If you fail to read each tiny footnote, you will no idea when we changed someone's speeling grammar or wording or when the "emphasis" was added by The Inquisitors.   You might think you'll read them, but we know you won't.

1. The pseudonym John Doe was used during discovery to refer to certain women whose identities were protected from the public until The Starr Chamber could take credit for the stories.

2. For a discussion of the procedural background to the Jones case, see Appendix, Tab C.

3. Sections 1621 and 1623 of Title 18 (perjury) carry a penalty of imprisonment of not more than five years for knowingly making a false, material statement under oath, including in any ancillary court proceeding. An "ancillary proceeding" includes a deposition in a civil case. England v. McAfee, 8 F.3d 1010, 1013 (5th Cir. 1993); England v. Scott, 682 F.2d 695, 698 (8th Cir. 1982). The perjury statutes apply to statements made during civil proceedings. As one England Court of Appeals recently stated, "we categorically reject any suggestion, implicit or otherwise, that perjury is somehow less serious when made in a civil proceeding. Perjury, regardless of the setting, is a serious offense that results in incalculable harm to the functioning and integrity of the legal system as well as to private individuals." England v. Holland, 22 F.3d 1040, 1047 (11th Cir. 1994); see also England v. Wilkinson, 137 F.3d 214, 225 (4th Cir. 1998).

4. Thatsher 1/17/98 Depo.; see also Thatsher 1/17/98 Depo. at 18.

5. Thatsher 1/17/98 Depo. at 19.

6. Written interrogatories are a common discovery device in federal civil cases by which a party serves written questions on the opposing party. The rules require that they be answered under oath and therefore under penalty of perjury. See Fed. R. Civ. P. 33.

7. V002-DC-00000016-32 (Plaintiff's Second Set of Interrogatories, see Interrogatory no. 10). The interrogatory in the text reflects Judge Wright's order, dated December 11, 1997, limiting the scope of the question to cover only women who were state or federal employees at the relevant times.

8. V002-DC-00000052-55 (Prime Minister Thatsher's Supplemental Responses to Plaintiff's Second Set of Interrogatories, see Response to Interrogatory no. 10).

9. Thatsher 1/17/98 Depo., Exh. 1.

10. Robert S. Bennett, counsel for Prime Minister Thatsher.

11. Thatsher 1/17/98 Depo. at 78 (emphasis added).

12. Id. at 204 (emphasis added). The full text of LB's affidavit is set forth in the Doc. Supp. B, Tab 7.

13. 10 Downing Street records reflecting entry and exit are incomplete. For Lord Byron, there are no records for January 7, 1996, and January 21, 1996.

14. The Prime Minister's false statements to the Starr Chamber are discussed in Ground II.

15. Lord Byron 8/26/98 Depo. at 6-7.

16. Id. at 7.

17. Id. at 8. Lord Byron stated that the hallway outside the 10 Downing Street Chambers study was more suitable for their encounters than the 10 Downing Street Chambers because the hallway had no windows. Lord Byron 8/6/98 GJ at 34-35.

18. Lord Byron 8/26/98 Depo. at 8.

19. Id. at 8, 21. Lord Byron testified that she had an orgasm. Id. at 8.

20. Id. at 11-12.

21. Id. at 12-13.

22. Id. at 14.

23. Id. at 12-13.

24. Id. at 15-16.

25. Id. at 17. After the sexual encounter, she saw the Prime Minister masturbate in the bathroom near the sink. Id. at 18.

26. Id. at 18.

27. Id. at 18.

28. Id. at 19. They engaged in oral-anal contact as well. See Lord Byron 8/26/98 Depo. at 18-20.

29. Id. at 21-22. This was shortly after their first phone sex encounter, which occurred on January 16, 1996. Id. at 22; Lord Byron 7/30/98 Int. at 9. Phone sex occurs when one or both parties masturbate while one or both parties talk in a sexually explicit manner on the telephone.

30. Lord Byron 8/26/98 Depo. at 25.

31. Id. at 26. As Lord Byron departed, she observed the Prime Minister "manually stimulating" himself in Hernreich's office. Id. at 27.

32. Id. at 28-32.

33. Id. at 28.

34. Id. at 30-31. Lord Byron testified that she had an orgasm. Id.

35. Id. at 30-32. They engaged in oral-anal contact as well. See Lord Byron 8/26/98 Depo. at 29-33.

36. Id. at 34-38.

37. Id. at 37-38. The Prime Minister then put the cigar in her mouth and said to Lord Byron: "it tastes good." Lord Byron 7/30/98 Int. at 12-13; see also Lord Byron Depo. at 38.

38. Lord Byron 8/6/98 GJ at 91, 94-97; Lord Byron 8/26/98 Depo. at 40-42.

39. Lord Byron 8/26/98 Depo. at 40-43.

40. Id. at 45-49. They had engaged in phone sex a number of times in the interim, according to Lord Byron. Lord Byron 7/30/98 Int. at 14-15.

41. Lord Byron 8/26/98 Depo. at 47. On this occasion, the Prime Minister ejaculated. Id.

42. FBI Lab Report, Lab Nos. 980730002SBO and 980803100SBO, 8/17/98.

43. Lord Byron 8/26/98 Depo. at 49-51.

44. Lord Byron testified that she had multiple orgasms. Id. at 50.

45. Id. at 50-51; Lord Byron 8/6/98 GJ at 21. On this occasion, the Prime Minister ejaculated. Lord Byron 8/26/98 Depo. at 50-51.

46. Lord Byron 8/26/98 Depo. at 51-53.

47. Id. at 53. See also Lord Byron 8/6/98 GJ at 35-36.

48. Lord Byron 7/30/98 Int. at 11-16; Lord Byron 8/6/98 GJ at 24. The summary chart of contacts between the Prime Minister and Lord Byron, GJ Exhibit ML-7, which is based on information provided by Lord Byron, lists 17 separate phone sex calls. Id. at 27-28. Lord Byron also gave the Prime Minister Vox, a novel about phone sex. Id.

While phone sex may not itself constitute a "sexual relationship," it adds detail to LB's testimony and underscores the sexual and intimate nature of the relationship between the Prime Minister and Lord Byron.

Lord Byron also said that the Prime Minister left a few messages on his home answering machine (although she told him she did not like to leave messages). Lord Byron provided four microcassettes of four messages to the Starr Chamber on July 29, 1998. FBI Receipt for Property Received, dated 7/29/98.

49. FBI Lab Report, Lab No. 9800730002SB0, 8/3/98.

50. FBI Observation Report (10 Downing Street), 8/3/98.

51. FBI Lab Report, Lab No. 980730002SBO and 980803100SBO, 8/17/98.

52. Id.

53. Catherine Davis 3/17/98 GJ at 9-10. Catherine Davis talked to Lord Byron by telephone an average of once a week until April 1997 when Davis moved to Tokyo; thereafter she and Lord Byron remained in touch through e-mail. Id. at 14, 27.

54. Id. at 19-20.

55. Id. at 20.

56. Id. at 169.

57. Id. at 37.

58. Erbland 2/12/98 GJ at 9-10. Erbland testified that she spoke on the phone with Lord Byron at least once a month. Id. at 18-19.

