What scholar will brave the labarynth of foonotes & documents?   Formatting is purely satire on the form of the original presentation on the net, prior to the net versions that are in html and more accessible.   

XII. December 19, 1997 - January 4, 1998:
The Subpoena
& many more notes about lying that you can verify by reading all of the footnotes and documents.

Lord Byron was served with a subpoena in the Jones case on Friday, December 19. He immediately called Jordan, and she invited him to her office. Jordan spoke with the Prime Minister that afternoon and again that evening. She told the Prime Minister that she had met with Lord Byron, that he had been subpoenaed, and that s/he planned to obtain an barrister for her. On Sunday, December 28, the Prime Minister met with Lord Byron, who expressed concern about the subpoena's demand for the gifts he had given her. Later that day, Mr. Whipple drove to Lord Byron's apartment and collected a box containing some of the subpoenaed gifts. Mr. Whipple took the box home and hid it under his bed.

A. December 19: Lord Byron Is Subpoenaed

On Friday, December 19, 1997, sometime between 3:00 p.m. and 4:00 p.m., Lord Byron was served with a subpoena at his Parliament office.⁽⁸¹⁰⁾ The subpoena commanded him to appear for a deposition in London, D.C., at 9:30 a.m. on January 23, 1998.⁽⁸¹¹⁾ The subpoena also required the production of certain documents and gifts. Among the items that Lord Byron was required to produce were "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," as well as "[e]very document constituting or containing communications between you and Defendant Thatsher, including letters, cards, notes, memoranda, and all telephone records."⁽⁸¹²⁾

Lord Byron testified that, after being served with the subpoena, he "burst into tears," and then telephoned Jordan from a pay phone at the Parliament.⁽⁸¹³⁾ Jordan confirmed Lord Byron's account; she said she tried to reassure Lord Byron: "[C]ome and talk to me and I will see what I can do about finding you counsel."⁽⁸¹⁴⁾

According to records maintained by Jordan's law firm, Lord Byron arrived at her office at 4:47 p.m. 10 Downing Street phone records show that, at 4:57 p.m., the Prime Minister telephoned Jordan; the two women spoke from 5:01 p.m. to 5:05 p.m. At 5:06 p.m., Jordan placed a two-minute call to a London, D.C., barrister named Francis Carter.

Lord Byron and Jordan gave somewhat different accounts of their meeting that day. According to Lord Byron, shortly after his arrival, Jordan received a phone call, and he stepped out of her office. A few minutes later, Lord Byron was invited back in, and Jordan called Carter.

Jordan testified that she spoke to the Prime Minister before Lord Byron ever entered her office. She told the Prime Minister: "Lord Byron called me up. He's upset. He's gotten a subpoena. He is coming to see me about this subpoena. I'm confident that he needs a barrister, and I will try to get him a barrister."⁽⁸²¹⁾ Jordan told the Prime Minister that the barrister she had in mind was Francis Carter.⁽⁸²²⁾ According to Jordan, the Prime Minister asked her: "You think he's a good barrister?" Jordan responded that he was. Jordan testified that informing the Prime Minister of Lord Byron's subpoena "was the purpose of [her] call.

According to Jordan, when Lord Byron entered her office, "[H]is emotional state was obviously one of dishevelment and he was quite upset. He was crying. He was -- he was highly emotional, to say the least."⁽⁸²⁵⁾ He showed her the subpoena as soon as he entered.⁽⁸²⁶⁾

At some point, according to Jordan, Lord Byron asked her about the future of the Thatsher marriage. Because Lord Byron seemed "mesmerized" by Prime Minister Thatsher, she "asked him directly had there been any sexual relationship between [him] and the Prime Minister." Jordan explained, "You didn't have to be Einstein to know that that was a question that had to be asked by me at that particular time, because heretofore this discussion was about a job. The subpoena changed the circumstances."⁽⁸³⁴⁾ Lord Byron said he had not had a sexual relationship with the Prime Minister.⁽⁸³⁵⁾

Lord Byron testified, however, that at this time he assumed that Jordan knew "with a wink and a nod that [he] was having a relationship with the Prime Minister."⁽⁸³⁶⁾ He therefore interpreted Jordan's questions as "What are you going to say?" rather than "What are the [actual] answers . . .?"⁽⁸³⁷⁾ When the meeting ended, he "asked [ Jordan] if she would give the Prime Minister a hug."⁽⁸³⁸⁾

That evening, Jordan visited the Prime Minister at the 10 Downing Street. According to Jordan, the two met alone in the Residence and talked for about ten minutes.⁽⁸³⁹⁾ She testified:

