Related Links Full Coverage: Clinton Accused Full Text of Other Legal Documents Jones Filings Detail Sex Allegations (Washington Post, March 14)

Following are excerpts from former White House aide Kathleen Willey's January deposition in Paula Jones's sexual harassment lawsuit against President Clinton. Portions of the deposition were released on March 13 by Paula Jones's lawyers, as part of their opposition to the Clinton legal team's Feb. 17 motion for summary judgement. Jones lawyer Donovan Campbell did the questioning:

Q. I'm going to take you through in narrative fashion exactly what happened, if anything, in what I'm referring to as the incident. Do you understand me when I say that now?

A. Yes.

Q. Were you involved in any way in the incident?

A. Yes.

Q. On the occasion that is reported in Exhibit 1, did you go to see Mr. Clinton?

A. Yes.

Q. And to the best of your recollection, what date was that?

A. Nov. 29, 1993.

Q. And what was the purpose of your visit to Mr. Clinton?

A. To discuss my need for a paid position . . .

Q. With the federal government?

A. Yes.

Q. And where did you see Mr. Clinton?

A. In the Oval Office. . . .

Q. And who else was present?

A. No one.

Q. Do you recall approximately what time of day that meeting occurred?

A. I think it was about 3:00. . . .

Q. And once you were inside the Oval Office, was the door closed?

A. Yes. . . .

Q. And once the door was closed, it was just you and Mr. Clinton inside the office; is that right?

A. Yes. . . .

Q. Could you tell us, please, to the best of your recollection what you said to Mr. Clinton?

A. We were having a family crisis and my husband had asked me to sign a note for a large amount of money two weeks prior to this – to my going into the White House. And I was there just to say that I could no longer volunteer.

Q. Did you say anything else?

A. That was the gist of it.

Q. Well, ma'am, I thought you told us before that you were intending to go see Mr. Clinton about a paying job within the White House: is that right?

A. I went to tell him that I couldn't be a volunteer any more and that I was going to need to get paid if I was going to continue to come to Washington to work.

Q. Okay. So is it correct that you gave him to understand that you needed to be paid in order to continue to work at the White House?

A. Yes.

Q. And did Mr. Clinton say anything back to you?

A. I think we had some discussion of what had led up to that, why my situation had changed.

Q. To the best of your recollection, please tell us what you recall that Mr. Clinton said to you in that conversation.

A. He said that – I think he said that they would try to help me. . . .

Q. Would you tell us, please where within the Oval Office you were standing during this conversation? In terms of, was there a desk in the Oval Office?

A. Yes.

Q. Where were you in relation to the desk?

A. Across from it. I mean, on the other side of it.

Q. In front of the desk?

A. Uh-huh.

Q. And was Mr. Clinton behind the desk?

A. Yes.

Q. Was he standing, sitting?

A. Sitting.

Q. And were you standing or sitting?

A. Sitting.

Q. At any time during this meeting with Mr. Clinton did he physically do anything other than sit behind his desk. . . .

A. No.

Q. Did you, during this meeting with Mr. Clinton, did you ever physically do anything other than sit in front of his desk?

A. No.

Q. How did the meeting with Mr. Clinton conclude?

A. I left.

Q. Is there anything that you said before you left that you haven't told us here today?

A. I don't think so.

Q. Is there anything that Mr. Clinton said to you during that meeting that you have not told us here today?

A. No.

Q. At any time during that meeting did Mr. Clinton approach you physically?

A. In the Oval Office?

Q. At any time in your meeting with him that day. In any meeting that day.

A. Yes.

Q. Please explain that situation.

A. Do you want to know – what do you want to know?

Q. Well, I want to know – you said in response to my question, "Did he physically approach you at any time that day," you said, "Yes," I believe. Is that correct?

A. Well, when I walked in, he got up and came over and hugged me.

Q. Okay. He got up from behind his desk. Is that correct?

A. Yes.

Q. And approached you and hugged you?

A. Right.

Q. And then what happened?

A. And then we went and sat down and talked.

Q. And he went back behind his desk. Is that right?

A. Yes.

Q. And you sat in the chair that you've described?

A. Yes.

Q. During the hug, what precisely occurred?

A. Nothing.

Q. Just an embrace?

A. Yes.

Q. How long did that last?

A. A few seconds.

Q. At any point in time did you or Mr. Clinton go into any office other than the Oval Office itself?

A. Yes.

Q. When was that?

A. During the meeting.

Q. All right. Please describe the other office that you went into.

A. There's a hall to the side of the – there's a door on the other side of the main entrance door that goes into a small hall that goes back toward their – his private dining room.

Q. And there's a private office back there?

A. Yes.

Q. And you went into that private office; is that right?

A. Well, he poured me a cup of coffee first.

Q. Where?

A. In the little galley kitchen.

Q. So is it correct that on your way from the Oval Office proper to what I'll call the private office . . . that you and Mr. Clinton stopped for a cup of coffee?