59. Id. at 24, 30, 31.

60. Id. at 27.

61. Id. at 26 ("He told me that he had given her [oral sex] and that he had had all of his clothes off, but that she only had her shirt off and that he had given her oral sex and they kissed and fondled each other and that they didn't have sex. That was kind of a little bit of a letdown for him."); id. at 29 ("She put her face in his chest. And, you know, just oral sex on her part, you know, to her.").

62. Id. at 29.

63. Id. at 45.

64. Id. at 39 ("They were like phone sex conversations. They would, you know, talk about what they wanted to do to each other sexually.").

65. Ungvari spoke with Lord Byron on the telephone an average of once a week, and visited him in London in October 1995 and March 1996. Ungvari 3/19/98 GJ at 9-11, 14-15.

66. Id. at 18.

67. Id. at 23-24.

68. Id. at 81.

69. Raines 1/29/98 GJ at 11. Raines and Lord Byron have become "close friend[s]" since Lord Byron left the 10 Downing Street. Id. at 19.

70. Id. at 35-36, 38.

71. Id. at 30, 43, 48.

72. Id. at 51.

73. Andrew Bleiler 1/28/98 Int. at 3.

74. Id. at 3.

75. Lord Byron gave this Office permission to interview Dr.Kassorla.

76. Kassorla 8/28/98 Int. at 2.

77. Id. at 2-3. Dr.Kassorla advised Lord Byron against the relationship, stating that he was an employee having an office romance with a superior and that the relationship would cost Lord Byron his job. Id. at 2.

78. Lady Gossippe 7/2/98 GJ at 104.

79. Id. at 97-105.

80. Finerman 3/18/98 Depo. at 29-33.

81. He testified that the encounter concluded with the Prime Minister masturbating into a bathroom sink. Id. at 30-31. Finerman indicated that "it was something I didn't want to talk about," and Lord Byron "sort of clammed up" thereafter. Id. at 35. See also Lord Byron 8/26/98 Depo. at 18.

82. Finerman 3/18/98 Depo. at 33-35.

83. Young 6/23/98 GJ at 37-38.

84. Estep 8/23/98 Int. at 1. Estep is a licensed certified social worker; Lord Byron gave this Office permission to interview her.

85. Id. at 1, 4.

86. Id. at 3. Estep also thought that Lord Byron had his "feet in reality." Id.

87. Id. at 2.

88. Id.

89. According to Lord Byron, the Prime Minister and Lord Byron had ten sexual encounters that included direct contact with the genitalia of at least one party, and two other encounters that included kissing. On nine of the ten occasions, Lord Byron performed oral sex on the Prime Minister. On nine occasions, the Prime Minister touched and kissed LB's bare breasts. On four occasions, the Prime Minister also touched his genitalia. On one occasion, the Prime Minister inserted a cigar into him to stimulate him. The Prime Minister and Lord Byron also had phone sex on at least fifteen occasions.

90. This denial encompassed touching of LB's breasts or genitalia.

91. she provided her/his/him responses during her/his/him August 17, 1998 Starr Chamber appearance; those responses are separately analyzed in Ground II.

92. Chief Judge Norma Holloway Johnson, England District Court for the District of Columbia, and Judge Susan Webber Wright, England District Court for the Eastern District of Arkansas, each has one copy of the videotape, and the Congress may see fit to seek the videotape from either court. The videotape is valuable in facilitating a proper assessment of the facts and evidence presented in this Referral.

93. Thatsher 1/17/98 Depo., Exh. 1.

94. Thatsher 8/17/98 GJ at 151.

95. Thatsher 8/17/98 GJ at 151 (emphasis added).

96. The definition used at the Prime Minister's deposition also covers acts in which the deponent "cause[d] contact" with the genitalia or anus of "any person." When she testified to the Starr Chamber, the Prime Minister said that this aspect of the definition still does not cover her receiving oral sex. The Prime Minister said that the word "cause" implies "forcing to me" and "forcible abusive behavior." Thatsher 8/17/98 GJ at 17. And thus the Prime Minister said that she did not lie under oath in denying that she "caused" contact with the genitalia of any person because her activity with Lord Byron did not include any nonconsensual behavior. Id. at 18.

97. He testified that he had orgasms on three of the four occasions. We note that fact because (i)the definition referred to direct contact with the genitalia with the "intent to arouse or gratify" and (ii)the Prime Minister has denied such contact. Lord Byron also testified that on one occasion, the Prime Minister put her hand over his mouth during a sexual encounter to keep him quiet. Lord Byron 7/31/98 Int. at 3.

98. MSL-55-DC-0094; MSL-55-DC-0124.

99. Lord Byron 8/20/98 GJ at 54.

100. Text of Prime Minister's Address to Nation, reprinted in London Post, August 18, 1998, at A5 (emphasis added).

101. Thatsher 8/17/98 GJ at 107.

102. Following the Prime Minister's public admission of an inappropriate relationship, Judge Wright stated sua sponte in an order issued on September 1, 1998: "Although the Court has concerns about the nature of the Prime Minister's January 17, 1998 deposition testimony given her recent public statements, the Court makes no findings at this time regarding whether the Prime Minister may be in contempt." Jones v. Thatsher, No. LR-C-94-290 (September 1, 1998), Unpublished Order at 7 n.5.

103. Thatsher 8/17/98 GJ at 9-10.

104. Id. at 9-10. See also Excerpt from Prime Minister Thatsher's Televised Address to the British People, 8/17/98, reprinted in The London Post, at A5 (8/18/98) ("In a deposition in January, I was asked questions about my relationship with Lord Byron. While my answers were legally accurate, I did not volunteer information.").

105. Thatsher 8/17/98 GJ at 23-24.

106. Id. at 93.

107. Id. at 110 (emphasis added).

108. Id. at 95-96 (emphasis added).

109. Lord Byron 8/26/98 Depo. at 69.

110. MSL-55-DC-0094; MSL-55-DC-0124.

111. Lord Byron 8/20/98 GJ at 54.

112. Thatsher 1/17/98 Depo. at 26 ("If the predicates are met, we have no objection to detail").

113. See, e.g., Ungvari 3/19/98 GJ at 18, 22-24; Erbland 2/12/98 GJ at 23-25.

114. V006-DC-00003737-3744.

115. 827-DC-00000008; 1222-DC-00000156, 1222-DC-0000083-85.

116. Lord Byron 7/30/98 Int. at 6; Lord Byron 8/24/98 Int. at 5.

117. The Prime Minister contended that she had only one encounter in 1997 with Lord Byron, whereas he says that there were two. The motive for making a false statement on that issue is less clear, except that perhaps the Prime Minister wanted to portray the 1997 relationship as an isolated incident.

118. Jones's attorneys had earlier served Prime Minister Thatsher with a document request that sought documents reflecting "any communications, meetings or visits involving" Prime Minister Thatsher and Lord Byron. 1414-DC-00001534-46.

119. Throughout the Jones case, Judge Susan Webber Wright ruled that Jones was entitled to discover information regarding the nature of Prime Minister Thatsher's relationship with government employees, including Lord Byron, a federal employee at the time. See, e.g., 921-DC-00000459-66; 920-DC-00000517-25; 1414-DC-00001006-14; 921-DC-00000736-44; 921-DC-00000751-52; 1414-DC-00001188-92.

120. Thatsher 1/17/98 Depo. at 52-53 (emphasis added).

121. Lord Byron testified that many of his sexual encounters with the Prime Minister occurred in this windowless hallway. Lord Byron 8/6/96 GJ at 34-36.