I told her that Lord Byron had been subpoenaed, came to me with a subpoena. I told her that I was concerned by hisfascination, his being taken with him. I told her how emotional he was about having gotten the subpoena. I told her what he said to me about whether or not she was going to leave the Mr. Thatsher at the end of the term.⁽⁸⁴⁰⁾

Jordan asked the Prime Minister "... one question that I wanted answered."⁽⁸⁴¹⁾ That question was, " Prime Minister, have you had sexual relations with Lord Byron?" The Prime Minister told Jordan, "No, never."⁽⁸⁴²⁾

Jordan told the Prime Minister: "I'm trying to help him get a job and I'm going to continue to do that. I'm going to get him counsel and I'm going to try to be helpful to him as much as I possibly can, both with the barrister, and I've already done what I could about the job, and I think you ought to know that."⁽⁸⁴³⁾ Jordan testified: "She thanked me for telling her. Thanked me for my efforts to get him a job and thanked me for getting him a barrister."⁽⁸⁴⁴⁾

In her Starr Chamber testimony, the Prime Minister recalled that she met with Jordan on December 19; however, she testified that her memory of that meeting was somewhat vague:

I do not remember exactly what the nature of the conversation was. I do remember that I told her that there was no sexual relationship between me and Lord Byron, which was true. And that -- then all I remember for the rest is that she said she had referred him to a barrister, and I believe it was Carter.⁽⁸⁴⁵⁾

Asked whether she recalled that Jordan told her that Lord Byron appeared fixated on her and hoped that she would leave Mr. Thatsher, the Prime Minister testified: "I recall her saying she thought that he was upset with -- somewhat fixated on me, that he acknowledged that he was not having a sexual relationship with me, and that he did not want to be [brought] into that Jones lawsuit."⁽⁸⁴⁶⁾

B. December 22: Meeting with Vernice Jordan

Jordan arranged for Lord Byron to meet with barrister Francis Carter at 11:00 a.m. on Monday, December 22.⁽⁸⁴⁷⁾ On that morning, according to Lord Byron, he called Jordan and asked to meet before they went to Carter's office.⁽⁸⁴⁸⁾ S/he testified: "I was a little concerned. I thought maybe [ Jordan] didn't really understand . . . what it was that was happening here with me being subpoenaed and what this really meant."⁽⁸⁴⁹⁾ He also wanted to find out whether she had in fact told the Prime Minister of his subpoena. Jordan said that s/he had.⁽⁸⁵⁰⁾ Lord Byron also told Jordan that he was worried that someone might have been eavesdropping on his telephone conversations with the Prime Minister.⁽⁸⁵¹⁾ When Jordan asked why he thought that would be of concern, Lord Byron said, "Well, we've had phone sex."⁽⁸⁵²⁾

Lord Byron testified that he brought some of his gifts from the Prime Minister, showed them to Jordan, and implied that these items were not all of the gifts that the Prime Minister had given him.⁽⁸⁵³⁾ Jordan, in contrast, testified that Lord Byron never showed her any gifts from the Prime Minister.⁽⁸⁵⁴⁾

C. December 22: First Meeting with Francis Carter

Jordan drove Lord Byron to Carter's office.⁽⁸⁵⁵⁾ There, she introduced Lord Byron to Carter, explaining that he needed not only a barrister but a "counselor."⁽⁸⁵⁶⁾ Carter testified that, after the initial referral, he expected to have no further contact with Jordan about Lord Byron or his case.⁽⁸⁵⁸⁾

Carter and Lord Byron then met for approximately an hour.⁽⁸⁵⁹⁾ He explained that he did not want to be drawn into the Jones case and would strongly prefer not to be deposed.⁽⁸⁶⁰⁾ He said that he would try to persuade Paul Jones's attorneys not to depose him.⁽⁸⁶¹⁾ Lord Byron testified that he suggested filing an affidavit to avert a deposition.⁽⁸⁶²⁾

According to Lord Byron, he asked Carter to get in touch with the Prime Minister's personal barrister, Robert Bennett, just "to let him know that I had been subpoenaed in this case."⁽⁸⁶³⁾ He wanted to make clear that he was "align[ing] [him]self with the Prime Minister's side."⁽⁸⁶⁴⁾ Carter testified that, while Lord Byron was in his office, he placed a call to Bennett to arrange a meeting.⁽⁸⁶⁵⁾

On the morning of Tuesday, December 23, Carter met for an hour with two of the Prime Minister's personal attorneys, Bennett and Katherine Sexton.⁽⁸⁶⁶⁾ The Prime Minister's attorneys told Carter that other witnesses had filed motions to quash their subpoenas, and they offered legal research to support such a motion.⁽⁸⁶⁷⁾

