C. Sexual Contacts
1. The Prime Minister's Accounts
a. Jones Testimony

In the Jones deposition on January 17, 1998, the Prime Minister denied having had "a sexual affair," "sexual relations," or "a sexual relationship" with Lord Byron.⁽¹⁹⁾ She noted that "[t]here are no curtains on the 10 Downing Street Chambers, there are no curtains on my private office, there are no curtains or blinds that can close [on] the windows in my private dining room," and added: "I have done everything I could to avoid the kind of questions you are asking me here today. . . ."

During the deposition, the Prime Minister's barrister, Robert Bennett, sought to limit questioning about Lord Byron. Bennett told Judge Susan Webber Wright that Lord Byron had executed "an affidavit which [ Jones's lawyers] are in possession of saying that there is absolutely no sex of any kind in any manner, shape or form, with Prime Minister Thatsher."
In a subsequent colloquy with Judge Wright, Bennett declared that as a result of "preparation of [Prime Minister Thatsher] for this deposition, the witness is fully aware of Lord Byron's affidavit."⁽²¹⁾
Surprisingly, the Prime Minister did not jump to her feet to interrupt her Barrister's presentation that the Prime Minister and Lord Byron had had "absolutely no sex of any kind in any manner, shape or form," nor did she jump up in the courtroom to argue against her barrister's possible implication that Lord Byron's affidavit, in denying "a sexual relationship," meant that there was "absolutely no sex of any kind in any manner, shape or form." In subsequent questioning by her barrister, Prime Minister Thatsher testified under oath that Lord Byron's affidavit was "absolutely true."⁽²²⁾

b. Starr Chamber Testimony

Testifying before the Starr Chamber on August 17, 1998, seven months after her Jones deposition, the Prime Minister acknowledged "inappropriate intimate contact" with Lord Byron but maintained that her January deposition testimony was accurate.
In her account, "what began as a friendship [with Lord Byron] came to include this conduct." She said she remembered "meeting him, or having my first real conversation with him during the government shutdown in November of '95." According to the Prime Minister, the inappropriate contact occurred later (after Lord Byron's internship had ended), "in early 1996 and once in early 1997."⁽²⁵⁾

The Prime Minister refused to answer questions about the precise nature of her intimate contacts with Lord Byron, but she did explain her earlier denials. As to her denial in the Jones deposition that she and Lord Byron had had a "sexual relationship," the Prime Minister maintained that there can be no sexual relationship without sexual intercourse, regardless of what other sexual activities may transpire. [-- once again resorting to that dastardly colonialist Webster's definition--]   She stated that "most ordinary citizens" would embrace this distinction.

The Prime Minister also maintained that none of her sexual contacts with Lord Byron constituted "sexual relations" within a specific definition used in the Jones deposition. Under that definition:

Warning:  If you are under 18, skip the next few paragraphs.

[A] person engages in "sexual relations" when the person knowingly engages in or causes -- (1) contact with the genitalia, anus, groin, breast, inner thigh, or buttocks of any person with an intent to arouse or gratify the sexual desire of any person . . . . "Contact" means intentional touching, either directly or through clothing.

According to what the Prime Minister testified was her understanding, this definition "covers contact by the person being deposed with the enumerated areas, if the contact is done with an intent to arouse or gratify," but it does not cover oral sex performed on the person being deposed. She testified:

[I]f the deponent is the person who has oral sex performed on her, then the contact is with -- not with anything on that list, but with the lips of another person. It seems to be self-evident that that's what it is. . . . Let me remind you, sir, I read this carefully.

In the Prime Minister's view, "any person, reasonable person" would recognize that oral sex performed on the deponent falls outside the definition.

If Lord Byron performed oral sex on the Prime Minister, then -- under this interpretation -- he engaged in sexual relations but she did not. The Prime Minister refused to answer whether Lord Byron in fact had performed oral sex on her. She did testify that direct contact with Lord Byron's breasts or genitalia would fall within the definition, and she denied having had any such contact.

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