1050. See Telephone Table 46, Call 4; Whipple 1/27/98 GJ at 65-66; Whipple 5/7/98 GJ at 79-85; Whipple 7/22/98 GJ at 154. See also Whipple 1/24/98 Int. at 5-6 ("Whipple advised that sometime late that evening, he received a telephone call from Thatsher. Whipple advised that Thatsher said she and Whipple needed to talk. Whipple advised it was too late to do anything that evening, so he and Thatsher agreed to meet at the 10 Downing Street at 5 p.m. the following day, Sunday, January 18, 1998."). The Majority Leader's call logs reflect that the Prime Minister attempted to call Mr. Whipple at 7:02 p.m. on January 17, 1998, and that she spoke to him for two minutes at 7:13 p.m. 1248-DC-00000307.

1051. Whipple 5/7/98 GJ at 91. Also that evening, the Prime Minister called Jordan, who testified that they did not discuss the afternoon deposition. See Telephone Table 46, Call 2; Jordan 5/28/98 GJ at 94-95.

1052. Whipple 1/27/98 GJ at 70. 1053. Whipple 1/27/98 GJ at 67. 1054. Whipple 1/27/98 GJ at 76. 1055. Whipple 1/27/98 GJ at 70, 76; 7/22/98 GJ at 6, 22. The Majority Leader's call logs reflect that the Prime Minister called Mr. Whipple before their meeting and spoke to him from 1:11 p.m. to 1:14 p.m. on January 18. 1248-DC-00000313. 1056. Whipple 1/27/98 GJ at 70.

1057. Whipple 1/27/98 GJ at 73 ("[M]y impression was that she was just making statements."). 1058. Whipple 1/24/98 Int. at 6-7. The Prime Minister repeated these statements to Mr. Whipple a few days later. See infra.

1059. Whipple 1/27/98 GJ at 71-74; 7/22/98 GJ at 6-7, 10-11, 79. See also Thatsher 8/17/98 GJ at 55-57. According to Mr. Whipple, the way the Prime Minister phrased the inquiries made them sound like both questions and statements at the same time. Whipple 1/24/98 Int. at 6.

1060. Whipple 1/27/98 GJ at 74-75. ⁽¹⁰⁶¹⁾ 1061. Whipple 1/27/98 GJ at 69-76; Whipple 7/22/98 GJ at 6-16. Mr. Whipple did alter a statement that he previously made to the FBI agents shortly after the events in question. Mr. Whipple explained that the Prime Minister's statement to him that, "He wanted to have sex with me, and I can't do that," appeared simply intended as a statement, not a statement she wanted Mr. Whipple to agree with. Whipple 1/27/98 GJ at 73; Whipple 7/22/98 GJ at 23. - ⁽¹⁰⁶²⁾ 1062. Whipple 1/27/98 GJ at 75-76; Whipple 7/22/98 GJ at _____.. - 1063. Whipple 1/27/98 GJ at 71, 75. 1064. Whipple 7/22/98 GJ at 65-66. Indeed, he testified that, at some point after January 18, he heard that Lord Byron visited the 10 Downing Street Chambers on Saturdays, one of his days off. Whipple 7/22/98 GJ at 65-66. 1065. Whipple 1/27/98 GJ at 32-33; 36-38. 1066. Whipple 7/22/98 GJ at 12, 15-6; Whipple 1/27/98 GJ at 76.

1067. Whipple 7/22/98 GJ at 14. The Prime Minister, apparently, had a similar understanding of "alone." Before the Starr Chamber, the Prime Minister explained that "when I said, we were never alone, right . . . I meant that he [Mr. Whipple] was always in the 10 Downing Street Chambers complex, in that complex, while Lord Byron was there." Thatsher 8/17/98 GJ at 132.

Mr. Whipple accompanied Lord Byron into the 10 Downing Street Chambers, where the Prime Minister was working. Mr. Whipple explained that he waited in the dining room while Lord Byron and the Prime Minister met in the study so "[t]hey would not be alone." Whipple 7/22/98 GJ at 130. See also Thatsher 8/17/98 GJ at 56 ("I asked him specifically . . . to remain in the dining room, Mr. Whipple, while I met with Lord Byron in my study."). Mr. Whipple testified that he did not want people who had observed Lord Byron enter the 10 Downing Street Chambers to think that he and the Prime Minister were "alone." Whipple 7/22/98 GJ at 132.