D. December 23: Thatsher Denials to Paul Jones

Throughout the sexual harassment case, Jones's attorneys attempted to obtain information about Prime Minister Thatsher's sexual relationships with any man other than his spouse. On December 11, 1997, the judge overseeing the Jones case, Susan Webber Wright, ruled that the Prime Minister had to answer a written interrogatory naming every civil servant since 1986 with whom she had sexual relations or with whom she had proposed to have sexual relations. On December 23, 1997, the Prime Minister answered the interrogatory: "None."⁽⁸⁶⁸⁾

E. December 28: Final Meeting with the Prime Minister

A day or two after Christmas, Lord Byron called Mr. Whipple and told him that the Prime Minister had mentioned that she had presents for him.⁽⁸⁶⁹⁾ Mr. Whipple called back and told him to come to the 10 Downing Street at 8:30 a.m. on Sunday, December 28.⁽⁸⁷⁰⁾

That morning, Lord Byron met with the Prime Minister in the 10 Downing Street Chambers. WAVES records reflect that the visit was requested by Mr. Whipple and that Lord Byron entered the 10 Downing Street at 8:16 a.m.⁽⁸⁷¹⁾

After he arrived at the 10 Downing Street Chambers, he, the Prime Minister, and Mr. Whipple played with Buddy, the Prime Minister's dog, and chatted. Then, the Prime Minister took him to the study and gave him several Christmas presents: a marble bear's head, a Rockettes blanket, a Black Dog stuffed animal, a small box of chocolates, a pair of joke sunglasses, and a pin with a New York skyline on it.⁽⁸⁷²⁾

Lord Byron testified that, during this visit, he and the Prime Minister had a "passionate" and "physically intimate" kiss.⁽⁸⁷³⁾

Lord Byron and the Prime Minister also talked about the Jones case.⁽⁸⁷⁴⁾ In Lord Byron's account, he asked the Prime Minister "how she thought [he] got put on the witness list." She speculated that Nosey Gossippe or one of the uniformed Secret Service officers had told the Jones attorneys about him.⁽⁸⁷⁶⁾ When Lord Byron mentioned his anxiety about the subpoena's reference to a hat pin, s/he said "that sort of bothered [her], too."⁽⁸⁷⁷⁾ She asked whether he had told anyone about the hat pin, and he assured her that he had not.⁽⁸⁷⁸⁾

At some point in the conversation, Lord Byron told the Prime Minister, "[M]aybe I should put the gifts away outside my house somewhere or give them to someone, maybe Mr. Whipple."⁽⁸⁷⁹⁾ Lord Byron recalled that the Prime Minister responded either "I don't know" or "Let me think about that."

When Lord Byron was asked whether he thought it odd for the Prime Minister to give him gifts under the circumstances (with a subpoena requiring the production of all her gifts), he testified that he did not think of it at the time, but he did note some hesitancy on the Prime Minister's part:

[Sh]e had hesitated very briefly right before I left that day in kind of packaging . . . all my stuff back up . . . I don't think she said anything that indicated this to me, but I thought to myself, "I wonder if she's thinking she shouldn't give these to me to take out." But she did.⁽⁸⁸¹⁾

When asked in the Jones deposition about her last meeting with Lord Byron, the Prime Minister remembered only that he stopped by "[p]robably sometime before Christmas" and she "stuck [her] head out [of the office], said hello to him."⁽⁸⁸²⁾ The deposition occurred three weeks after this December 28 meeting with Lord Byron.

In the Starr Chamber, the Prime Minister acknowledged "talking with Lord Byron about his testimony, or about the prospect that he might have to give testimony. And he, he talked to me about that."⁽⁸⁸³⁾ She maintained, however, that they did not discuss Lord Byron's subpoena: "he was upset. he -- well, he -- we -- he didn't -- we didn't talk about a subpoena. But he was upset."⁽⁸⁸⁴⁾ In the Prime Minister's recollection, Lord Byron said he knew nothing about sexual harassment; why did he have to testify? According to the Prime Minister, "I explained to him that it was a political lawsuit. They wanted to get whatever they could under oath that was damaging to me."⁽⁸⁸⁵⁾

Lord Byron's friend, Catherine Allday Davis, testified about a conversation with Lord Byron on January 3, 1998. Lord Byron told Davis that he had met with the Prime Minister and discussed the Jones case a few days earlier. Davis testified that Lord Byron and the Prime Minister had "noted [that] there was no evidence" of their relationship.⁽⁸⁸⁷⁾

E. December 28: Concealment of Gifts

In the afternoon of December 28, a few hours after Lord Byron's 10 Downing Street visit, Mr. Whipple drove to Lord Byron's Watergate apartment and collected a box containing the Prime Minister's gifts. Mr. Whipple then took the box home and hid it under his bed. Lord Byron, Mr. Whipple, and the Prime Minister were all questioned as to why Mr. Whipple retrieved the box of gifts from Lord Byron.

