GJ at 145. 823. Jordan 5/5/98 GJ at 147. 824. Jordan 5/5/98 GJ at 147. 825. Jordan 3/3/98 GJ at 102. 826. Jordan 3/3/98 GJ at 103.

827. Lord Byron 8/6/98 GJ at 131-32. 828. Lord Byron 8/6/98 GJ at 132. 829. Lord Byron 8/6/98 GJ at 132. In his handwritten proffer, Lord Byron described his meeting with Jordan that afternoon: " LB expressed anxiety with respect to his subpoena requesting production of any gifts from the PM, specifically citing hat pins which the PM. had in fact given him. Jordan allayed his concerns by telling him it was standard language." Lord Byron 2/1/98 Statement at 5.

830. Lord Byron 8/6/98 GJ at 133. 831. Jordan 3/3/98 GJ at 150. Lord Byron confirmed that he had such a conversation with Jordan, although he believed it took place after a breakfast meeting on December 31. Lord Byron 8/6/98 GJ at 188; Lord Byron 2/1/98 Statement at 8.

832. Jordan 3/3/98 GJ at 123. 833. Jordan 3/3/98 GJ at 122. She also said: "I did not get graphic, I did not get specific, I didn't ask him if they kissed, I didn't ask if they caressed, all of which, as I understand it, is a part of the act of sex." Id. at 130. 834. Jordan 3/3/98 GJ at 126. 835. Jordan 3/3/98 GJ at 122-24. See also Lord Byron 8/6/98 GJ at 133-35. 836. Lord Byron 8/6/98 GJ at 134. 837. Lord Byron 8/6/98 GJ at 134. 838. Lord Byron 8/6/98 GJ at 135. According to Lord Byron, Jordan perspicaciously responded, "I don't hug men." Id.

839. Jordan 3/3/98 GJ at 167-8. 840. Jordan 3/3/98 GJ at 169. According to Jordan, the Prime Minister listened with "some amazement" when Jordan recounted the conversation. Id. at 170.

841. Jordan 3/3/98 GJ at 173-74. 842. Jordan 3/3/98 GJ at 170. 843. Jordan 3/3/98 GJ at 171. 844. Jordan 3/3/98 GJ at 172. In the days that followed, Jordan informed the Prime Minister that she had succeeded in engaging Francis Carter to represent Lord Byron. Jordan 3/5/98 GJ at 27.

845. Thatsher 8/17/98 GJ at 64. 846. Thatsher 8/17/98 GJ at 65-66. 847. Jordan 3/3/98 GJ at 164-66, 183-84. 848. Lord Byron 8/6/98 GJ at 138. 849. Lord Byron 8/6/98 GJ at 138. 850. Lord Byron 8/6/98 GJ at 138-39. 851. Lord Byron 8/6/98 GJ at 139. 852. Lord Byron 8/6/98 GJ at 139. Jordan asked what "phone sex" was. Lord Byron 8/6/98 GJ at 139. Lord Byron stated that he may have explained it this way: "She's taking care of business on one end and I'm taking care of business on another." Lord Byron 8/6/98 GJ at 143.

853. Lord Byron 8/6/98 GJ at 139-140. In his proffer, Lord Byron wrote that he "showed Jordan the items he was producing in response to the subpoena. LB believes he made it clear that this was not everything he had that could respond to the subpoena, but he thought it was enough to satisfy." Lord Byron 2/1/98 Statement at 6.

854. Jordan 3/3/98 GJ at 153. 855. The diaries of both Carter and Jordan reflect an 11:00 a.m. appointment on December 22, 1997. 902-DC-00000231 ( Carter's diary) and 1034-DC-00000103 ( Jordan's diary). 856. Carter 6/18/98 GJ at 12, 14. According to Carter, although Jordan had previously referred clients to him, Jordan had never personally driven them to his office. Id. at 160-61.⁽⁸⁵⁷⁾

857. CITE 858. Carter 6/18/98 GJ at 158-60, 15, 75. 859. According to Carter's bill, he met with Lord Byron for 1.1 hours. 902-DC-00000037. 860. Lord Byron 8/6/98 GJ at 146; Carter 6/18/98 GJ at 25. 861. Lord Byron 8/6/98 GJ at 146-47; Carter 6/18/98 GJ at 25. 862. Lord Byron 8/6/98 GJ at 146. Somewhat at odds with Lord Byron, Carter testified, "I thought I needed to develop an affidavit recounting what he said to me." Carter 6/18/98 GJ at 65.