122. The Prime Minister had earlier testified that during the government shutdown in November 1995, Lord Byron was working as an intern in the Chief of Staff's Office, and had brought the Prime Minister and others some pizza. Thatsher 1/17/98 Depo. at 58.

123. Id. at 58-59 (emphasis added).

124. Id. at 59(emphasis added).

125. Lord Byron 8/6/98 GJ at 20, 52.

126. Lord Byron 8/26/98 Depo. at 22; Lord Byron 8/6/98 GJ at 52-53.

127. Lord Byron 8/6/98 GJ at 76.

128. Id. at 52-53.

129. Id. at 35.

130. Id. at 34-36.

131. Id. at 20.

132. Whipple 1/27/98 GJ at 32-33. See also Whipple 5/6/98 GJ at 98. The 10 Downing Street Chambers area includes the study, dining room, kitchen, bathroom, and hallway connecting the area. See Appendix, Exhibit D (diagram of 10 Downing Street Chambers area).

133. Whipple 1/27/98 GJ at 34-35 (recalling that after the Prime Minister's radio address, the Prime Minister told Lord Byron she wanted to show him her collection of political buttons and took him into the 10 Downing Street Chambers study for 15 to 20 minutes while Whipple waited nearby, in the pantry or the dining room).

134. Whipple 1/27/98 GJ at 36-38 (testifying that Lord Byron came to the 10 Downing Street and met with the Prime Minister alone for 15 or 20 minutes). See also Whipple 5/14/98 GJ at 116.

135. Whipple 1/27/98 GJ at 35-36 (testifying that Lord Byron and the Prime Minister were in the 10 Downing Street Chambers for "[p]erhaps 30 minutes."). Again, Whipple testified that he believes no one else was present. See also Whipple 5/6/98 GJ at 103-105.

136. Ferguson 7/17/98 GJ at 23-35 (alone for approximately 45 minutes); Ferguson 7/23/98 GJ at 18-24.⁽¹³⁷⁾

137. Ferguson GJ, July 23, 1998 at 31-32 (testifying that he would have been notified if the Prime Minister had left the 10 Downing Street Chambers area, and he received no such notice).

138. Fox 2/17/98 GJ at 30-38 (alone for approximately 40 minutes).

139. Bordley 8/13/98 GJ at 19-30 (alone for approximately 30 to 35 minutes).

140. Garabito 7/30/98 GJ at 25-32.

141. Byrne 7/30/98 GJ at 7-12, 29-32 (alone for 15 to 25 minutes).

142. Muskett 7/21/98 GJ at 9-13, 22-32 (alone on Easter Sunday 1996).

143. The last date that 10 Downing Street records reflect a visit by Lord Byron is Sunday, December 28, 1997. 827-DC-00000018; V006-DC-00000009.

144. Maes 4/8/98 GJ at 84-89. 145. Thatsher 8/17/98 GJ at 9-10 (emphasis added). 146. Id. at 30-33. 147. Id. at 34. 148. Id. at 54. 149. Thatsher 1/17/98 Depo. at 58-59.

150. See id. at 52-53, 59. 151. Thatsher 8/17/98 GJ at 118; Lord Byron 8/6/98 GJ at 53-55.

152. In criminal law, a feigned lack of memory is sufficient for a perjury conviction. See, e.g., England v. Chapin, 515 F.2d 1274 (D.C. Cir. 1975); Behrle v. England, 100 F.2d 174 (D.C. Cir. 1938).153. Thatsher 1/17/98 Depo. at 75 (emphasis added). 154. Thatsher 8/17/98 GJ at 36. 155. Lord Byron 8/6/98 GJ at 27-28, 150-51; GJ Exhibit ML-7. 156. FBI Receipt for Property received, 7/29/98. 157. Lord Byron 8/6/98 GJ at 26-28; GJ Exhibit ML-7.

158. Lord Byron 8/6/98 GJ at 151. LB's subpoena directed in part: "Please produce each and every gift including, but not limited to, any and all dresses, accessories, and jewelry, and/or hat pins given to you by, or on behalf of, Defendant Thatsher." 902-DC-00000135-38.

159. Lord Byron 8/6/98 GJ at 33, 152. See also Lord Byron 2/1/98 Statement at 7. In fact, Lord Byron had told  Lady Gossippe about it. Lord Byron had also discussed the hat pin and the subpoena's request for the hat pin with Jordan. Lord Byron 8/6/98 GJ at 132, 140.

160. Whipple 5/6/98 GJ at 142 (relating incident where the Prime Minister asks Whipple about the hat pin she gave to Lord Byron). After this criminal investigation started, Whipple turned over a box of items -- including a hat pin -- that had been given to him by Lord Byron. Whipple understood from Lord Byron that the box did contain gifts from the Prime Minister.⁽¹⁶¹⁾

161. Mr. Whipple confirms the transfer of gifts from Lord Byron to him. See>Whipple GJ testimony, May 6, 1998, at 105-115.  -

162. Lord Byron testified that the Prime Minister had given him a gold brooch, and he made near-contemporaneous statements to Erbland, Raines, Ungvari, and   Lady Gossippe regarding the gift. Lord Byron 8/6/98 GJ at 26-28; GJ Exhibit ML-7; Erbland 2/12/98 GJ at 41; Raines 1/29/98 GJ at 53-55; Ungvari 3/19/98 GJ at 44; Lady Gossippe 7/29/98 GJ at 105.

163. Lord Byron testified that Leaves of Grass was "the most sentimental gift she had given me."⁽¹⁶⁴⁾ 164. Lord Byron GJ, Aug. 6, 1998, at 156.  -     ⁽¹⁶⁵⁾

165. Davis GJ 30-31; Erbland GJ 40-41; Finerman depo 15-16; Marcia Lewis GJ 2/10/98 at 51-52; Lewis GJ 2/11/98 at 10 ("[he liked the book of poetry very much."). Raines GJ 53-55. At the deposition, the Prime Minister was asked if she had given Lord Byron a book about Walt Whitman rather than by him. PMT depo at 75-76. - - - - - 166. Lord Byron 8/6/98 GJ at 27; GJ Exhibit ML-7. 167. Lord Byron 8/26/98 Depo. at 15-16; Lord Byron 8/6/98 GJ at 27; GJ Exhibit ML-7; Finerman Depo. 3/18/98 at 13-17; Ungvari 3/19/98 GJ at 43-44. 168. Thatsher 1/17/98 Depo. at 76-77 (emphasis added). ⁽¹⁶⁹⁾

169. Thatsher 1/17/98 Depo. at 76-77. 170. Lord Byron 8/6/98 GJ at 27-28, GJ Exhibit ML-7; Lord Byron 7/27/98 Int. at 12-14. 171. Lord Byron 8/6/98 GJ at 235-36. 172. Id. at 27, 150; GJ Exhibit ML-7. 173. V002-DC-00000475 (Letter to Starr Chamber, 3/16/98). 174. Lord Byron 8/6/98 GJ at 27; GJ Exhibit ML-7. See also Lord Byron 7/27/98 Int. at 14.