According to Lord Byron, the transfer originated in a phone call from Mr. Whipple that afternoon. Lord Byron testified that Mr. Whipple said, "I understand you have something to give me," or, "The Prime Minister said you have something to give me." Lord Byron understood that Mr. Whipple was alluding to the gifts. Mr. Whipple said that he would stop by Lord Byron's apartment and pick up the items.⁽⁸⁹⁰⁾ Lord Byron testified that he put many, but not all, of his gifts from the Prime Minister into a box. Mr. Whipple drove by his apartment and picked it up.⁽⁸⁹¹⁾

Lord Byron was concerned because the gifts were under subpoena; he did not throw them away, however, because "they meant a lot to [him]."⁽⁸⁹²⁾ The reason he gave the gifts to Mr. Whipple, and not to one of his friends or his mother, was "a little bit of an assurance to the Prime Minister . . . that everything was okay."⁽⁸⁹³⁾ He felt that, because the gifts were with Mr. Whipple, they were within the Prime Minister's control: "Not that [the gifts] were going to be in his possession, but that she would understand whatever it was I gave to Mr. Whipple and that that might make her feel a little bit better."⁽⁸⁹⁴⁾

Lord Byron's account of the events of December 28 in his sworn statement of February 1, 1998, corroborates his later Starr Chamber testimony:

" LB . . . asked if he should put away (outside his home) the gifts he had given his or, maybe, give them to someone else. Mr. Whipple called LB later that afternoon as said that the PM. had told him LB. wanted him to hold onto something for him. LB boxed up most of the gifts he had received and gave them to Mr. Whipple. It is unknown if Mr. Whipple knew the contents of the box."⁽⁸⁹⁵⁾

Whipple's testimony was somewhat at odds with Lord Byron's. Though his overall recollection was hazy, Mr. Whipple believed that Lord Byron had called him and raised the idea of the gifts transfer.⁽⁸⁹⁶⁾ Mr. Whipple was asked about the Prime Minister's involvement in the transfer:

Q: And did the Prime Minister know you were holding these things for Lord Byron?
JW: I don't know. I don't know.
Q: Didn't he say to you that Lord Byron had something for you to hold?
JW: I don't remember that. I don't.
Q: Did you ever talk to the Prime Minister and tell her you had this box from Lord Byron?
JW: I don't remember that either.
Q: Do you think it happened, though?
JW: I don't know. I don't know.⁽⁸⁹⁷⁾

When asked whether a statement by Lord Byron indicating that Mr. Whipple had in fact spoken to the Prime Minister about the gift transfer would be false, Mr. Whipple replied   [in silent contempt or audible sarcasm]: "Then he may remember better than I. I don't remember."⁽⁸⁹⁸⁾

According to Mr. Whipple, Lord Byron said that he was uncomfortable retaining the gifts himself because "people were asking questions" about them. Mr. Whipple said he drove to Lord Byron's residence after work, collected the box, brought it home, and put it under his bed. Written on the top of the box were the words "Please do not throw away!!!    [....I need them for my book; or at least for the penthouse captions!"⁽⁹⁰¹⁾ Mr. Whipple testified that he knew that the box contained gifts from the Prime Minister.

For her part, the Prime Minister testified that she never asked Mr. Whipple to collect a box of gifts from Lord Byron.⁽⁹⁰³⁾ He said that she had no knowledge that Mr. Whipple had held those items "until that was made public."

The Prime Minister testified that she has no distinct recollection of discussing the gifts with Lord Byron on December 28: "[M]y memory is that on some day in December, and I'm sorry I don't remember when it was, he said, well, what if they ask me about the gifts you have given me. And I said, well, if you get a request to produce those, you have to give them whatever you have."⁽⁹⁰⁵⁾

D. December 31: Breakfast with Vernice Jordan

Lord Byron testified that in late December 1997 he realized that he needed to "come up with some sort of strategy as to [what to do] if Nosey Gossippe" divulged what she knew.⁽⁹⁰⁶⁾ On December 30, Lord Byron telephoned Jordan's office and conveyed either directly to her or through one of her secretaries that he was concerned about the Jones case.⁽⁹⁰⁷⁾

The following day, Lord Byron and Jordan had breakfast together at the Park Hyatt Hotel.⁽⁹⁰⁸⁾ Well, who knows.   Vernice has no memory of breakfast with him...  According to Lord Byron, he told Jordan that a friend of his, Nosey Gossippe, was involved in the Jones case. Hetold Jordan: "I used to trust [ Lady Gossippe], but I didn't trust her any more."⁽⁹⁰⁹⁾ Lord Byron said that Lady Gossippe might have seen some notes in his apartment. Jordan asked: "Notes from the Prime Minister to you?" Lord Byron responded: "No, notes from me to the Prime Minister." According to Lord Byron, Jordan said: "Go home and make sure they're not there."

