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                     IN THE SENATE OF THE UNITED STATES
                     SITTING AS A COURT OF IMPEACHMENT

   _______________________________
                                  )
   In re                          )
   Impeachment of                 )
   William Jefferson Clinton      )
   President of the United States )
   _______________________________)

                                 ANSWER OF
                    PRESIDENT WILLIAM JEFFERSON CLINTON
                       TO THE ARTICLES OF IMPEACHMENT

     The Honorable William Jefferson Clinton, President of the United
     States, in response to the summons of the Senate of the United
     States, answers the accusations made by the House of
     Representatives of the United States in the two Articles of
     Impeachment it has exhibited to the Senate as follows:

                                  PREAMBLE

 THE CHARGES IN THE ARTICLES DO NOT CONSTITUTE HIGH CRIMES OR MISDEMEANORS

     The charges in the two Articles of Impeachment do not permit the
     conviction and removal from office of a duly elected President. The
     President has acknowledged conduct with Ms. Lewinsky that was
     improper. But Article II, Section 4 of the Constitution provides
     that the President shall be removed from office only upon
     ``Impeachment for, and Conviction of, Treason, Bribery or other
     high Crimes and Misdemeanors.'' The charges in the articles do
     not rise to the level of ``high Crimes and Misdemeanors''
     as contemplated by the Founding Fathers, and they do not satisfy
     the rigorous constitutional standard applied throughout our
     Nation's history. Accordingly, the Articles of Impeachment
     should be dismissed.

          THE PRESIDENT DID NOT COMMIT PERJURY OR OBSTRUCT JUSTICE

     The President denies each and every material allegation of the two
     Articles of Impeachment not specifically admitted in this ANSWER.

                                 ARTICLE I

     President Clinton denies that he made perjurious, false and
     misleading statements before the federal grand jury on August 17,
     1998.

                       FACTUAL RESPONSES TO ARTICLE I

     Without waiving his affirmative defenses, President Clinton offers
     the following factual responses to the allegations in Article I:

    1. The President denies that he made perjurious, false and misleading
       statements to the grand jury about ``the nature and details of
       his relationship'' with Monica Lewinsky.

     There is a myth about President Clinton's testimony before the
     grand jury. The myth is that the President failed to admit his
     improper intimate relationship with Ms. Monica Lewinsky. The myth
     is perpetuated by Article I, which accuses the President of lying
     about ``the nature and details of his relationship'' with
     Ms. Lewinsky.

     The fact is that the President specifically acknowledged to the
     grand jury that he had an improper intimate relationship with Ms.
     Lewinsky. He said so, plainly and clearly: ``When I was alone
     with Ms. Lewinsky on certain occasions in early 1996 and once in
     early 1997, I engaged in conduct that was wrong. These encounters .
     . . did involve inappropriate intimate contact.'' The President
     described to the grand jury how the relationship began and how it
     ended at his insistence early in 1997 -- long before any public
     attention or scrutiny. He also described to the grand jury how he
     had attempted to testify in the deposition in the Jones case months
     earlier without having to acknowledge to the Jones lawyers what he
     ultimately admitted to the grand jury -- that he had an improper
     intimate relationship with Ms. Lewinsky.

     The President read a prepared statement to the grand jury
     acknowledging his relationship with Ms. Lewinsky. The statement was
     offered at the beginning of his testimony to focus the questioning
     in a manner that would allow the Office of Independent Counsel to
     obtain necessary information without unduly dwelling on the
     salacious details of the relationship. The President's
     statement was followed by almost four hours of questioning. If it
     is charged that his statement was in any respect perjurious, false
     and misleading, the President denies it. The President also denies
     that the statement was in any way an attempt to thwart the
     investigation.

     The President states, as he did during his grand jury testimony,
     that he engaged in improper physical contact with Ms. Lewinsky. The
     President was truthful when he testified before the grand jury that
     he did not engage in sexual relations with Ms. Lewinsky as he
     understood that term to be defined by the Jones lawyers during
     their questioning of him in that deposition. The President further
     denies that his other statements to the grand jury about the nature
     and details of his relationship with Ms. Lewinsky were perjurious,
     false, and misleading.

