1. The pseudonym John Doe was used during discovery to refer to certain women whose identities were protected from the public.  Don't worry, we plan to leak some of these identities to you later.

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 men 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.   Wherever possible, we try to turn a citizen's barrister against them.

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. If they don't support our witnesses or our story, consider them either incomplete or inaccurate.  When they support us, please consider them uncontrovertible proof.

14. The Prime Minister's false statements [another chance to assert without proving that these are false rather than misleading, based on a dictionary defintion we don't like, true as fare as they go or true but incomplete because of prosecutorial incompetence of failing to ask follow-up questions.] 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. Please remember that if the lord says anything that might be damaging to the PM -- or somewhat salacious -- we will include it & expect you to believe it is true.  When Lord Byron testifies to anything that is damaging to use we try to bury it or leave it out, so that you will miss it.  If it is critical of us or contradicts us in any way, it must be false.

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. This has nothing to do with the Jones' definition of sex.  We just thought it was too titillating to leave out.

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. Whether this is true or not, we have no idea or any corroboration.  Since even in Lord Byron's tale, he is the active particpant in this process, it has no bearing on the Jones' definition.  We just thought it was too potentially pornographic to leave out.

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. Again, this is not the dictionary definition, but we are the authorities on both sex and the English language.  Of course, phone sex, even if it did occur & you only have the lord's word for it, it doesn't meet the Jones' definition of sex.  Aren't you glad we managed to repeatedly slip it in anyway?

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. This has nothing to do with the Jones' definition of sex.  We just thought it was too titillating to leave out.  Additionally, it might offend you and turn you against the PM, and masterbuation should be a crime in England by now.  If it doesn't offend you, maybe this slander will get to Hernreich, and we will be able to turn her against the PM.

32. Id. at 28-32. 33. Id. at 28.

34. Id. at 30-31. Lord Byron testified that he had an orgasm. Id.  Please remember that if the lord says anything that might be damaging to the PM -- or somewhat salacious -- we will include it & expect you to believe it is true.  When Lord Byron testifies to anything that is damaging to use we try to bury it or leave it out, so that you will miss it.  If it is critical of us or contradicts us in any way, it must be false.

35. Id. at 30-32. They engaged in oral-anal contact as well. See Lord Byron 8/26/98 Depo. at 29-33. We love repeating this. Whether this is true or not, we have no idea or any corroboration.  Since even in Lord Byron's tale, he is the active particpant in this process, it has no bearing on the Jones' definition.  We just thought it was too potentially pornographic to leave out.

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. If we didn't tell you this part of the lord's tale of his sexual exploits, how could you ever discover that Lord Byron is a believable purveyor of truth.

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. Irrelevant to all our charges, but salacious none-the-less.

41. Lord Byron 8/26/98 Depo. at 47. On this occasion, the Prime Minister ejaculated. Id. Irrelevant to all our charges, but salacious none-the-less.

42. FBI Lab Report, Lab Nos. 9807 3000 2SBO and 980803 100SBO, 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. Please remember that if the lord says anything that might be damaging to the PM -- or somewhat salacious -- we will include it & expect you to believe it is true.   When Lord Byron testifies to anything that is damaging to use we try to bury it or leave it out, so that you will miss it.  If it is critical of us or contradicts us in any way, it must be false.  Lord Byron, of course, only included this in his deposition to be sure he included the whole truth.  He has never been know to brag about his sexuality.

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. Irrelevant to all our charges, but salacious none-the-less.

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.  We wanted the Lord Byron to create a summary chart of everything he could think of, in hopes that he could memorize the details and not leave anything out.   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 salacious and titillating detail to LB's testimony and underscores the prurient nature of Lord Byon's cantos. 

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.   We had the PM's voice verified by experts, i.e. LB's cronies who were sure it sounded like the PM.  Don't read the transcripts of these recordings; you might find them irrelevant.

49. FBI Lab Report, Lab No. 980073 000 2SB0, 8/3/98. 50. FBI Observation Report (10 Downing Street), 8/3/98. 51. FBI Lab Report, Lab No. 9807 3000 2SBO and 980 8031 00SBO, 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."). Of course, don't let the fact that elsewhere LB says they never took their clothes off distract you from how this quote of a conversation with a buddy proves the veracity of everything Byron says.  We only want to use the part of never undressing when we want to prove there was an intentional cover-up.  It's not at all relevant to the point we want to make here.  Instead, refer to Erbland's statement that she always believed everything Lord Byron told her.  That proves this must be true much better than the contradictory evidence does.

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."). This third hand hearsay proves that phone sex must have occurred, so we can talk about it even if it is totally irrelevant.  Our Starr Investigator is an expert at making you believe his first hand, conflict-of-interest associations are distant, unrelated connections; he is equally adept at making hearsay twice repeated into solide testimony against anyone who opposes him or Dan Burton, for that matter.