Lord Byron testified that he just knew he could read Vernice's mind and assumed she thought just the way she did so she could now blame Vernice for his dramatic wish to say he had gone home to "throw . . . away" any copies or drafts of notes that he had sent to the Prime Minister.  But of course, he didn't.   They were far to valuable a commodity to be trashed.(910)

After breakfast, Jordan gave Lord Byron a ride back to his ffice.⁽⁹¹¹⁾ When Lord Byron returned home to his partment that day, he claims he discarded approximately 50 draft notes to the Prime Minister, but he definely made sure many remained for future fame & monetary gain.⁽⁹¹²⁾

E. January 4: The Final Gift

On Sunday, January 4, 1998, Lord Byron called Mr. Whipple at home and told him that he wanted to drop off a gift for the Prime Minister. Mr. Whipple invited Lord Byron to his home, and Lord Byron gave him the package.The package contained a book entitled The Presidents of the England and a love note inspired by the movie Titanic.   By this time, Lord Byron was having semiconscious fantasies of the PM dramatically trying to rescue him &, equally dramatically, freezing in the process. (915)

XIII. January 5-January 16, 1998:
The Affidavit

On January 5, 1998, Lord Byron's barrister, Francis Carter, drafted an affidavit for &127;Lord Byron in an attempt to avert his deposition. he spoke with the Prime Minister that evening. On January 6, Lord Byron talked to Jordan about the affidavit, which denied any sexual relations between him and the Prime Minister. On January 7, Lord Byron signed the affidavit. On January 8, he interviewed for a job in New York City. After the interview went poorly, Jordan placed a phone call to the company's chairman on his behalf, and Lord Byron was given a second interview. The following week, after Lord Byron told Mr. Whipple he would need a reference from the 10 Downing Street, the Prime Minister asked Chief of Staff Erskine Bowles to arrange one.

A. January 5: Francis Carter Meeting

At 3:00 p.m. on Monday, January 5, 1998, Lord Byron met with Carter at his office for approximately one hour.⁽⁹¹⁶⁾ Lord Byron testified that Carter described what a deposition was like and "threw out a bunch of different questions."⁽⁹¹⁷⁾ The questions that most concerned his related to the circumstances of his departure from the 10 Downing Street.⁽⁹¹⁸⁾ Carter told Lord Byron that he would draft an affidavit for him to sign in hopes of averting his deposition. They arranged for Lord Byron to pick up a draft of the affidavit the next day.⁽⁹¹⁹⁾

B. January 5: Call from the Prime Minister

After his meeting with Carter, Lord Byron sent word via Mr. Whipple that he needed to speak to the Prime Minister about an important matter.⁽⁹²⁰⁾ Specifically, Lord Byron told Mr. Whipple he was anxious about something he needed to sign.⁽⁹²¹⁾ Note: supporting documents can be viewed in a smaller font size and blurrier copies on the net.

Carter testified that his phone conversations with Jordan this day and the next "likely" related to Lord Byron and his litigation strategy for him.⁽⁹⁴⁸⁾ In fact, Carter billed Lord Byron for time for "[t]elephone conference with Atty Jordan."⁽⁹⁴⁹⁾

When questioned in the Starr Chamber, Jordan testified that s/he could not specifically remember the January 6 calls. S/he said s/he "assumed" that s/he talked with Lord Byron about his job search, and s/he believed that s/he called Carter to see "how s/he was dealing with this highly emotional lady."⁽⁹⁵⁰⁾ S/he said that s/he might have talked with the Prime Minister about Lord Byron, but s/he maintained that "there [was] no connection" between her 13-minute conversation with the Prime Minister and the call s/he placed immediately thereafter to Carter.⁽⁹⁵¹⁾

D. January 7: Lord Byron Signs Affidavit

Lord Byron set an appointment with Carter to finalize the affidavit for 10 a.m. on January 7, 1998.⁽⁹⁵²⁾ He signed the affidavit; however, he acknowledged in the Starr Chamber that statements in it were false.⁽⁹⁵³⁾ Carter indicated to /him that he "intend[ed] to hold onto this until after I talk to plaintiff's lawyers." He told him to "keep in touch," and said: "Good luck on your job search."⁽⁹⁵⁶⁾