    2. The President denies that he made perjurious, false and misleading
       statements to the grand jury when he testified about statements he
       had made in the Jones deposition.

     There is a second myth about the President's testimony before
     the grand jury. The myth is that the President adopted his entire
     Jones deposition testimony in the grand jury. The President was not
     asked to and did not broadly restate or reaffirm his Jones
     deposition testimony. Instead, in the grand jury he discussed the
     bases for certain answers he gave. The President testified
     truthfully in the grand jury about statements he made in the Jones
     deposition. The President stated to the grand jury that he did not
     attempt to be helpful to or assist the lawyers in the Jones
     deposition in their quest for information about his relationship
     with Ms. Lewinsky. He truthfully explained to the grand jury his
     efforts to answer the questions in the Jones deposition without
     disclosing his relationship with Ms. Lewinsky. Accordingly, the
     full, underlying Jones deposition is not before the Senate.

     Indeed, the House specifically considered and rejected an article
     of impeachment based on the President's deposition in the
     Jones case. The House managers should not be allowed to prosecute
     before the Senate an article of impeachment which the full House
     has rejected.

    3. The President denies that he made perjurious, false and misleading
       statements to the grand jury about ``statements he allowed his
       attorney to make'' during the Jones deposition.

     The President denies that he made perjurious, false and misleading
     statements to the grand jury about the statements his attorney made
     during the Jones deposition. The President was truthful when he
     explained to the grand jury his understanding of certain statements
     made by his lawyer, Robert Bennett, during the Jones deposition.
     The President also was truthful when he testified that he was not
     focusing on the prolonged and complicated exchange between the
     attorneys and Judge Wright.

    4. The President denies that he made perjurious, false and misleading
       statements to the grand jury concerning alleged efforts ``to
       influence the testimony of witnesses and to impede the discovery
       of evidence'' in the Jones case.

     For the reasons discussed more fully in response to ARTICLE II, the
     President denies that he attempted to influence the testimony of
     any witness or to impede the discovery of evidence in the Jones
     case. Thus, the President denies that he made perjurious, false and
     misleading statements before the grand jury when he testified about
     these matters.

                         FIRST AFFIRMATIVE DEFENSE:
   ARTICLE I DOES NOT MEET THE CONSTITUTIONAL STANDARD FOR CONVICTION AND
                                  REMOVAL

     For the same reasons set forth in the PREAMBLE of this ANSWER,
     Article I does not meet the rigorous constitutional standard for
     conviction and removal from office of a duly elected President and
     should be dismissed.

                        SECOND AFFIRMATIVE DEFENSE:
          ARTICLE I IS TOO VAGUE TO PERMIT CONVICTION AND REMOVAL

     Article I is unconstitutionally vague. No reasonable person could
     know what specific charges are being leveled against the President.
     It alleges that the President provided the grand jury with
     ``perjurious, false, and misleading testimony'' concerning
     ``one or more'' of four subject areas. But it fails to
     identify any specific statement by the President that is alleged to
     be perjurious, false and misleading. The House has left the Senate
     and the President to guess at what it had in mind.

     One of the fundamental principles of our law and the Constitution
     is that a person has a right to know what specific charges he or
     she is facing. Without such fair warning, no one can prepare the
     defense to which every person is entitled. The law and the
     Constitution also mandate adequate notice to jurors so they may
     know the basis for the vote they must make. Without a definite and
     specific identification of false statements, a trial becomes a
     moving target for the accused. In addition, the American people
     deserve to know upon what specific statements the President is
     being judged, given the gravity and effect of these proceedings,
     namely nullifying the results of a national election.

     Article I sweeps broadly and fails to provide the required definite
     and specific identification. Were it an indictment, it would be
     dismissed. As an article of impeachment, it is constitutionally
     defective and should fail.