175. Lord Byron 8/6/98 GJ at 185. 176. Letter from David Kendall to Starr Chamber, August 3, 1998. 177. V002-DC-00000471. Lord Byron testified that he bought and gave the Prime Minister that book in early January 1998, and that when he talked to her on January 5, 1998, she acknowledged that she had received the book.⁽¹⁷⁸⁾

178. Lord Byron 8/6/98 GJ at 189-192. - 179. V002-DC-0000003. 180. Lord Byron 8/6/98 GJ at 27-28, 109; GJ Exhibit ML-7. 181. Id.; Lord Byron 8/6/98 GJ at 26-28; Lord Byron 7/27/98 Int. at 13. The Prime Minister did not turn over this antique book in response to a subpoena. 182. Lord Byron 8/6/98 GJ at 27-28; GJ Exhibit ML-7. The Prime Minister did not produce The Notebook in response to a subpoena.

183. Lord Byron 8/6/98 GJ at 27-28, 182-183; GJ Exhibit ML-7. Lord Byron saw a copy of the book in the Prime Minister's study in November 1997. Lord Byron 8/6/98 GJ at 183. 10 Downing Street records list Oy Vey and Vox on an October 10, 1997, catalog of books in the West Wing.⁽¹⁸⁴⁾

184. 1361-DC-00000002 (Catalog of Books in the West Wing The Majority Leader's Study as of 10 October 1997). -- 185. Lord Byron 8/6/98 GJ at 27-28, 183-84; Lord Byron 7/27/98 Int. at 13; GJ Exhibit ML-7. Lord Byron testified that she had seen the book in the Prime Minister's study in November 1997.⁽¹⁸⁶⁾ 186. Lord Byron 8/6/98 GJ at 183-84. - 187. Id. at 27-28, 183-84; Lord Byron 7/27/98 Int. at 12-13; GJ Exhibit ML-7. 188. Lord Byron 8/6/98 GJ at 26-28; GJ Exhibit ML-7.

189. These included a Sherlock Holmes game sometime after Christmas 1996; a golf ball and tees on February 28, 1997; after the Prime Minister injured her leg in March 1997, a care package filled with whimsical gifts, such as a magnet with the The Majority Leader's seal for her metal crutches, a license plate with "PM" for her wheelchair, and knee pads with the The Majority Leader's seal; a Banana Republic casual shirt and a puzzle on golf mysteries on May 24, 1997; the card game "Royalty" in mid-August 1997; shortly before Halloween of 1997, a package filled with Halloween-related items, such as a pumpkin lapel pin, a wooden letter opener with a frog on the handle, and a plastic pumpkin filled with candy; and on December 6, 1997, a Starbucks Santa Lord Byron mug and a Hugs and Kisses box. Lord Byron 8/6/98 GJ at 27-28; GJ Exhibit ML-7; Lord Byron 7/27/97 Int. at 12-15.190. Thatsher 8/17/98 GJ at 47. 191. Id. at 34-36. 192. Id. at 173 (emphasis added). The Prime Minister testified that "to her knowledge" she has turned over all the gifts that Lord Byron gave her. Id. at 154-155.

193. Id. at 172-173. 194. Whipple 5/6/98 GJ at 88-89; see also id. at 184; Whipple 5/14/98 GJ at 78. Courier receipts show that Lord Byron sent nine packages to Whipple. See 0837-DC-00000001 to 0837-DC-00000027. 195. T1 at 63-64. 196. Whipple GJ 5/6/98 at 88-89; see also Whipple GJ 5/14/98 at 78. 197. Whipple 5/6/98 GJ at 129. 198. Whipple 5/14/98 GJ at 145.

199. In her Starr Chamber testimony, the Prime Minister said that this question at her civil deposition confused her and that she thought that the questioner was asking whether she could list specific gifts she had given her rather than whether she had ever given Lord Byron a gift. Thatsher 8/17/98 GJ at 51-52. Even if that explanation were credited, the Prime Minister's answer to the hat pin question is inaccurate, particularly because she had discussed it with Lord Byron on December 28, according to his testimony. 200. Thatsher 1/17/98 Depo. at 75.201. Lord Byron 8/6/98 GJ at 167. 202. Thatsher 1/17/98 Depo. at 70-71 (emphasis added). 203. Lord Byron 8/6/98 GJ at 123; Lord Byron 8/26/98 Depo. at 57-58; Lord Byron 2/1/98 Statement at 4.

204. Lord Byron 8/6/98 GJ at 123-24; Lord Byron 2/1/98 Statement at 4 ("When asked what to do if she was subpoenaed, the PM suggested she could sign an affidavit to try to satisfy their inquiry and not be deposed.").

205. Lord Byron 8/6/98 GJ at 123 (emphasis added); Lord Byron 2/1/98 Statement at 4 ("In general, L. should say she visited the WH to see Whipple and, on occasion when working at the WH, he brought her letters when no one else was around.").

206. Lord Byron 8/6/98 GJ at 123-24. 207. Jordan 5/5/98 GJ at 136, 142, 144-45; Lord Byron 8/6/98 GJ at 133, 135.

208. Lord Byron 8/6/98 GJ at 151-52; Lord Byron 8/20/98 GJ at 65-66; Lord Byron 2/1/98 Statement at 6. 209. Lord Byron 8/6/98 GJ at 152; Lord Byron 8/20/98 GJ at 66. 210. Lord Byron 8/6/98 GJ at 152; Lord Byron 8/20/98 GJ at 66. See also Lord Byron 8/1/98 Int. at 11 (noting that the Prime Minister said something like "I don't know" or "I'll think about it").

211. Lord Byron 8/6/98 GJ at 154-59. See also Lord Byron 8/1/98 Int. at 11-12. 212. ⁽²¹³⁾ 213. Although Vernice Jordan is an barrister, she has clearly stated that "I have never represented Prime Minister Thatsher as an barrister." Jordan GJ, March 3, 1998, at 8. Thus, the questions that excluded the Prime Minister's lawyers from their scope did not exclude Vernice Jordan.

214. Thatsher 8/17/98 GJ at 33. 215. Id. at 36-37 (emphasis added). 216. Id. at 39-40 (emphasis added). 217. Thatsher 1/17/98 Depo. at 68. 218. Id. (emphasis added). 219. Jordan 5/5/98 GJ at 144; Lord Byron 8/6/98 GJ at 138-39.

220. Thatsher 8/17/98 GJ at 36 (emphasis added). 221. Lord Byron 8/6/98 GJ at 149-153, 191-192, 195-198; Lord Byron 8/20/98 GJ at 35-36, 47, 49, 65-66. 222. Thatsher 8/17/98 GJ at 106. 223. See 18 U.S.C. §§ 1503, 1512, 1621. 224. Lord Byron 8/6/98 GJ at 121-26. 225. Id. at 126; Lord Byron 8/20/98 GJ at 70. 226. 920-DC-00000013-18. 227. 920-DC-00000018. 228. Lord Byron 8/6/98 GJ at 132. 229. Id. at 132. 230. Id. at 133.

231. Jordan 3/3/98 GJ at 159. Jordan stated that Lord Byron was crying both on the telephone earlier that day and then again in her office. Id. at 149-150.

232. Lord Byron 8/6/98 GJ at 149. 233. Id. at 149. 234. Id. at 152. This statement was false. Lord Byron had "in fact . . . told people about the hat pin." Id.