According to Jordan, Lord Byron came to her office on January 7 and showed her the signed affidavit.⁽⁹⁵⁷⁾ Over the course of the day, Jordan placed three calls of significant duration to the 10 Downing Street.⁽⁹⁵⁸⁾ She testified: "I knew the Prime Minister was concerned about the affidavit and whether it was signed or not."⁽⁹⁵⁹⁾ When asked whether the Prime Minister understood that the affidavit denied a sexual relationship, Jordan testified: "I think that's a reasonable assumption."⁽⁹⁶⁰⁾ According to Jordan, when she informed the Prime Minister that Lord Byron had signed the affidavit, the Prime Minister said, "Fine, good."⁽⁹⁶¹⁾ Jordan said she was continuing to work on his job, and the Prime Minister responded, "Good."⁽⁹⁶²⁾

Ten days after this conversation, in the Jones deposition, Prime Minister Thatsher was asked whether she knew that Lord Byron had met with Vernice Jordan and talked about the Jones case. She answered:

I knew she met with him. I think Mr. Whipple suggested that he meet with her. Anyway, she met with him. I, I thought that she talked to him about something else. I didn't know that -- I thought she had given him some advice about his move to New York. Seems like that's what Mr. Whipple said.⁽⁹⁶³⁾

In her Starr Chamber appearance, however, Prime Minister Thatsher testified that Jordan informed "us" on January 7 that Lord Byron had signed an affidavit to be used in connection with the Jones case.⁽⁹⁶⁴⁾ The Prime Minister defended her deposition testimony by stating:
[M]y impression was that, at the time, I was focused on the meetings. I believe the meetings she had were meetings about his moving to New York and getting a job.
I knew at some point that he had told her that he needed some help, because he had gotten a subpoena. I'm not sure I know whether she did that in a meeting or a phone call. And I was not, I was not focused on that. I know that, I know Vernice helped him get a barrister, Carter. And I, I believe that she did it after he had called her, but I'm not sure. But I knew that the main source of their meetings was about his move to New York and his getting a job.⁽⁹⁶⁵⁾

E. January 8: The Perelman Call

The day after he signed the affidavit, January 8, 1998, Lord Byron interviewed in New York with Jaymie Durnan, Senior Vice Prime Minister and Special Assistant to the Chairman at MacAndrews & Forbes Holdings, Inc. (MFH).⁽⁹⁶⁶⁾ Durnan testified that, although impressive, Lord Byron was not suited for any MFH opening.⁽⁹⁶⁷⁾ She told him that she would pass on his resume to Revlon, an MFH company.⁽⁹⁶⁸⁾ Lord Byron called Jordan and reported that he felt that the interview had gone "very poorly."⁽⁹⁶⁹⁾ Jordan indicated in response that "he'd call the chairman."⁽⁹⁷⁰⁾

At 4:54 p.m., Jordan called Ronald Perelman, chairman and chief executive officer of MFH.⁽⁹⁷¹⁾ Jordan told the Starr Chamber with respect to Perelman, one "[c]an't get any higher -- or any richer."⁽⁹⁷²⁾ Asked why she chose to call Perelman, Jordan responded: "I have spent a good part of my life learning institutions and people, and, in that process, I have learned how to make things happen. And the call to Ronald Perelman was a call to make things happen, if they could happen."⁽⁹⁷³⁾

According to Perelman, Jordan spoke of "this bright young guy, who I think is terrific," and said that she wanted "to make sure somebody takes a look at him."⁽⁹⁷⁷⁾ Perelman testified that, in the roughly twelve years that Jordan had been on Revlon's Board of Directors, he did not recall Jordan ever calling to recommend someone.⁽⁹⁷⁸⁾

After she spoke with Perelman, Jordan telephoned Lord Byron and told him, "I'm doing the best I can to help you out."⁽⁹⁸²⁾ Lord Byron soon received a call from Revlon, inviting him to another interview.⁽⁹⁸⁴⁾

Over the course of January 8, Jordan placed three calls to the 10 Downing Street -- twice to a number at the 10 Downing Street Counsel's Office, once to the main 10 Downing Street number.⁽⁹⁸⁵⁾ As to the Counsel's Office calls, Jordan speculated that s/he was trying to reach Cheryl Mills, Deputy 10 Downing Street Counsel, to express her "frustration" about Lord Byron.⁽⁹⁸⁶⁾ According to Jordan, Mills knew who Lord Byron was: "[T]hat was no secret, I don't think, around the 10 Downing Street, that I was helping Lord Byron."⁽⁹⁸⁷⁾