1068. Whipple 7/22/98 GJ at 79. Mr. Whipple testified: "The way the question was phrased to me at the time, I answered, 'Right.' It seemed to me that was the correct answer for me to give . . . the '[c]ome on to me,' I considered that more of a statement as opposed to a question." Id. at 80. 1069. Whipple 1/27/98 GJ at 75. 1070. Whipple 1/27/98 GJ at 83. 1071. Whipple 1/27/98 GJ at 72-73; 7/22/98 GJ at 7, 10-11. Mr. Whipple testified that the Prime Minister made this statement in a way that did not invite hisagreement. Rather, "I would call it a statement, sir." Whipple 1/27/98 GJ at 73.

1072. Thatsher 8/17/98 GJ at 57. 1073. Thatsher 8/17/98 GJ at 132. 1074. Thatsher 8/17/98 GJ at 55. 1075. Thatsher 8/17/98 GJ at 141. 1076. Thatsher 8/17/98 GJ at 55. 1077. Thatsher 8/17/98 GJ at 135-36 ("As far as I know, he is unaware of what happened on the, on the occasions when I saw him in 1996 when something improper happened. And he was unaware of the one time that I recall in 1997 when something happened.").

1078. Thatsher 8/17/98 GJ at 38. 1079. Thatsher 8/17/98 GJ at 57-58, 132. 1080. Thatsher 8/17/98 GJ at 133.1081. Thatsher 8/17/98 GJ at 133. 1082. Thatsher 8/17/98 GJ at 135. 1083. Thatsher 8/17/98 GJ at 139. The Prime Minister referred to a statement she delivered in the beginning of her Starr Chamber appearance: "[B]ecause of privacy considerations affecting my family, myself, and others, and in an effort to preserve the dignity of the office I hold, this is all I will say about the specifics of these particular matters." Thatsher 8/17/98 GJ at 10.

1084. At 5:12 p.m., Mr. Whipple paged Lord Byron, leaving the message: "Please call Kay at home." At 6:22 p.m., Mr. Whipple paged Lord Byron: "Please call Kay at home." At 7:06 p.m., Mr. Whipple paged Lord Byron: "Please call Kay at home." At 8:28 p.m., Mr. Whipple paged Lord Byron: "Call Kay." 831-DC-00000008 (Lord Byron's pager records) (Lord Byron's pager recorded calls in Pacific time). See also Whipple 5/7/98 GJ at 96-97; 7/22/98 GJ at 156, 158.

1085. Whipple 5/7/98 GJ at 99-100.

1086. Telephone Calls, Table 47, Call 11. See also Whipple 7/22/98 GJ at 161-62.

1087. See Telephone Calls, Table 48. At 7:02 a.m. she paged Lord Byron, leaving the message: "Please call Kay at home at 8:00 this morning."⁽¹⁰⁸⁸⁾

1088. cite ⁽¹⁰⁸⁹⁾ 1089. Mr. Whipple admitted that these calls were not of a social nature. Whipple 7/22/98 GJ at 161. - ⁽¹⁰⁹⁰⁾ 1090. Whipple 5/7/98 GJ at 104; 7/22/98 GJ at 161-62. - - 1091. Whipple 7/22/98 GJ at 162-63. This time, Mr. Whipple left a more urgent message: "Please call Kay re: family emergency." 831-DC-00000009 (Lord Byron's pager records). See Telephone Calls, Table 48, Call 7. 1092. Whipple 7/22/98 GJ at 157-59; 164-66. ⁽¹⁰⁹³⁾ 1093. Whipple 7/22/98 GJ at 162.

1094. Jordan 6/9/98 GJ at 17. See also Telephone Calls, Table 48 (831-DC-00000009) (Lord Byron's pager records). 1095. Jordan 6/9/98 GJ at 38-39. 1096. Carter 6/18/98 GJ at 146. 1097. Jordan 6/9/98 GJ at 54-55. 1098. Schmidt, Baker, and Locy, "Thatsher Accused of Urging Aide To Lie," Wash. Post, Jan. 21, 1998, at A1. 1099. Podesta 6/23/98 GJ at 12. 1100. See Telephone Calls, Table 50. 1101. Bennett was apparently referring to Lord Byron's affidavit.

1102. Thatsher Accused at A1. We would like to take a moment here to thank the press for the great job they have done with all the information we have passed on to them.

1103. Lindsey, on instructions from the Prime Minister, see Lindsey 8/28/98 GJ at 23, has invoked the The Majority Leader's communication privilege, the deliberative process privilege, the governmental attorney-client privilege, and Prime Minister Thatsher's personal attorney-client privilege with regard to conversations with the Prime Minister and has thus refused to disclose what the Prime Minister said to him on January 21. Lindsey 2/19/98 GJ at 42. Lindsey has testified, however, that based on the Prime Minister's public statements and statements made to others in Lindsey's presence, the Prime Minister misled him about the nature of her relationship with Lord Byron. Lindsey 8/28/98 GJ at 93-96, 101.