                         THIRD AFFIRMATIVE DEFENSE:
             ARTICLE I CHARGES MULTIPLE OFFENSES IN ONE ARTICLE

     Article I is fatally flawed because it charges multiple instances
     of alleged perjurious, false and misleading statements in one
     article. The Constitution provides that ``no person shall be
     convicted without the Concurrence of two thirds of the Members
     present,'' and Senate Rule XXIII provides that ``an article
     of impeachment shall not be divisible for the purpose of voting
     thereon at any time during the trial.'' By the express terms of
     Article I, a Senator may vote for impeachment if he or she finds
     that there was perjurious, false and misleading testimony in
     ``one or more'' of four topic areas. This creates the very
     real possibility that conviction could occur even though Senators
     were in wide disagreement as to the alleged wrong committed. Put
     simply, the structure of Article I presents the possibility that
     the President could be convicted even though he would have been
     acquitted if separate votes were taken on each allegedly perjurious
     statement. For example, it would be possible for the President to
     be convicted and removed from office with as few as 17 Senators
     agreeing that any single statement was perjurious, because 17 votes
     for each of the four categories in Article I would yield 68 votes,
     one more than necessary to convict and remove.

     By charging multiple wrongs in one article, the House of
     Representatives has made it impossible for the Senate to comply
     with the Constitutional mandate that any conviction be by the
     concurrence of two-thirds of the members. Accordingly, Article I
     should fail.

                                 ARTICLE II

     President Clinton denies that he obstructed justice in either the
     Jones case or the Lewinsky grand jury investigation.

                      FACTUAL RESPONSES TO ARTICLE II

     Without waiving his affirmative defenses, President Clinton offers
     the following factual responses to the allegations in Article II:

    1. The President denies that on or about December 17, 1997, he
       ``corruptly encouraged'' Monica Lewinsky ``to execute
       a sworn affidavit in that proceeding that he knew to be
       perjurious, false and misleading.''

     The President denies that he encouraged Monica Lewinsky to execute
     a false affidavit in the Jones case. Ms. Lewinsky, the only witness
     cited in support of this allegation, denies this allegation as
     well. Her testimony and proffered statements are clear and
     unmistakable:

     * ``[N]o one ever asked me to lie and I was never promised a job
       for my silence.''
     * ``Neither the President nor anyone ever directed Lewinsky to
       say anything or to lie . . .''
     * ``Neither the Pres[ident] nor Mr. Jordan (or anyone on their
       behalf) asked or encouraged Ms. L[ewinsky] to lie.''

     The President states that, sometime in December 1997, Ms. Lewinsky
     asked him whether she might be able to avoid testifying in the
     Jones case because she knew nothing about Ms. Jones or the case.
     The President further states that he told her he believed other
     witnesses had executed affidavits, and there was a chance they
     would not have to testify. The President denies that he ever asked,
     encouraged or suggested that Ms. Lewinsky file a false affidavit or
     lie. The President states that he believed that Ms. Lewinsky could
     have filed a limited but truthful affidavit that might have enabled
     her to avoid having to testify in the Jones case.

    2. The President denies that on or about December 17, 1997, he
       ``corruptly encouraged'' Monica Lewinsky ``to give
       perjurious, false and misleading testimony if and when called to
       testify personally'' in the Jones litigation.

     Again, the President denies that he encouraged Ms. Lewinsky to lie
     if and when called to testify personally in the Jones case. The
     testimony and proffered statements of Monica Lewinsky, the only
     witness cited in support of this allegation, are clear and
     unmistakable:

     * ``[N]o one ever asked me to lie and I was never promised a job
       for my silence.''
     * ``Neither the President nor anyone ever directed Lewinsky to
       say anything or to lie . . .''
     * ``Neither the Pres[ident] nor Mr. Jordan (or anyone on their
       behalf) asked or encouraged Ms. L[ewinsky] to lie.''