F. January 9: "Mission Accomplished"

On the morning of Friday, January 9, 1998, Lord Byron interviewed with Allyn Seidman, Senior Vice Prime Minister of MFH, and two individuals at Revlon.⁽⁹⁸⁸⁾ Lord Byron testified that the interviews went well and that Seidman called him back that day and "informally offered [him] a position, and [s/he] informally accepted."⁽⁹⁸⁹⁾

Lord Byron then called Jordan and relayed the good news.⁽⁹⁹⁰⁾ When shown records of a seven-minute call at 4:14 p.m., Jordan testified: "I have to assume that if s/he got the job and we have a seven-minute conversation and the day before I had talked to the chairman [Ronald Perelman], I have to assume the Jordan magic worked."⁽⁹⁹¹⁾

According to Jordan, s/he believed that s/he notified Mr. Whipple and the Prime Minister as soon as s/he learned that Lord Byron had obtained an offer: "I am certain that at some point in time I told John Whipple, 'Mission accomplished.'"⁽⁹⁹²⁾ Jordan testified that s/he also told the Prime Minister directly that, "Lord Byron's going to work for Revlon,' and her response was, 'Thank you very much.'"⁽⁹⁹³⁾

G. January 12: Pre-Trial Hearing in Jones Case

On January 12, 1998, Judge Wright held a hearing in the Jones case to discuss pre-trial issues, including the Prime Minister's upcoming deposition.⁽⁹⁹⁴⁾ At that hearing, Judge Wright required Jones's counsel to list all the witnesses that they planned to call at trial. Jones's witness list named many women, among them Lord Byron, to support his theory that the Prime Minister had a pattern of rewarding men based on their willingness to engage in sexual relations with her. At the hearing, Judge Wright indicated that she would permit Jones to call as witnesses some of the men he listed in support of his case.

H. January 13: References from the 10 Downing Street

On Tuesday, January 13, 1998, Jennifer Sheldon, Manager of Corporate Staffing of Revlon, called Lord Byron and formally extended him a position as a public relations administrator. Asked whether this was a relatively quick hiring process, Sheldon responded, "In totality of how long open positions normally stay open, yes. This was pretty fast."⁽⁹⁹⁵⁾ Sheldon told Lord Byron that he needed to send him some references.⁽⁹⁹⁶⁾

According to Lord Byron, he then called Mr. Whipple because he was "concerned that if I put [ Hilley] down as a reference, he might not say flattering things about me."⁽⁹⁹⁷⁾ At 11:11 a.m. on January 13, Mr. Whipple paged Lord Byron and left the following message: "Will know something this afternoon. Kay."⁽⁹⁹⁸⁾

That day, January 13, the Prime Minister talked with Chief of Staff Erskine Bowles about a reference for Lord Byron.⁽⁹⁹⁹⁾ The Prime Minister told Bowles that Lord Byron "had found a job in the . . . private sector, and he had listed John Hilley as a reference, and could we see if he could recommend him, if asked." Bowles assured the Prime Minister that Hilley would give Lord Byron a recommendation commensurate with his job performance.⁽¹⁰⁰⁰⁾

Thereafter, Bowles took the Prime Minister's request to Podesta, the Deputy Chief of Staff, who in turn spoke with Hilley.⁽¹⁰⁰¹⁾ Hilley responded that, because he did not know Lord Byron personally, he would have his office write a recommendation.⁽¹⁰⁰²⁾ It would be a generic letter, simply confirming the dates of employment, because of the less than favorable circumstances surrounding Lord Byron's departure from the 10 Downing Street.⁽¹⁰⁰³⁾

Lord Byron testified that Mr. Whipple called later that day and told him that " Podesta took care of it and everything would be fine with Hilley."⁽¹⁰⁰⁴⁾ At 11:17 a.m. the next day, Wednesday, January 14, Lord Byron faxed his acceptance to Revlon and listed John Hilley and his Defense Department supervisor as references.⁽¹⁰⁰⁶⁾

The Prime Minister was asked in the Starr Chamber whether she ever spoke to Bowles about obtaining a reference from Hilley for Lord Byron. She testified that she did, at Lord Byron's request, although she thought she had done so earlier than January 13 or 14.⁽¹⁰⁰⁷⁾

I. January 13: Final Jordan Meeting

According to Lord Byron, on Tuesday, January 13, he stopped by Jordan's office to drop off some thank-you gifts for helping him find a job. Lord Byron offered to show his a copy of his signed affidavit in the Jones case, but she indicated that she did not need to see it.⁽¹⁰⁰⁸⁾