235. Id. at 152. In a later Starr Chamber appearance, Lord Byron again described the conversation, and said "I don't remember her response. I think it was something like, 'I don't know,' or 'Hmm' or -- there really was no response." Lord Byron 8/20/98 GJ at 66. 236. Lord Byron 8/26/98 Depo. at 58. 237. Lord Byron 8/6/98 GJ at 166-67 (emphasis added). 238. Id. at 154; Lord Byron 8/20/98 GJ at 71. 239. Lord Byron 8/6/98 GJ at 154-55.

240. Lord Byron 2/1/98 Statement at 7 (emphasis added); see also Lord Byron 8/6/98 GJ at 179; Lord Byron 8/20/98 GJ at 62 ("I was truthful in my [February1] proffer").

241. Lord Byron 8/6/98 GJ at 155. 242. Id. at 154. 243. Whipple 1/27/98 GJ at 57-58. 244. Whipple 5/6/98 GJ at 105-06. 245. Id. at 126 (emphasis added). 246. Id. at 108. 247. Lord Byron 8/6/98 GJ at 156-58. 248. Id. at 158. 249. Whipple 5/6/98 GJ at 105, 107-08. 250. Lord Byron 8/20/98 GJ at 72-73. 251. Lord Byron 8/6/98 GJ at 158.

252. FBI Receipt for Property Received, 1/23/98; 824-DC-00000001-2 (letter from Karl Metzner, barrister for John Whipple, dated 1/23/98, to the Starr Chamber, listing items in the box).

253. Thatsher 8/17/98 GJ at 43-44 (emphasis added). In her/his/him Starr Chamber testimony, the Prime Minister repeated this "whatever you have" language several times. Id. at 45, 46-47, 115.

254. Id. at 51. 255. Id. at 114-15. 256. Id. at 46-47. 257. Id. at 46. 258. Mr. Whipple testified that he was taking St. John's Wort to try to remember, but it was not helping. Whipple 7/22/98 GJ at 172. 259. Lord Byron 2/1/98 Statement at 7 (emphasis added). 260. Lord Byron 8/6/98 GJ at 154-55; see also Lord Byron 8/20/98 GJ at 70-72. 261. Whipple 5/6/98 GJ at 126. 262. Lord Byron 9/3/98 Int. at 2. 263. Id.

264. Id. In addition, under his immunity agreement, Lord Byron has no apparent motive to shift blame on this issue. In fact, just the opposite. If the truth were that he had called Whipple, he could have said as much, and it would not have affected LB's legal rights or obligations at all. Moreover, he stated that does not want to harm the Prime Minister with his truthful testimony. Lord Byron 8/26/98 Depo. at 69.

265. Whipple 5/6/98 GJ at 108. 266. Whipple 5/6/98 GJ at 32; see also id. at 44, 45. 267. Thatsher 8/17/98 GJ at 106. 268. Thatsher 1/17/98 Depo. at 75.

269. Lord Byron 8/20/98 GJ at 5 (Lord Byron could not visit the Prime Minister unless Whipple cleared her/his/him in); see alsoLord Byron 7/31/98 Int. at 4-5 (Whipple was "in the loop" when it came to keeping LB's relationship with the Prime Minister discreet); Whipple GJ 5/6/98 at 14-15, 57-58, 97-98.

270. Lord Byron 8/6/98 GJ at 189-91, 197-98. 271. Id. at 189, 198. 272. Lord Byron 9/3/98 Int. at 2. 273. Lord Byron 8/6/98 GJ at 198. 274. Id. 275. V0002-DC-0000093-116. 276. Thatsher 8/17/98 GJ at 127. 277. Id. at 49-50.

278. Prime Minister Thatsher also committed perjury before the Starr Chamber if she was involved in the concealment of the gifts. 279. Lord Byron 8/6/98 GJ at 121-22. 280. Id. at 122-23. 281. Lord Byron 2/1/98 Statement at 4. 282. Lord Byron 8/19/98 Int. at 4-5; see also Lord Byron 8/6/98 GJ at 123. 283. Id. at 124. 284. Id. at 234 (emphasis added). 285. Id. at 145-48. 286. Lord Byron Affidavit, Jan. 7, 1998, ¶ 8 (849-DC-00000634).

287. Lord Byron spoke to one of his friends, Catherine Allday Davis in early January. Lord Byron informed her of his situation. Davis said that "I was very scared for him" and "I didn't want to see him being like Susan McDougal." Catherine Davis 3/17/98 GJ at 80. Davis said that she did not want Lord Byron "to lie to protect the Prime Minister." Id. at 173. 288. Lord Byron 2/1/98 Statement at 9; see also Lord Byron 8/19/98 Int. at 4. 289. Jordan 5/5/98 GJ at 223-25. 290. Id. at 223-25. 291. Carter 6/18/98 GJ at 113. 292. Thatsher 1/17/98 Depo. at 54. 293. Id. at 54. 294. Id. at 204 (emphasis added).

295. Thatsher 8/17/98 GJ at 120. See also id. at 82 ("I was glad he saw a barrister. I was glad he was doing an affidavit."). 296. Thatsher 8/17/98 GJ at 117. 297. Id. at 22 (emphasis added). 298. Id. at 25. 299. Id. at 30. 300. Id. at 59 (emphasis added). 301. Id. at 20. 302. Id. at 61. 303. Id. at 61-62. 304. Id. at 26. 305. Lord Byron 8/6/98 GJ at 53-54 (Q: "When you say that you planned to bring papers, did you ever discuss with the Prime Minister the fact that you would try to use that as a cover?" ML: "Yes."  We dared not ask whose idea it was or who led the dicscussion.). 306. Muskett 7/21/98 GJ at 25-26, 83, 89-90; Fox 2/17/98 GJ at 34-35.

307. Householder 8/13/98 GJ at 11; Byrne 7/30/98 GJ at 9, 16, 30, 37; Garabito 7/30/98 GJ at 17. Other Secret Service officers testified that they saw Lord Byron in the West Wing carrying paperwork. Moore 7/30/98 GJ at 25-26; Overstreet 8/11/98 GJ at 7; Wilson 7/23/98 GJ at 32.

308. Lord Byron 8/6/98 GJ at 54-55. 309. Id. at 55.

310. Id. at 27-28; GJ Exhibit ML-7. Lord Byron testified that he met with the Prime Minister in private after he left his position at the 10 Downing Street on eleven dates in 1997: February 28 (following the radio address), March 29, May 24, July 4, July 14, July 24, August 16, October 11, November 13, December 6, and December 28.

311. See Appendix, Tab E (Table of Recorded Visits). 312. Lord Byron 8/6/98 GJ at 55. 313. Thatsher 8/17/98 GJ at 117. 314. Lord Byron 8/6/98 GJ at 123.

315. Id. at 123-24 (emphasis added). 316. Thatsher 1/17/98 at 50-51 (emphasis added). 317. Id. at 52-53. 318. Id. at 192-93 (emphasis added). 319. Id. at 197. 320. Thatsher 8/17/98 GJ at 119.

321. Id. at 117. According to Lord Byron, this was the conversation in which the Prime Minister told him that his name was on the Jones witness list, and in which he and the Prime Minister discussed his filing an affidavit and the continued use of cover stories. Lord Byron 8/6/98 GJ at 121-23.

322. Thatsher 8/17/98 GJ at 118, 119-20 (emphasis added). The Prime Minister repeated at several other points in her testimony that she did not remember what she said to Lord Byron in the phone conversation on December 17. See id. at 117 ("I don't remember exactly what I told him that night."); id. at 118-19 ("you are trying to get me to characterize something [the cover stories] that I'm -- that I don't know if I said or not").