     The President states that, prior to Ms. Lewinsky's involvement
     in the Jones case, he and Ms. Lewinsky might have talked about what
     to do to conceal their relationship from others. Ms. Lewinsky was
     not a witness in any legal proceeding at that time. Ms.
     Lewinsky's own testimony and statements support the
     President's recollection. Ms. Lewinsky testified that she
     ``pretty much can'' exclude the possibility that she and
     the President ever had discussions about denying the relationship
     after she learned she was a witness in the Jones case. Ms. Lewinsky
     also stated that ``they did not discuss the issue [of what to
     say about their relationship] in specific relation to the Jones
     matter,'' and that ``she does not believe they discussed
     the content of any deposition that [she] might be involved in at a
     later date.''

    3. The President denies that on or about December 28, 1997, he
       ``corruptly engaged in, encouraged, or supported a scheme to
       conceal evidence'' in the Jones case.

     The President denies that he engaged in, encouraged, or supported
     any scheme to conceal evidence from discovery in the Jones case,
     including any gifts he had given to Ms. Lewinsky. The President
     states that he gave numerous gifts to Ms. Lewinsky prior to
     December 28, 1997. The President states that, sometime in December,
     Ms. Lewinsky inquired as to what to do if she were asked in the
     Jones case about the gifts he had given her, to which the President
     responded that she would have to turn over whatever she had. The
     President states that he was unconcerned about having given her
     gifts and, in fact, that he gave Ms. Lewinsky additional gifts on
     December 28, 1997. The President denies that he ever asked his
     secretary, Ms. Betty Currie, to retrieve gifts he had given Ms.
     Lewinsky, or that he ever asked, encouraged, or suggested that Ms.
     Lewinsky conceal the gifts. Ms. Currie told prosecutors as early as
     January 1998 and repeatedly thereafter that it was Ms. Lewinsky who
     had contacted her about retrieving gifts.

    4. The President denies that he obstructed justice in connection with
       Monica Lewinsky's efforts to obtain a job in New York to
       ``corruptly prevent'' her ``truthful testimony''
       in the Jones case.

     The President denies that he obstructed justice in connection with
     Ms. Lewinsky's job search in New York or sought to prevent her
     truthful testimony in the Jones case. The President states that he
     discussed with Ms. Lewinsky her desire to obtain a job in New York
     months before she was listed as a potential witness in the Jones
     case. Indeed, Ms. Lewinsky was offered a job in New York at the
     United Nations more than a month before she was identified as a
     possible witness. The President also states that he believes that
     Ms. Lewinsky raised with him, again before she was ever listed as a
     possible witness in the Jones case, the prospect of having Mr.
     Vernon Jordan assist in her job search. Ms. Lewinsky corroborates
     his recollection that it was her idea to ask for Mr. Jordan's
     help. The President also states that he was aware that Mr. Jordan
     was assisting Ms. Lewinsky to obtain employment in New York. The
     President denies that any of these efforts had any connection
     whatsoever to Ms. Lewinsky's status as a possible or actual
     witness in the Jones case. Ms. Lewinsky forcefully confirmed the
     President's denial when she testified, ``I was never
     promised a job for my silence.''

    5. The President denies that he ``corruptly allowed his attorney
       to make false and misleading statements to a Federal judge''
       concerning Monica Lewinsky's affidavit.

     The President denies that he corruptly allowed his attorney to make
     false and misleading statements concerning Ms. Lewinsky's
     affidavit to a Federal judge during the Jones deposition. The
     President denies that he was focusing his attention on the
     prolonged and complicated exchange between his attorney and Judge
     Wright.

    6. The President denies that he obstructed justice by relating
       ``false and misleading statements'' to ``a potential
       witness,'' Betty Currie, ``in order to corruptly influence
       [her] testimony.''