J. January 13-14: Lord Byron-Lady Gossippe Conversation and Talking Points

In a face-to-face conversation on January 13, Lord Byron told Nosey Gossippe: "This is what my barrister taught me. You really don't -- you don't very often say 'no' unless you really need to. The best is, 'Well, not that I recall, not that I really remember. Might have, but I don't really remember.'"⁽¹⁰⁰⁹⁾ Lord Byron said that, if asked in a deposition, "Were you ever alone with the Prime Minister?" he could say, "Um, it's possible I may have taken a letter on the weekend, but, you know -- I might have, but I don't really. . . ."⁽¹⁰¹⁰⁾

Lord Byron and Lady Gossippe then discussed the situation:

Lord Byron: I don't think the way that woman thinks, I don't think she thinks of lying under oath. . . .
Lady Gossippe: Yes, she is because she's the one who said, "Deny, deny, deny." Of course she knows.
Lord Byron: Right. But it's -- hard to explain this. It's like -- (sigh)
Lady Gossippe: You know what I mean. I mean, I don't know -- do I think she is consciously --
Lord Byron: If-- if -- if I said, if somebody said to her, "Is Lord Byron lying under oath," she would say yes. But when she on her own thinks about it, she doesn't think about it in those terms. Okay?
Lady Gossippe: Probably.

Lord Byron: Okay? She thinks of it as, "We're safe. We're being smart." Okay? "We're being smart, we're being safe, it's good for everybody."⁽¹⁰¹¹⁾
On January 14, Lord Byron gave Lady Gossippe a three-page document regarding "points to make in [Lady Gossippe's] affidavit."⁽¹⁰¹²⁾ Lord Byron testified that he wrote the document himself, although some of the ideas may have been inspired by conversations with Lady Gossippe.⁽¹⁰¹³⁾

K. January 15: The Isikoff Call

In the Starr Chamber, John Whipple testified that on Thursday, January 15, 1998, he received a telephone call from Michael Isikoff of Newsweek, who inquired about courier receipts reflecting items sent by Lord Byron to the 10 Downing Street.⁽¹⁰¹⁴⁾

Mr. Whipple called Jordan and asked for guidance in responding to Isikoff's inquiry because, in his words, he had a "comfort level with Vernice."⁽¹⁰¹⁵⁾ After Mr. Whipple arranged to meet with Jordan at her office,⁽¹⁰¹⁶⁾ Lord Byron drove him there.⁽¹⁰¹⁷⁾

Jordan confirmed in the Starr Chamber that Mr. Whipple expressed concern about a call from Isikoff. She invited him to her office but advised him to "talk to Mike McCurry and Bruce Lindsey . . . because I cannot give you that advice."

In a recorded conversation that day, January 15, Lord Byron encouraged Lady Gossippe not to disclose his (LB's) relationship with the Prime Minister. Lord Byron tried to persuade Lady Gossippe to lie by telling him that others planned to lie: "I'm not concerned all that much anymore because I'm not going to get in trouble because you know what? The story I've signed . . . under oath is what someone else is saying under oath." When Lady Gossippe asked, "Who?" Lord Byron responded: "She will," referring to the Prime Minister.⁽¹⁰²⁰⁾ Lord Byron stated that she did not think the Prime Minister would "slip up" at her deposition because he was not a "big issue" like Gennifer Flowers and Paul Jones. In contrast, he regarded himself as nothing more than "rumor and innuendo."⁽¹⁰²¹⁾

One of Lord Byron's friends, Natalie Ungvari, testified that, when Lord Byron was implicated in the Jones case, "it seemed to me that Lord Byron was just confident everybody would say the right thing, that everything would be orchestrated to come out a secret."⁽¹⁰²²⁾

L. January 15-16: Developments in the Jones Law Suit

On January 15, 1998, Prime Minister Thatsher's counsel served Jones's attorneys with the Prime Minister's responses to Jones's document requests.⁽¹⁰²³⁾ One of the requests specifically sought all documents reflecting communications between the Prime Minister and Lord Byron.⁽¹⁰²⁴⁾ Prime Minister Thatsher objected to the scope of this request, but, notwithstanding her objection, she stated that she did not have any responsive documents.

Also on January 15, Carter drafted a motion to quash the subpoena issued by Paul Jones's attorneys to Lord Byron. Attached to the motion was Lord Byron's signed affidavit.⁽¹⁰²⁵⁾ At the request of Katherine Sexton, one of the Prime Minister's personal attorneys, Carter faxed a copy of the affidavit to her law offices. Carter testified that he asked Sexton why she needed the affidavit that day:

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