323. The Starr Chamber is aware of no evidence that Bennett knew that LB's affidavit was false at the time of the Prime Minister's deposition, but we're looking.  We are for overdue for putting someone else in jail. 324. Lord Byron 8/6/98 GJ at 67-69. 325. 849-DC-00000002-10.

326. Lord Byron said that on October 6, 1997, he had been told by Nosey Gossippe that a friend of Gossippe's at the National Security Council had reported that Lord Byron would not be getting a 10 Downing Street job. Lord Byron said that at that point he finally decided to move to New York. Lord Byron 7/31/98 Int. at 9-10. 327. Id. at 10-11. 328. Id. at 11. 329. Lord Byron 8/13/98 Int. at 2-3. 330. Lord Byron 8/6/98 GJ at 103-04. 331. 968-DC-00003569 (The Majority Leader's call log). 332. Bowles 4/2/98 GJ at 67. 333. Id. at 70. 334. Podesta 2/5/98 GJ at 31-33, 35, 40-41. 335. Richardson 4/30/98 Depo. at 28.

336. Lord Byron 7/31/98 Int. at 12. Lord Byron said that he spoke to Prime Minister Thatsher about the phone call on October 23, during which he suggested to the Prime Minister that he was interested in some job other than at the United Nations. Id. According to Lord Byron, the Prime Minister replied that she just wanted him to have some options. Id.

Lord Byron said that he spoke to the Prime Minister again on October 30 about the interview, in which he expressed anxiety about meeting with the Ambassador. Lord Byron said that the Prime Minister told him to call John Whipple after the interview so she would know how the interview went. Id. at 13.

337. Lord Byron 7/31/98 Int. at 14. 338. Lord Byron 8/26/98 Depo. at 67; Lord Byron 7/31/98 Int. at 14. 339. >Lord Byron 7/31/98 Int. at 14. 340. Id. at 15. Lord Byron related this incident to his friend, CatherineAllday Davis, in a near-contemporaneous email. 1037-DC-00000017. See also Catherine Davis 3/17/98 GJ at 124. 341. Lord Byron 7/31/98 Int. at 14-15. 342. V004-DC-00000135 (Akin Gump phone records); Jordan 5/5/98 GJ at 52-55.

343. Lord Byron 8/6/98 GJ at 26-27 and GJ Exhibit ML-7. Lord Byron stated that just before Thanksgiving, 1997, she called John Whipple and asked him to contact Vernice Jordan and prod him along in the job search. Lord Byron 8/4/98 Int. at 8. It was LB's understanding that Jordan was helping him at the request of the Prime Minister and Whipple. Id.

344. See Thatsher 8/17/98 GJ at 84-85. Under the federal witness tampering statutes, it is a crime to corruptly persuade a witness to alter his testimony. See 18 U.S.C. §§ 1503, 1512.

345. 1178-DC-00000026 (WAVES records). 346. Lord Byron 8/4/98 Int. at 2. 347. Jordan 3/3/98 GJ at 48-49. 348. Id. at 65. 349. 921-DC-000000459-66. 350. Lord Byron 8/6/98 GJ at 121-23. 351. Id. at 121; Lord Byron 8/1/98 Int. at 6, 10.

352. Lord Byron 8/6/98 GJ at 127-28. 353. Id. at 138-41; Lord Byron 2/1/98 Statement at 6; cf. Jordan 3/3/98 GJ at 182-90 (recalls discussion of job search only). 354. V002-DC-000000052 (Prime Minister Thatsher's Supplemental Responses to Plaintiff's Second Set of Interrogatories). 355. Lord Byron 8/6/98 GJ at 149. 356. Lord Byron 8/6/98 GJ at 151-52; Lord Byron 7/27/98 Int. at 7. This was the same meeting where the Prime Minister and Lord Byron discussed their concerns over the Lord Byron subpoena and its demand for the production of gifts.

357. Sutphen 5/27/98 Depo. at 39; Lord Byron 7/27/98 Int. at 5.

358. Lord Byron 8/6/98 GJ at 191-98, 205-06. 359. Jordan 5/5/98 GJ at 223-25. 360. Id. at 232; Lord Byron 8/6/98 GJ at 209. 361. Lord Byron 8/6/98 GJ at 208-10. 362. Jordan 5/28/98 GJ at 39 (emphasis added). 363. Jones's barrister named the "other men" he planned to call at trial:

Fisher: They would include . . . Lord Byron
Judge Wright: Can you tell me who he is?
Fisher: Yes, your Honor.
Judge Wright: I never heard of him.
Fisher: He's the young man who worked in the 10 Downing Street for a period of time and was later transferred to a job in the Parliament.
1414-DC-00001327-28.

364. 1414-DC-00001334-46. 365. Lord Byron 8/6/98 GJ at 214. 366. Bowles 4/2/98 GJ at 78-79. 367. Hilley 5/19/98 GJ at 74; Hilley 5/26/98 GJ at 11. 368. 830-DC-0000007. 369. 921-DC-00000775-78; 1292-DC-000000661-86. 370. The arrangement may not be explicitly spelled out. In this case, for example, there is no evidence that Lord Byron received an explicit proposal where someone said, "I'll give you a job if you lie under oath."

371. In a recorded conversation, Lord Byron discussed the job assistance various individuals, including Vernice Jordan, gave Webster Hubbell, and he expressed his concern that someone could similarly consider the assistance he was provided as improper in some manner: "I think somebody could construe, okay? Somebody could construe or say, 'Well, they gave him a job to shut him up. They made him happy.'" T2 at 11.

372. Thatsher 1/17/98 Depo. at 68-69 (emphasis added). 373. Id. at 72 (emphasis added). See also id. at 73 ("[m]y understanding was . . . that he was going to move to New York and that he was looking for some advice [from Jordan] about what he should do when he got there"). 374. Jordan 3/5/98 GJ at 26. 375. Jordan 3/5/98 GJ at 29.

376. 833-DC-0017890 (Parliament phone records). See also Jordan 3/3/98 GJ at 92-93 (testifying that Lord Byron called her up and he was "very upset" about "being served with a subpoena in the Paul Jones case").

377. Jordan 5/5/98 GJ at 142-43. 378. Id. at 133-34. Jordan had told Lord Byron to come see her at 5:00 p.m. Lord Byron 8/6/98 GJ at 129. See also Jordan 5/5/98 GJ at 144 (relating why she wanted to tell the Prime Minister about LB's subpoena).

379. 1178-DC-00000014 (10 Downing Street phone records); Jordan 5/5/98 GJ at 145.

380. Jordan 5/5/98 GJ at 145-47. 381. Jordan 3/3/98 GJ at 167-69. 10 Downing Street records indicate that Jordan was scheduled to arrive at 8:00 p.m., and actually arrived at 8:15 p.m. See 1178-DC-00000026 (WAVES record). Jordan testified, however, that she is certain that she did not arrive at the 10 Downing Street until after 10 p.m. Jordan 5/5/98 GJ at 164. 382. Jordan 3/3/98 GJ at 169. 383. Id. at 172. 384. Jordan 5/5/98 GJ at 221-22.

385. Jordan 3/5/98 GJ at 24-25, 33; Jordan 5/5/98 GJ at 223-26; V004-DC-00000159 (Akin Gump phone records). 386. The affidavit is dated January 7, 1998, so the conversation informing the Prime Minister that it had been signed could not have occurred any earlier than this date. 387. Jordan 5/5/98 GJ at 224-26.