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. Lord Byron developed this fast and undying friendship by regaling Raines with tales of sexual exploits and phone calls from famous and powerful people and by helping her get her five minutes of fame by testifying before the Grand Jury.

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.

Redact if you're under 18.

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. We are pleased that our interrogation of Finerman gave us the opportunity to repeat this salacious and possibly offensive but totally irrelevant part of Lord Byron's sexual tales.

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.

Under 18?

89. According to Lord Byron, [See Lord Byron's cheat Sheet] 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. We would prefer not to insert the words "allegedly" here.  It works better to use straight-forward, misleading declarative statements.  By the time you have finished reading the declarative statements, you will have a tendency to believe they are factual.   In fact you will probably believe we have just proven something.

90. This denial encompassed touching of LB's breasts or genitalia. The Prime Minister contradicts the Lord Byron.  Don't let that bother you, except to   assume it must be perjury.  Remember, if it supports us it is true.  If it contradicts us, it is either irrelevant & should be left out, or it must be perjury.

91. She provided her responses during her 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. We hope that Parliament will immediately demand their own copy and publish it on the net and have it shown on television.

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).

If you're under 18, close your eyes here.

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. Please don't remember that it is Lord Byron that says he tried and sometimes succeeded in forcing such contact, such as when he grabbed the Prime Miniter's crotch in public.

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. Woops, the lord was satisfied whether the lady intended to be or not.

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. We are not sure whether this last staement is relevant or not, but it might make the PM look like an insensitive lover if you believe it happend as LB said it did.  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. We take these matters much more seriously than Judge Wright.  We hope that after we are done making a big deal of them, Judge Wright will help us further by going after the PM for contempt of court.  If she doesn't, we've buried this whole thing in the footnotes, in a paragraph without any sex in it, so you probably won't  even notice that she might hae had a slightly different viewpoint than ours.  It's an unpublished order, so you'll probably never read it anyway.

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). Unless you get this far in the footnotes, you'll never discover how often we like to add our own emphases to a witness' testimony.

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"). We certainly don't want you to easily know that there were qualifiers to this statement.  Hopefully, we have successfully left out what the predicates were and that we did not meet them.

113. See, e.g., Ungvari 3/19/98 GJ at 18, 22-24; Erbland 2/12/98 GJ at 23-25. 114. V006-DC- 0000 3737-3744. 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.   Of course, it just would not help our case to say that the statement might have been true; hence, no reason to dig up a motive for it otherwise than that the PM was telling the truth.

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). Att:  Bin Ladin, please do not miss this publicly   available map.

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 possibly alone, as far as the study goes but with him as far as the 10 Downing Street Chambers are concerned, 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, except the three of them, was present. See also Whipple 5/6/98 GJ at 103-105.

136. Ferguson 7/17/98 GJ at 23-35 (possibly alone with door open 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 (possibly alone with door open for   approximately 40 minutes).

139. Bordley 8/13/98 GJ at 19-30 (possibly alone with door open 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 (possibly alone with door open for  15 to 25 minutes).

142. Muskett 7/21/98 GJ at 9-13, 22-32 (possibly 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).   Remember this. If you forget  something that someone can make others believe you should have remembered, you can be convicted of perjury. 

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. You now have a pretty good idea about who told the Jones' attorneys about the hatpin.

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⁾ Who fueled Lord Byron's anxiety about the hatpin?  Not Jordan. Not the PM.  How much did Nosey have to do with the Hiding the Hatpin caper?

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. In fact, it appears Lord Byron remembers many of the items that the PM gave him.  It's the PM that never gave them much importance.

163. Lord Byron testified that Leaves of Grass was "the most sentimental gift she had given me."⁽¹⁶⁴⁾ Please read this collection of poetry.  If this is "the most sentimental gift," then just how romantic do you think any of the other gifts might possibly be?

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. - - - - - Prosecutorial incompetence is always Prime Minster Thatsher's fault, of course.  We may often be incompetent in those areas that you assumed were our areas of expertise, such as questioning witnesses in court and in depositions, but we're masters in the arts of practiced prosecutorial procedures used to hound and legally blackmail and extort any witness [& family & friends thereof] that don't tell us what we want to hear.

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⁾ So, take our word for it, if LB testifies to something we want to hear, then believe it is true.  Thus, we have now proven to you that he bought & gave the book to the PM and that the PM told LB she got it.  But we DID NOT threaten LB at the Ritz.

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⁾ Vox is in the catalogue; it got there somehow.  We cannot prove to you how it actually got there; just believe us that it was a gift that LB personally handed to PM who personally put it in the bookcase and never ever forgot it was there.