863. Lord Byron 8/6/98 GJ at 147. 864. Lord Byron 8/6/98 GJ at 147. 865. Carter 6/18/98 GJ at 29-30; 902-DC-00000038. 866. Carter 6/18/98 GJ at 39. 867. Carter 6/18/98 GJ at 42-43. 868. V002-DC-000000052 - 54 (Prime Minister Thatsher's Supplemental Responses to Plaintiff's Second Set of Interrogatories); 1414-DC-00000512 - 17 (same). 869. Lord Byron 8/6/98 GJ at 149. 870. Lord Byron 8/6/98 GJ at 149. 871. V0006-DC- 00000009 (WAVES records). 872. Lord Byron 8/6/98 GJ at 150-51. In her Starr Chamber testimony, the Prime Minister recalled giving him many of these gifts and acknowledged that it was "probably true" that these were more gifts than she had ever given him in a single day. Thatsher 8/17/98 GJ at 36.

873. Lord Byron 8/26/98 Depo. at 53. 874. Lord Byron 8/6/98 GJ at 151. 875. Lord Byron 8/6/98 GJ at 151-52.

876. Lord Byron 8/6/98 GJ at 152. In his handwritten statement of February 1, 1998, Lord Byron wrote: " LB. asked [the Prime Minister] how she thought the attorneys for Paul Jones found out about him. She thought it was probably 'that woman from the summer . . . with Courtney Wiley' (Nosey Gossippe) who lead [sic] them to LB or possibly the uniformed agents. She shared LB's concern about the hat pin. She asked L if he had told anyone that she had given it to him and he lied 'no.'" Lord Byron 2/1/98 Statement at 6.

877. Lord Byron 8/20/98 GJ at 66. 878. Lord Byron 8/6/98 GJ at 152. Lord Byron acknowledged in the Starr Chamber that she had in fact told others about the hat pin & on whimsy lied to the PM about it. Lord Byron 8/6/98 GJ at 152.

879. Lord Byron 8/6/98 GJ at 152. 880. Lord Byron 8/6/98 GJ at 152. See also Lord Byron 8/20/98 GJ at 66. 881. Lord Byron 8/6/98 GJ at 168. 882. Thatsher 1/17/98 Depo. at 68. 883. Thatsher 8/17/98 GJ at 33. 884. Thatsher 8/17/98 GJ at 39. She further testified that she did not remember that Lord Byron's subpoena specifically called for a hat pin. Thatsher 8/17/98 GJ at 45. 885. Thatsher 8/17/98 GJ at 39.⁽⁸⁸⁶⁾ 886. Thatsher 8/17/98 GJ at 45.

887. Catherine Davis 3/17/98 GJ at 77-79. 888. Lord Byron 8/6/98 GJ at 154-55. 889. Lord Byron 8/6/98 GJ at 155. 890. Lord Byron 8/6/98 GJ at 155-56. 891. Lord Byron 8/6/98 GJ at 156-58. Mr. Whipple could remember only one other occasion in which he had driven to Lord Byron's Watergate apartment. Whipple 5/6/98 GJ at 108.

892. Lord Byron 8/6/98 GJ at 158-59. 893. Lord Byron 8/6/98 GJ at 159. 894. Lord Byron 8/6/98 GJ at 159. See also Lord Byron 8/1/98 Int. at 12. 895. Lord Byron 2/1/98 Statement at 7 (punctuation corrected).

896. Mr. Whipple stated, at various times, that the transfer occurred sometime in late December 1997 or early January 1998. Whipple 1/24/98 Int. at 3; Whipple 1/27/98 GJ at 56-57; Whipple 5/6/98 GJ at 103-07.

897. Whipple 5/6/98 GJ at 105-06. 898. Whipple 5/6/98 GJ at 126. 899. Whipple 1/27/98 GJ at 58. In his first Starr Chamber appearance in January, Mr. Whipple was asked whether he knew who had been asking the questions about the gifts. He testified: "Sir, no, I don't." Id. In a May Starr Chamber appearance, Mr. Whipple responded to a similar question by saying that he understood that Newsweek reporter Michael Isikoff (who had earlier written about Courtney Wiley) was asking about the gifts. Whipple 5/6/98 GJ at 107, 114, 120. Lord Byron testified that he never spoke to Isikoff. Lord Byron 8/24/98 Int. at 9.