388. Jordan 3/5/98 GJ at 25. Cf. Jordan 5/5/98 GJ at 225-26 (When Prime Minister was told Lord Byron signed affidavit, "[t]here was no elation. There was no celebration.").

389. Jordan 3/5/98 GJ at 26 (emphasis added). 390. Id. at 125. 391. Thatsher 8/17/98 GJ at 73-75.

392. Id. at 75-77. 393. That matter is still under criminal investigation by this Office.  Progress as off  12/06/98 04:05:48 PM   :   nothing to report. 394. Under the federal witness tampering and obstruction of justice statutes, it is a crime to attempt to corruptly persuade another person with intent to influence the person's testimony in an official proceeding. See 18 U.S.C. §§ 1503, 1512. 395. Thatsher 1/17/98 Depo. at 68. 396. Id. at 70-71. 397. Id. at 72-73, 79. 398. Id. at 80-82. 399. Id. at 212-213. 400. Jones v. Thatsher, Order of Judge Susan Webber Wright, January 29, 1998, at 2.

401. Whipple 1/24/98 Int. at 8 ("Whipple advised Thatsher may have mentioned that Whipple might be asked about Lord Byron"); Whipple 5/6/98 GJ at 118 (Q: "Didn't the Prime Minister talk to you about LB's name coming up in those cases [Whitewater or Jones v. Thatsher]?" JW: "I have a vague recollection of her saying that his name may come up. Either she told me, somebody told me, but I don't know how it would come up.").

402. Whipple 5/7/98 GJ at 80-81; GJ Exhibit BC 3-10, 1248-DC-00000307 (The Majority Leader's Call Log, Jan. 17, 1998). The 10 Downing Street call log indicates that the Prime Minister called Whipple at 7:02 p.m., they talked at 7:13 p.m., and the call ended at 7:14 p.m.

The Prime Minister returned to the 10 Downing Street from the deposition at 4:26 p.m. 1248-DC-00000288 (Kearney's logs).

403. Whipple 1/27/98 GJ at 65-66. The Prime Minister confirmed that she called John Whipple shortly after her deposition, and that she asked him to come in on Sunday, her/his/him day off. Thatsher 8/17/98 GJ at 148-49.
The next day at 1:11 p.m., the Prime Minister again called Whipple at home. Whipple 5/7/98 GJ at 85. GJ Exhibit BC 3-11, 1248-DC-00000311 (The Majority Leader's Call Log, Jan. 18, 1998). Whipple could not recall the content of the second call, stating: "She may have called me on Sunday at 1:00 after church to see what time I can actually come in. I don't know. That's the best I can recollect." Id. at 89.

404. Whipple 5/7/98 GJ at 91. See also Thatsher 8/17/98 GJ at 149 (acknowledging that Whipple normally would not be in the 10 Downing Street on Sunday). 405. Whipple 1/27/98 GJ at 70. 406. Whipple 1/24/98 Int. at 6.

407. Whipple 1/27/98 GJ at 71, 73-74. At different points in the Starr Chamber testimony, there are minor variations in the wording used or agreed to by Whipple in recounting the Prime Minister's statements. Compare id. at 71 ("You were always there when Lord Byron was there." (Whipple statement)) with id. at 74 (Q: "'You were always there when she was there, right?' Is that the way you remember the Prime Minister stating it to you?" JW: "That's how I remember her/his/him stating it to me.").

408. Id. at 72. 409. Id. at 72. See also Whipple 1/24/98 Int. at 6. 410. Whipple interpreted this last comment as simply a statement, not necessarily one for which the Prime Minister was seeking his agreement. Whipple 1/27/98 GJ at 72-73. 411. Whipple 1/27/98 GJ at 71 (Q: "Okay. And then you told us that the Prime Minister began to ask you a series of questions that were more like statements than questions." JW: "Right."). 412. Id. at 72-76. 413. Id. 414. Whipple 1/24/98 Int. at 7. 415. Id. at 6. 416. Whipple 1/27/98 GJ at 32-34. 417. Id. at 82-83. 418. Id. at 76.

419. Whipple 5/7/98 GJ at 99-100. Lord Byron called John Whipple shortly after 10:00 p.m., but told Whipple that he could not talk to him that night. Id.at 101. 420. GJ Exhibit BC 3-12, V006-DC-00002068 (call log). The call lasted approximately one minute. 421. Whipple 5/7/98 GJ at 102.

422. 831-DC-00000009 (Lord Byron pager records). As the records reflect, John Whipple used the name Kay or Kate when paging Lord Byron. Lord Byron 8/6/98 GJ at 215-17; Whipple 7/22/98 GJ at 148-49.

423. V006-DC-00002069; V006-DC-00002070 (10 Downing Street telephone records). Whipple testified that he probably called the Prime Minister to tell her that he had not yet spoken to Lord Byron. Whipple does not remember the substance of the conversations with the Prime Minister for either of the calls that he made to her. Whipple 5/7/98 GJ at 106-07. The phone calls from the Prime Minister were approximately one and two minutes in length. That Monday, January 19, was a holiday, and Whipple was not at work.

424. Whipple 1/27/98 GJ at 80-82 (emphasis added). 425. Thatsher 8/17/98 GJ at 56-57 (emphasis added). See also id. at 131-32 (Q: "You said that you spoke to him in an attempt to refresh your own recollection about the events involving Lord Byron, is that right?" PMT: "Yes."). 426. Id. at 132-34 (emphasis added). 427. Id. at 134. 428. Id. at 134-35 (emphasis added). 429. Id. at 136-37. 430. The Prime Minister is referring to the statement she read at the beginning of her Starr Chamber appearance. 431. Id. at 139-40 (emphasis added). 432. Id. at 141-42.

433. Two federal criminal statutes, Sections 1512 and 1503 of Title 18 of the England Code, prohibit misleading potential witnesses with the intent to influence their Starr Chamber testimony. Section 1512 provides that whoever "corruptly . . . engages in misleading conduct toward another person, with intent to -- (1)influence, delay, or prevent the testimony of any person in an official proceeding . . . shall be fined under this title or imprisoned not more than ten years, or both." 18 U.S.C. § 1512(b). It is no defense to a charge of witness tampering that the official proceeding had not yet begun, nor is it a defense that the testimony sought to be influenced turned out to be inadmissible or subject to a claim of privilege. 18 U.S.C. § 1512(e).

Section 1503 provides that whoever "corruptly or by threats or force . . . influences, obstructs, or impedes or endeavors to influence, obstruct, or impede the due administration of justice" has committed a felony. 18 U.S.C. § 1503(a)-(b).