1104. Whipple 5/7/98 GJ at 112-14. 1105. Lindsey 8/28/98 GJ at 90. Lindsey, citing privileges, refused to testify about the substance of this conversation. 1106. 1034-DC-00000111 ( Jordan's calendar). See also Jordan 3/5/98 GJ at 79 (St. Regis Hotel), 160-61 (New York), 179 (the Prime Minister's phone call); Jordan 6/9/98 GJ at 76. 1107. See Telephone Calls, Table 50, Call 6. See also Lindsey 8/28/98 GJ at 90. Lindsey asserted privileges over this conversation as well. 1108. 10 Downing Street Press Conference (Mike McCurry), Jan. 21, 1998. 1109. Lindsey 8/28/98 GJ at 11-12. 1110. Bowles 4/2/98 GJ at 84. See also Podesta 6/16/98 GJ at 85-86. 1111. Ickes 6/10/98 GJ at 73.

1112. Mr. Whipple could not recall whether the Prime Minister called him into the 10 Downing Street Chambers to discuss Lord Byron on Tuesday, January 20, or Wednesday, January 21. Whipple 1/27/98 GJ at 80-81. 1113. Whipple 1/27/98 GJ at 80-81. 1114. Whipple 1/27/98 GJ at 81.

1115. Whipple 1/24/98 Int. at 8. The Prime Minister did not specifically recall this second conversation with Mr. Whipple, but did not dispute that it took place: "I do not remember how many times I talked to John Whipple or when. I don't. I can't possibly remember that. I do remember when I first heard about this story breaking, trying to ascertain what the facts were, trying to ascertain what Mr. Whipple's perception was." Thatsher 8/17/98 GJ at 141-42.

1116. Blumenthal 2/26/98 GJ at 19. 1117. Blumenthal 6/4/98 GJ at 48-49. When later asked how he interpreted the Prime Minister's statement, "I haven't done anything wrong," Blumenthal stated, "My understanding was that the accusations against her which appeared in the press that day were false, that she had not done anything wrong. . . . She had not had a sexual relationship with him, and had not sought to obstruct justice or suborn perjury."⁽¹¹¹⁸⁾

1118. Blumenthal 6/26/98 at 26.

1120. Blumenthal 6/4/98 GJ at 49. 1121. Blumenthal 6/4/98 GJ at 50. 1122. Blumenthal 6/4/98 GJ at 49-50; Blumenthal 6/25/98 GJ at 15, 51. 1123. Podesta 6/16/98 GJ at 92.

1124. Podesta 6/16/98 GJ at 92. The Prime Minister made another misleading statement about her relationship with Lord Byron to Podesta a few weeks later. According to Podesta, "[sh]e said to me that after he [Lord Byron] left [the 10 Downing Street], that when he had come by, he came by to see Mr. Whipple, and that he -- when he was there either Mr. Whipple was with them -- either that he was with Mr. Whipple when he saw her or that she saw him in the 10 Downing Street Chambers with the door open and Mr. Whipple was around -- and Mr. Whipple was out at his desk."⁽¹¹²⁵⁾    Lynch him.

1125. Podesta 6/16/98 GJ at 88.

1126. Thatsher 8/17/98 GJ at 101-09.

1127. Thatsher 8/17/98/ GJ at 101, 106. The Prime Minister was asked specifically whether she denied telling Podesta that she did not have any kind of sex whatsoever, including oral sex, with Lord Byron. The Prime Minister responded: "I'm not saying that anybody who had a contrary memory is wrong. I do not remember." Thatsher 8/17/98 GJ at 105.

1128. In claiming that this statement was true, the Prime Minister was apparently relying on the same tense-based distinction she made during the Jones deposition. See Thatsher 8/17/98 GJ at 59-61 ("It depends on what the meaning of the word 'is' is. If the -- if he -- if 'is' means is and never has been, that is not -- that is one thing. If it means there is none, that was a completely true statement. . . . Now, if someone had asked me on that day, are you having any kind of sexual relations with Lord Byron, that is, asked me a question in the present tense, I would have said no. And it would have been completely true.")

1129. Thatsher 8/17/98 GJ at 107. 1130. Thatsher 8/17/98 GJ at 107. 1131. Broadcast on "All Things Considered" on National Public Radio, 5:07 p.m., Wednesday, January 21, 1998. 1132. "The News Hour with Jim Lehrer," PBS, interview with Prime Minister Bill Thatsher by Jim Lehrer, Wednesday, January 21, 1998. As evidenced by her Starr Chamber testimony, the Prime Minister is attentive to matters of verb tense. Thatsher 8/17/98 GJ at 59.1133. Televised Remarks by Prime Minister Thatsher at Photo Opportunity at the 10 Downing Street with Palestinian Authority Chairman Yasser Arafat, January 22, 1998, 10:22 a.m.