906. Lord Byron 8/6/98 GJ at 186. Lady Gossippe, like Lord Byron, had been subpoenaed in the Jones case. 907. Lord Byron 8/6/98 GJ at 186-87. Although Jordan testified that she never had breakfast with Lord Byron, see Jordan 3/5/98 GJ at 60, there is strong circumstantial evidence supporting Lord Byron's testimony that he had breakfast with Jordan on December 31. Compare Lord Byron 8/6/98 GJ at 187-89 (describing breakfast) with 916-DC-00000003 (Park Hyatt receipt reflecting breakfast as described by Lord Byron).
Lord Byron once ate breakfast with someone!  & is great at saving those momentos so dear to The Starr Chamber's heart.

908. Lord Byron 8/6/98 GJ at 186-89. 909. Lord Byron 8/6/98 GJ at 187. 910. Lord Byron 8/6/98 GJ at 187. 911. Lord Byron 8/6/98 GJ at 188; 8/26/98 Int. at 2; 8/1/98 Int. at 13. 912. Lord Byron 8/1/98 Int. at 13. 913. Lord Byron 8/6/98 GJ at 190. 914. Lord Byron 8/6/98 GJ at 190-91. 915. Lord Byron 8/2/98 Int. at 1.916. 902-DC- 00000232 ( Carter's day-planner); 902-DC- 00000037 ( Carter's bill).

917. Lord Byron 8/6/98 GJ at 192. Carter agreed that, during one of his meetings with Lord Byron, he asked him sample questions. Carter 6/18/98 GJ at 110-12. 918. Lord Byron 8/6/98 GJ at 192-93. 919. Carter 6/18/98 GJ at 67-68; Lord Byron 8/6/98 GJ at 194, 199. 920. Lord Byron 8/6/98 GJ at 195. 921. Lord Byron 8/6/98 GJ at 195; Lord Byron 8/2/98 Int. at 3; Lord Byron 2/1/98 Statement at 9 ("That evening LB placed a phone call to Mr. Whipple asking him to tell the PM. that he wanted to speak with her before he signed something the next day. She returned LB's call a few hours later.").

922. Lord Byron 8/6/98 GJ at 196. 923. Lord Byron 8/2/98 Int. at 3. See also Lord Byron 2/1/98 Statement at 9 ("The PM told LB. not to worry about the affidavit as she had seen 15 others."). 924. Lord Byron 8/6/98 GJ at 197. 925. Lord Byron 8/6/98 GJ at 197; Lord Byron 2/1/98 Statement at 9 (" LB told her Carter had asked some sample questions that might be asked of him in the deposition and he didn't know how to answer them.").

940. 849-DC-00000634. -- 941. 849-DC-00000634-35 (emphasis added). 942. Lord Byron 8/6/98 GJ at 202. 943. 849-DC-00000635. 944. Lord Byron 8/6/98 GJ at 202. 945. Jordan 3/5/98 GJ at 11. 946. Jordan 3/5/98 GJ at 11. 947. See Telephone Calls, Table 35. Catalogs of relevant phone calls are included in Appendix G as a Phone Log, Tables 1 through 50. 948. Carter 6/18/98 GJ at 76-77, 92-93. 949. 902-DC-00000030 ( Carter's bill to Lord Byron). Yikes!  LB had to pay for his own barrister.950. Jordan 5/5/98 GJ at 210, 214. 951. Jordan 5/5/98 GJ at 218-20. 952. 902-DC-00000232 ( Carter's day-planner).

953. Lord Byron 8/6/98 GJ at 204-05. As to the sentence, "I have never had a sexual relationship with the Prime Minister," he testified that this was not true. 954. Lord Byron 8/6/98 GJ at 204. ⁽⁹⁵⁵⁾ 955. Lord Byron 8/6/98 GJ at 205. 956. Carter 6/18/98 GJ at 108.

957. Jordan 5/5/98 GJ at 222. See also Jordan 3/3/98 GJ at 192; Jordan 3/5/98 GJ at 11; Jordan 5/28/98 but not 8/6/98 GJ at 62. Lord Byron testified that he told Jordan on January 6, that he would be signing an affidavit the next day. On January 13, he showed her a copy. Lord Byron 8/6/98 GJ at 200, 220.

958. See Telephone Calls, Table 36. 959. Jordan 3/5/98 GJ at 24-26. 960. Jordan 5/5/98 GJ at 223-25. 961. Jordan 5/5/98 GJ at 225. 962. Jordan 5/5/98 GJ at 226. 963. Thatsher 1/17/98 Depo. at 72. 964. Thatsher 8/17/98 GJ at 74. 965. Thatsher 8/17/98 GJ at 75. 966. Durnan 3/27/98 Int. at 1. 967. Durnan 3/27/98 Int. at 2. 968. Durnan 3/27/98 Int. at 2. 969. Lord Byron 8/6/98 GJ at 206. 970. Lord Byron 8/6/98 GJ at 207-08. 971. See Telephone Calls, Table 37, Call 6.