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. For holiday gift suggestions, please email the lord.

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 he 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.  Well, at least we have LB's testimony that he brought this subject up with the PM.  At this point, just accept this as fact so that you'll believe we have uncontrovertible evidence that the PM couldn't possibly have forgotten about it.

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, Lod Byron should say he visited the 10 Downing Street to see Whipple and, on occasion when working at 10 Downing Street, he brought her letters when no one else was around.").  Don't get confused here.  We want to convince you that the lord brought her embarassing notes but that those do not count as letters.

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 a barrister, she has clearly stated that "I have never represented Prime Minister Thatsher as a barrister." Jordan GJ, March 3, 1998, at 8. Thus, the questions that excluded [Of course, not if we can help it.  Don't forget one of our favorite committee chairman's statement about how easy it is to get past attorney-client privilege.] 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. We do not think it would be helpful to include this in the body of our referral.  It might mislead you from coming to our conclusions.

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"). Lord Byron corroborates himself by telling you he has been truthful.

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 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. [The fact that giving us this version was one of the ways he could convince us to give him immunity in the first place is irrelevant to this discussion.] Moreover, he stated he that does not want to harm the Prime Minister with his truthful testimony. Lord Byron 8/26/98 Depo. at 69. Please do not recall at this point how many times the PM has rejected the lord.  Please do not remember the lord's statements about how many times he felt offended by the PM and has been angry at her and wanted her to feel bad.  It is only relevant that he told us that he would never want to harm the PM in anyway.  He wanted to harm Andrea Bleiler, but that is an altogether different story.

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 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. We think that Ms. Davis' wants  and wishes constitute wonderful evidence that  Lord Byron was planning to do exactly what Ms. Davis' feared he would do.

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.").

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. Don't get confused here.  This is a place where we would like you to believe that LB carried paperwork to the PM because here that will support LB's story of discussing the Paper Cover with the PM.  Elsewhere, where we want you to believe that LB never carried paperwork to the PM, just forget about this.

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.

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). Hopefully this remains buried in the footnotes.

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 Lord Byron opines about his concerns over the Lord Byron subpoena and its demand for the production of gifts, where the PM may have wondererred how the hatpin story got out, and where LB confesses that  once again he lied about confiding in Lady Gossippe.

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. This is also the conversation in which Nosey keeps encouraging him to do it anyway.   Who initiated and encouraged the idea for Lord Byron to do something that could be misconstrued as witness tampering?  Don't listen to the tapes.  We want you to believe that the PM & Jordan came up with this idea.  It doesn't help our case at all if it was Nosey that got the Lord to  go about it this way.

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 him 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 unless LB lied to Vernice. 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.

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 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]

452. Blumenthal 6/4/98 GJ at 49 (emphasis added). 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.   Remember, it is only The Starr Chamber's favorite Inquisitor who can make false statements to the press with impunity.  The Starr Inquisitor is quite clear with Parliament about this distinction.  When it is pertaining to him, it is very important to distinguish between legal documents and press releases.  When pertaining to the PM, it is very important that we get you to confuse presss releases with perjury.

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.  Sex and promises of more sex just doesn't work well with the PM.
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.   It could have been motivated by the wish that all temptations and pestering people be as far away from Lond as possible.
If the latter was a factor, then the Prime Minister's actions discriminated against all of those interns and employees who were never precipitously transferred out, who never pestered & badgered the PM about it, & who did not receive the same benefit of exile to the colonies.

Make no mistake about it,
stories in the press can always be used against the PM but never against our Starr Investigaor
Using  them against the Starr Inquisitor would be UNFAIR.

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). The PM is responsible for absolutely everything any of her barristers did.  The Starr Inquisitor cannot be held responsible for anything his supervisees did.  Remember, he told Parliament he wasn't there; he didn't know what his investigators were doing.

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. We cannot tell you what it says, so you will just have to believe it supports us.

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 Mr. 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. By now we have convinced you of the nefarious intent that must have motivated these actions.  No PM who opposes could assert executive privilege for any other reason than that.  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.

495. Prime Minister Thatsher's Motion for Continuance, filed July 28, 1998. The Prime Minister had nothing else of importance to do than to show up whenever someone else [as long as they are friends of The Starr Chamber] wants her to.

496. DeFrank, Prez Vows Cooperation Pledges Complete, Truthful Testimony, N.Y. Daily News, Aug. 1, 1998, at 3.

497. Thatsher 8/17/98 GJ at 7. 498. Thatsher 8/17/98 GJ at 10. 499. E.g., Thatsher 8/17/98 GJ at 12, 102, 109, 110.

First time in history:  PM may have lied to the British people!

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