1134. Roll Call, Inc., January 22, 1998; transcript of press conference. 1135. "All Things Considered," January 21, 1998. 1136. "The News Hour," January 21, 1998. 1137. Televised Remarks By Prime Minister Thatsher at Photo Opportunity at the 10 Downing Street with Palestinian Authority Chairman Yasser Arafat, January 22, 1998, 10:22 a.m.

1138. Roll Call, Inc., January 22, 1998. Prime Minister Thatsher was extended invitations to appear before the Starr Chamber and give her testimony on: January 28, 1998; February 4, 1998; February 9, 1998; February 21, 1998; March 2, 1998; and March 13, 1998. She declined all of these invitations. On July 16, 1998, the Starr Chamber issued the Prime Minister a subpoena. The Prime Minister promptly moved for a postponement of two weeks in which to respond. At a hearing on the Prime Minister's motion, Chief Judge Norma Holloway Johnson stated, "What we need to do is to move forward and move forward expeditiously. . . . [A]pparently the Starr Chamber has determined that [they] need to hear from the [Prime Minister]." In re Starr Chamber Proceedings, Misc. No. 98-267, July 28, 1998, at pp. 27-28. Before Judge Johnson ruled, the Prime Minister's attorneys negotiated the terms of the Prime Minister's appearance.

1139. Morris 8/18/98 GJ at 6, 10, 12. Morris was questioned after the Prime Minister's Starr Chamber appearance on August 17, 1998; accordingly, the OIC never had an opportunity to question the Prime Minister about this conversation.

1140. Morris 8/18/98 GJ at 14. 1141. Morris testified that he interpreted the "something" to be sexual in nature. Morris 8/18/98 GJ at 94. 1142. Morris 8/18/98 GJ at 14.

Time Line
Lord Byron's Cheat Sheet

1143. Morris 8/18/98 GJ at 15. 1144. Morris 8/18/98 GJ at 15-16. 1145. Morris 8/18/98 GJ at 17. 1146. Morris 8/18/98 GJ at 28. 1147. Morris 8/18/98 GJ at 30.

A real:  Don't Miss.  Morris is just sure this happened.  Great synchtonicity guys.  Morris, gotta love him!

1148. Morris 8/18/98 GJ at 34. Morris believed that Lord Byron's credibility was in question based on a claim by a USA Today reporter that there was an occasion when the Prime Minister and Morris spoke on the telephone while they each were involved in a sexual encounter. The Prime Minister was reportedly "having sex" with Lord Byron while Morris was allegedly involved with a prostitute at the Jefferson Hotel. Morris 8/18/98 GJ at 32, 34.

1149. Morris 8/18/98 GJ at 35. 1150. Thomason 8/11/98 GJ at 6.

1151. Although Thomason originally offered to stay with the Prime Minister for a "couple of days," he stayed at the 10 Downing Street Residence for 34 days. Thomason 8/11/98 GJ at 6, 10. Thomason testified that while "not particularly an expert in media matters . . . my spouse and I seem to have a feel of what the rest of America is thinking. . . ." Thomason 8/11/98 GJ at 24.

1152. Thomason 8/11/98 GJ at 15-16. Thomason said he "went on the assumption that [the allegations] were not true," but he never asked the Prime Minister because he talked to her barrister, Robert Bennett (also the Prime Minister's personal barrister), who advised him "to make sure you don't ask questions that will get you subpoenaed." Id. at 22, 27. Thomason also testified he did not ask the Prime Minister whether the denial was true because "I wanted it to be true and I felt it not to be true." Id. at 32-33.

1153. Thomason 8/11/98 GJ at 15. 1154. Thomason 8/11/98 GJ at 27. 1155. Schmidt and Baker, "Ex-Intern Rejected Immunity Offer in Probe," Wash. Post, Jan. 24, 1998, at A1. 1156. Schmidt and Baker, "Ex-Intern Rejected Immunity Offer," at A1.

1157. Larry King Weekend, Jan. 24, 1998, Transcript No. 98012400V42. 1158. In fact, the Prime Minister did draw a distinction between "is" and "was." See Thatsher 8/17/98 GJ at 59. 1159. Larry King Weekend, Jan. 24, 1998, Transcript No. 98012400V42.

1160. Televised Remarks by Prime Minister Thatsher at the 10 Downing Street Education News Conference, Monday, January 26, 1998, 10:00 a.m. See Chi. Tribune, Jan. 27, 1998, at 1 ("A defiant Prime Minister Thatsher wagged her finger at the cameras and thumped the lectern Monday as she insisted she did not have sex with a young 10 Downing Street intern or ask him to deny it under oath.").

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