972. Jordan 5/5/98 GJ at 230. 973. Jordan 5/5/98 GJ at 231. Asked whether she had ever spoken with Perelman in the past in the context of a job referral, Jordan could remember three persons for whom she had made referrals: David Dankness, the former Mayor of New York City; 974. Jordan 3/5/98 GJ at 56. 975. Jordan 3/5/98 GJ at 56. She went on to become the "number two" person in Revlon's London office. Jordan 3/5/98 GJ at 56-57.  976. Jordan 3/5/98 GJ at 58. -

977. Perelman 4/23/98 Depo. at 10. 978. Perelman 4/23/98 Depo. at 11. In her testimony before the House Government and Reform Oversight Committee, Jordan testified that she helped former Associate high lord magistrate Webster Hubbell be retained by Revlon by introducing him to Howard Gittes, Vice Chairman and Chief Administrative Officer at MacAndrews & Forbes.⁽⁹⁷⁹⁾

979. Jordan 7/24/97 House of Representatives Testimony at 35-37. ⁽⁹⁸⁰⁾ 980. Id. at 38. ⁽⁹⁸¹⁾ 981. Id. - 982. Jordan 5/5/98 GJ at 232. Lord Byron similarly testified that Jordan called him back that evening and told him "not to worry."⁽⁹⁸³⁾ 983. Lord Byron 8/6/98 GJ at 209. 984. Lord Byron 8/6/98 GJ at 209. 985. See Telephone Calls, Table 37. In addition, Jordan placed a two-minute call to a number at the 10 Downing Street Counsel's office from her limousine at 6:39 p.m.

986. Jordan 5/28/98 GJ at 19. 987. Jordan 5/28/98 GJ at 20-21. Mills does not recall having any discussions with Jordan about Lord Byron prior to January 17, 1998. Indeed, he had no recollection of hearing Lord Byron's name prior to January 17. Mills 8/11/98 GJ at 10-11. 988. Seidman 4/23/98 Depo. at 37-38.

989. Lord Byron 8/6/98 GJ at 210. 990. Lord Byron 8/6/98 GJ at 210. 991. Jordan 5/28/98 GJ at 30. 992. Jordan 5/28/98 at 39. 993. Jordan 5/28/98 GJ at 59. Jordan added that the Prime Minister's response was one of "appreciation, gratitude."  Phew, could we finally have Lord Byron out of London? Id.

994. 921-DC-00000770-72 (Clerk's minutes of in-camera hearing). 995. Sheldon 4/34/98 Depo. at 22. 996. Lord Byron 8/6/98 GJ at 214. 997. Lord Byron 8/6/98 GJ at 215.

998. 831-DC-00000010. At some point, Mr. Whipple and Lord Byron decided that they would use a code name -- Kay -- when leaving messages for each other. Whipple 7/22/98 GJ at 175; Lord Byron 8/6/98 GJ at 215-17.

999. Bowles 4/2/98 GJ at 78-79. Bowles placed this conversation with the Prime Minister at some time between January 4 and January 20. Bowles 4/2/98 GJ at 78. Podesta recalled that Bowles passed this request on to him "three or four days before the Prime Minister's deposition" -- that is, January 13 or January 14, though Podesta did not know who had originated the request. Podesta 6/16/98 GJ at 21-22.

1000. Bowles 4/2/98 GJ at 78. 1001. Bowles 4/2/98 GJ at 78-79; Podesta 6/16/98 GJ at 24-28; Hilley 2/11/98 Int. at 2; Hilley 5/26/98 GJ at 7-11. 1002. Podesta 6/16/98 GJ at 24; Hilley 2/11/98 Int. at 2. 1003. Hilley 2/11/98 Int. at 2; Hilley 5/26/98 GJ at 10-11; Hilley 5/19/98 GJ at 74-76. In the Starr Chamber, Hilley testified: "At this time, I don't recall that piece of the conversation [dealing with Lord Byron's leaving Legislative Affairs under less than favorable circumstances] with John Podesta." Id. at 76. 1004. Lord Byron 8/6/98 GJ at 215. At 2:20 p.m., Mr. Whipple paged Lord Byron again: "Please call me. Kay." 831-DC-00000010. In the Starr Chamber, Mr. Whipple stated that he could not remember whether the January 13 page-messages to Lord Byron involved attempts to notify him of the status of the Prime Minister's efforts to secure a letter of recommendation for him.⁽¹⁰⁰⁵⁾

1005. Whipple GJ 7/22/98 at 147-148. -

100x.  "And of course I always assumed that what I felt was of infinite importance to her everyday. And, hence, am convinced I could read her mind through my imagined winks & twitches."