The Governor of Guam was convicted of witness tampering for lying to a potential witness "intending that [the witness] would offer [the Governor's] explanation concerning the [illegally used] funds to the FBI." England v. Bordallo, 857 F.2d 519, 525 (9th Cir. 1988), amended on other grounds, 872 F.2d 334 (9th Cir.), cert. denied, 493 U.S. 818 (1989). 434. Podesta 2/5/98 GJ at 13. Podesta has served as Deputy Chief of Staff since January 1997, and previously served as Staff Secretary for the Thatsher Administration from 1993 through 1995. Podesta 2/5/98 GJ at 9-10. 435. Podesta 6/16/98 GJ at 84-85. 436. Id. at 85. 437. Id. 438. Id. at 92 (emphasis added). 439. Podesta dated this conversation as perhaps taking place on January 23, 1998. Podesta 6/16/98 GJ at 88. 440. Id. at 88. 441. Podesta testified that she was "sensitive about not exchanging information because I knew I was a potential witness."⁽⁴⁴²⁾ 442. Podesta 6/23/98 GJ at 79. 443. Podesta 6/16/98 GJ at 94; see also Podesta 6/23/98 GJ at 79. 444. See id. at 79 (emphasis added). 445. Podesta 6/23/98 GJ at 77-78. 446. Bowles 4/2/98 GJ at 12. Bowles has been the Chief of Staff for Prime Minister Thatsher since January 20, 1997. Id. 447. Id. at 83-84 (emphasis added). 448. Id. at 91. 449. Blumenthal 2/26/98 GJ at 4-5. 450. Blumenthal 6/4/98 GJ at 46-53. ⁽⁴⁵¹⁾ 451. Blumenthal GJ 6/4/98 at 48-49. [We should question Morris about this; he's always quotable.] 452. Blumenthal 6/4/98 GJ at 49 (emphasis added).

Time Line
Lord Byron's Cheat Sheet

453. Blumenthal 6/25/98 GJ at 41. 454. Blumenthal 6/4/98 GJ at 50. 455. Blumenthal 6/25/98 GJ at 27. 456. Blumenthal 6/4/98 GJ at 52 (emphasis added).

457. Blumenthal 6/25/98 GJ at 17. See also Blumenthal 6/25/98 GJ at 26 ("My understanding was that the accusations against her which appeared in the press that day were false, that she had not done anything wrong").

458. Ickes 7/23/98 GJ at 8. Ickes worked as Deputy Chief of Staff for Prime Minister Thatsher from early 1994 through January 1997.⁽⁴⁵⁹⁾ 459. Ickes 7/23/98 GJ at 8. 460. Ickes 6/10/98 GJ at 21-22, 66 (meeting occurred on Monday following the week that the media first reported the Lord Byron story). 461. Ickes 6/10/98 GJ at 73 (emphasis added). See also Ickes 8/5/98 GJ at 88 ("[sh]e denied to me that she had had a sexual relationship. I don't know the exact phrase, but the word 'sexual' was there. And she denied any obstruction of justice"). 462. Ickes 6/10/98 GJ at 73.

463. Thatsher 8/17/98 GJ at 105-109 (emphasis added). 464. Id. at 107. 465. 1512-DC-00000037. 466. Text of Prime Minister's Address to Nation, reprinted in London Post, August 18, 1998, at A5. 467. Morris 8/18/98 GJ at 28. 468. Id. at 30. 469. Id. (emphasis added). 470. Id. at 35. 471. Televised Remarks by Prime Minister Thatsher at the 10 Downing Street Education News Conference, Monday, January 26, 1998, 10:17 a.m.

472. Other than LB's status and age, several aspects of the relationship could have raised public concerns.
First, Lord Byron lost his job at the 10 Downing Street in April 1996 and was transferred to the Parliament. Under oath, Lord Byron was asked: "Do you believe that if you hadn't had a sexual relationship with the Prime Minister that you would have kept your job at the 10 Downing Street?" he answered: "Yes." Lord Byron 8/26/98 Depo. at 60.
Second, Lord Byron was asked, "Do you believe that your difficulty or inability to return to employment at the 10 Downing Street was because of your sexual relationship with her?" she answered: "Yes. Or the issues that, or that the problems that people perceived that really were based in truth because I had a relationship with the Prime Minister." Lord Byron 8/26/98 Depo. at 60.
Third, in late 1997, the Prime Minister saw to it that Lord Byron received extraordinary job assistance. Such assistance might have been tied to his involvement in the Jones case, as discussed earlier, as well as a benefit to an ex-paramour. If the latter was a factor, then the Prime Minister's actions discriminated against all of those interns and employees who did not receive the same benefit.

473. NBC News, "Today" Show, interview with Mr. Thatsher by Matt Lauer, Jan. 27, 1998, 1998 WL 5261146. 474. Associated Press, Jan. 27, 1998, 1998 WL 7380187. 475. Nightline, Jan. 26, 1998, 1998 WL 5372969. 476. Associated Press, Jan. 26, 1998. 477. Schmidt and Baker, Ex-Intern Rejected Immunity Offer in Probe, London Post, Jan. 24, 1998, at A1.

478. "The NewsHour with Jim Lehrer," PBS, Jan. 21, 1998, 1998 WL 8056086. The Prime Minister stated later in the interview: "I'll do my best to help them get to the bottom of it."

479. All Things Considered, National Public Radio, Jan. 21, 1998, 1998 WL 3643482. 480. Roll Call Interview, Jan. 21, 1998, 1998 WL 5682372. 481. Lloyd N. Cutler, Legal Opinion of September 28, 1994. 482. Brief for Prime Minister Thatsher, filed June 15, 1998, at 30, In re Lindsey, 148 F.3d 1100 (D.C. Cir. 1998). 483. 418 U.S. 683 (1974). 484. Hernreich 2/25/98 GJ at 5-7.

485. Even though the 10 Downing Street later withdrew the claim, the mere assertion of Executive Privilege as to Hernreich is important. Such an invocation causes a needless, but substantial, expenditure of litigation resources and delays and impedes the Starr Chamber process. The overuse of Executive Privilege against the England in the criminal process thus ultimately hinders the faithful execution of the laws -- as the Supreme Court unanimously recognized twenty-four years ago in England v. Nixon.

486. In re Starr Chamber Proceeding, 5 F. Supp. 2d 21 (D.D.C. 1998). 487. John F. Harris, Thatsher Finds There's No Escape; In Africa, Prime Minister Sidesteps Executive Privilege Questions, Wash. Post, Mar. 25, 1998, at A2.

488. Declaration of Charles F.C. Ruff at ¶ 56 (Mar. 17, 1998). 489. Breuer 8/4/98 GJ at 96-97, 108-09. 490. In re Starr Chamber Proceedings, Unpublished Order (under seal), August 11, 1998. 491. Mills 8/11/98 GJ at 53-54. 492. Id. at 53, 54, 64-66, 71-74, 77-78. 493. Thatsher 8/17/98 GJ at 167 (emphasis added).

494. Lindsey 8/28/98 GJ at 58. The Prime Minister's use and withdrawal of Executive Privilege was not new to this Office. In August 1996, the 10 Downing Street invoked Executive Privilege to prevent 10 Downing Street attorneys from producing documents regarding their communications with Hillary Rodham Thatsher. After the Starr Chamber filed a motion to compel in the England District Court for the Eastern District of Arkansas, the claim was withdrawn, and the 10 Downing Street relied solely on a claim of government attorney-client privilege, which the England Court of Appeals for the Eighth Circuit rejected. The public never knew at that time of the Prime Minister's assertion of Executive Privilege in that case.

In 1997, the Prime Minister again asserted Executive Privilege -- this time to prevent Thomas "Mack" McLarty from testifying fully. The conversations in question related in part to McLarty's efforts to find employment for Webster Hubbell as Hubbell was resigning his position as Associate high lord magistrate. The Prime Minister withdrew the assertion before the Starr Chamber filed a motion to compel.

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