     The President denies that he obstructed justice or endeavored in
     any way to influence any potential testimony of Ms. Betty Currie.
     The President states that he spoke with Ms. Currie on January 18,
     1998. The President testified that, in that conversation, he was
     trying to find out what the facts were, what Ms. Currie's
     perception was, and whether his own recollection was correct about
     certain aspects of his relationship with Ms. Lewinsky. Ms. Currie
     testified that she felt no pressure ``whatsoever'' from the
     President's statements and no pressure ``to agree with
     [her] boss.'' The President denies knowing or believing that
     Ms. Currie would be a witness in any proceeding at the time of this
     conversation. Ms. Currie had not been on any of the witness lists
     proffered by the Jones lawyers. President Clinton states that,
     after the Independent Counsel investigation became public, when Ms.
     Currie was scheduled to testify, he told Ms. Currie to ``tell
     the truth.''

    7. The President denies that he obstructed justice when he relayed
       allegedly ``false and misleading statements'' to his
       aides.

     The President denies that he obstructed justice when he misled his
     aides about the nature of his relationship with Ms. Lewinsky in the
     days immediately following the public revelation of the Lewinsky
     investigation. The President acknowledges that, in the days
     following the January 21, 1998 Washington Post article, he misled
     his family, his friends and staff, and the Nation to conceal the
     nature of his relationship with Ms. Lewinsky. He sought to avoid
     disclosing his personal wrongdoing to protect his family and
     himself from hurt and public embarrassment. The President
     profoundly regrets his actions, and he has apologized to his
     family, his friends and staff, and the Nation. The President denies
     that he had any corrupt purpose or any intent to influence the
     ongoing grand jury proceedings.

                         FIRST AFFIRMATIVE DEFENSE:
  ARTICLE II DOES NOT MEET THE CONSTITUTIONAL STANDARD FOR CONVICTION AND
                                  REMOVAL

     For the reasons set forth in the PREAMBLE of this ANSWER, Article
     II does not meet the constitutional standard for convicting and
     removing a duly elected President from office and should be
     dismissed.

                        SECOND AFFIRMATIVE DEFENSE:
          ARTICLE II IS TOO VAGUE TO PERMIT CONVICTION AND REMOVAL

     Article II is unconstitutionally vague. No reasonable person could
     know what specific charges are being leveled against the President.
     Article II alleges that the President ``obstructed and impeded
     the administration of justice'' in both the Jones case and the
     grand jury investigation. But it provides little or no concrete
     information about the specific acts in which the President is
     alleged to have engaged, or with whom, or when, that allegedly
     obstructed or otherwise impeded the administration of justice.

     As we set forth in the SECOND AFFIRMATIVE DEFENSE TO ARTICLE I, one
     of the fundamental principles of our law and the Constitution is
     that a person has the right to know what specific charges he or she
     is facing. Without such fair warning, no one can mount the defense
     to which every person is entitled. Fundamental to due process is
     the right of the President to be adequately informed of the charges
     so that he is able to confront those charges and defend himself.

     Article II sweeps too broadly and provides too little definite and
     specific identification. Were it an indictment, it would be
     dismissed. As an article of impeachment, it is constitutionally
     defective and should fail.

                         THIRD AFFIRMATIVE DEFENSE:
            ARTICLE II CHARGES MULTIPLE OFFENSES IN ONE ARTICLE

     For the reasons set forth in the THIRD AFFIRMATIVE DEFENSE TO
     ARTICLE I, Article II is constitutionally defective because it
     charges multiple instances of alleged acts of obstruction in one
     article, which makes it impossible for the Senate to comply with
     the

     Constitutional mandate that any conviction be by the concurrence of
     the two-thirds of the members. Accordingly, Article II should fail.

     Respectfully submitted,
     _________________________________________________________________

   David E. Kendall
   Nicole K. Seligman
   Emmet T. Flood
   Max Stier
   Glen Donath
   Alicia Marti
   Williams & Connolly
   725 12th Street, N.W.
   Washington, D.C. 20005
     _________________________________________________________________

   Charles F.C. Ruff
   Gregory B. Craig
   Bruce R. Lindsey
   Cheryl D. Mills
   Lanny A. Breuer
   Office of the White House Counsel
   The White House
   Washington, D.C. 20502

     Submitted: January 11, 1999