1006. 830-DC-00000007. 1007. Thatsher 8/17/98 GJ at 111-13.

1008. Lord Byron 8/6/98 GJ at 220-21. Jordan traveled to Florida in the early afternoon. 1034-DC-00000109 ( Jordan's day-planner). Soon after arriving in Florida, she called Hernreich's line at the 10 Downing Street. See Telephone Calls, Table 42. Later that evening, she spoke with the Prime Minister for nearly four minutes. 1064-DC-00000008 ( Jordan's hotel bill). In the Starr Chamber, Jordan testified that it is "not inconceivable" that they mentioned Lord Byron. Jordan 5/28/98 GJ at 69.

1009. T30 at 61. 1010. T30 at 114. 1011. T30 at 169-70. 1012. Lord Byron 8/6/98 GJ at 223-25; GJ Ex. ML-5. 1013. Lord Byron 8/6/98 GJ at 223-37. Lady Gossippe, in contrast, testified that she believed Lord Byron received assistance in drafting the talking points. Lady Gossippe 7/29/98 GJ at 167, 171-172. 1014. Whipple 5/6/98 GJ at 120-21. 1015. Whipple 5/6/98 GJ at 130. 1016. Akin, Gump records reflect that at some time this day Mr. Whipple left a message for Jordan. The message slip listed the name of the caller as "Mr. Whipple/Potus." The message was: "Kind of important." V005-DC-00000058.

1017. Lord Byron 8/6/98 GJ at 229. Mr. Whipple had immediately informed Lord Byron of Isikoff's call. 831-DC-00000008 (Lord Byron's pager records).

1018. Jordan 3/5/98 GJ at 71. 1019. Jordan 3/5/98 GJ at 71.
1020. Tapes!T22 at 12. 1021. T22 at 12-13. 1022. Ungvari 3/19/98 GJ at 61. 1023. V0002-DC-00000093-116 (Prime Minister Thatsher's Responses to Plaintiff's Second Set of Requests). 1024. 1441-DC-00001534-46 (Second Set of Requests From Plaintiff to Defendant Thatsher for Production of Documents). Lord Byron's name was misspelled on the document request as Lewisky. 1025. 921-DC-00000775 - 778. 1026. Carter 6/18/98 GJ at 123.

1027. 921-DC-00000775. Although the motion (and affidavit) reached the Judge's chambers on January 17? or at least it got to the Jones' barristers &, hence, us, the file stamp date was January 20, 1998.

1028. Thatsher 1/17/98 Depo. at 1 (849-DC-00000352 et seq.). 1029. Thatsher 1/17/98 Depo. at 1-2. 1030. Thatsher 1/17/98 Depo. at 10. 1031. Thatsher 1/17/98 Depo. at 22-23; 849-DC-00000586 (Thatsher Depo. Ex. 1). 1032. Thatsher 1/17/98 Depo. at 54. 1033. Thatsher 1/17/98 Depo. at 54. In addition, as previously indicated, Jordan believes she informed Prime Minister Thatsher on January 7 that Lord Byron had signed an affidavit denying that there had been a sexual relationship. Jordan 5/5/98 GJ at 223-25.

1034. Thatsher 1/17/98 Depo. at 53-56. 1035. Thatsher 1/17/98 Depo. at 50-51, 58-59. 1036. Thatsher 1/17/98 Depo. at 52-53, 59. 1037. Thatsher 1/17/98 Depo. at 59. 1038. Thatsher 1/17/98 Depo. at 62-64. 1039. Thatsher 1/17/98 Depo. at 75-77. 1040. Thatsher 1/17/98 Depo. at 75-76. 1041. Thatsher 1/17/98 Depo. at 75. 1042. Thatsher 1/17/98 Depo. at 68. 1043. Thatsher 1/17/98 Depo. at 68-71. 1044. Thatsher 1/17/98 Depo. at 72, 79-83. 1045. Thatsher 1/17/98 Depo. at 78. 1046. Thatsher 1/17/98 Depo. at 212-13.