A. Yes.

Q. Okay. And then is it correct that you and Mr. Clinton proceeded into his private office?

A. Yes.

Q. When you were within the private office, please tell me exactly what happened.

A. I continued to talk to him about what was happening and how my situation had changed.

Q. Your financial situation?

A. Yes. Our whole family dynamics had changed. . . .

Q. And did you explain that to him?

A. Yes.

Q. To the best of your recollection, can you tell me how you – the words you used in explaining that to him?

A. I can't recall the words.

Q. Roughly how long did that conversation last?

A. I have no idea.

Q. All afternoon?

A. No.

Q. Half an hour?

A. I don't think so.

Q. Probably less than half an hour?

A. Probably.

Q. Can you be any more specific than that as to how long it lasted?

A. No.

Q. In response to your explanation about your family financial situation, did Mr. Clinton say anything to you?

A. I think he just listened.

Q. Do you recall whether he verbally responded at all?

A. Other than what I've already told you.

Q. Well, correct me if I'm wrong, ma'am, but I thought you said what you told me that he verbally said before took place in the Oval office, and now we're in the private office?

A. Right, correct.

Q. Within the private office, do you recall whether Mr. Clinton said anything verbally in response to you?

A. I don't recall.

Q. When you were within the private office, did Mr. Clinton physically approach you in any way?

A. No.

Q. When you were within the private office, did you physically approach Mr. Clinton in any way?

A. No.

Q. When you were within the private office, was there any physical contact between Mr. Clinton and you at all?

A. No.

Q. When you were within that private office, was there any sexual contact between you and Mr. Clinton at all?

A. No.

Q. At any time starting with your entry into the Oval Office that day and up to the point in your narrative now where you are within the private office, was there any physical contact between you and Mr. Clinton other than the hug that you described initially.

A. No.

Q. Can you tell us how the meeting in the private office concluded?

A. I think I said, "I've taken enough of your time and thank you for listening."

Q. And did he say anything back to you?

A. I think he said he was sorry that I was having the problems – that we were having the problems we were having. . . .

Q. And after you turned to leave, what happened?

A. Well, we got to the door back into the Oval Office. We got to that door.

Q. By walking back down that same hall?

A. Uh-huh.

Q. And then what happened?

A. Then he hugged me again and said that they would try to help me.

Q. And was that at the door in the private hallway leading back into the Oval Office?

A. Yes.

Q. And please describe the exact physical nature of the hug.

A. It was a hug.

Q. Is that all? Just an embrace?

A. It was a hug.

Q. Can you describe it any more fully than that?

A. Just a big hug.

Q. Did you hug him back?

A. I think so. I mean, I think so. I mean, I don't really recall if I did or not.

Q. After that hug, what happened after that?

A. Well, it continued.

Q. Okay, please describe exactly how it continued.

A. The hug just continued longer than I expected.

Q. Can you give us an estimation as to how long the hug continued?

A. No.

Q. It wasn't all afternoon; is that correct?

A. No.

Q. Okay. Was it as long as a minute?

A. I really don't know.

Q. Was there any kissing involved during that hug?

A. There was an attempt.

Q. Please describe that as fully as you can.

A. He attempted to kiss me.

Q. Mr. Clinton did?

A. Yes.

Q. On the lips?

A. Yes.

Q. Anyplace else? On the neck?

A. No.

Q. And what was your response to that attempt?

A. Surprise.

Q. Did you allow him to kiss you?

A. I don't think so.

Q. Was he successful in kissing you?

A. I can't remember.

Q. It could be that he was successful?

A. It could be that he wasn't. I don't remember.

Q. Was that the only – was there only one instance of an attempt on Mr. Clinton's part to kiss you?

A. Yes.

Q. Did you ever attempt to kiss him back?

A. No.

Q. During the time period that this hug went on longer than you expected, as you said, was there any other attempt physically on his part to touch you?

A. Well, he had his arms around me.

Q. Other than having his arms around your back; is that right?

A. Right.

Q. Did he ever move his arms to any other portion on your body?

A. I don't recall.

Q. Is it possible that he did?

A. I don't recall. . . .

The Court: . . . I think what Mr. Campbell wants to know is if there was any physical contact between you and the president which had a sexual connotation, and I think you can answer that.

A. I think that's where he was going.

Q. What's the basis for you saying "I think that's where he was going"?

A. It's just a feeling I had.

Q. Can you tell me how you got that feeling?

A. I felt like it was more than just a platonic hug.

Q. Can you give us any more specifics as to why you felt that way?

A. No.

Q. What were you wearing on that occasion?

A. I don't have the faintest idea.

Q. Can you tell us whether it was a dress or pants?

A. I don't remember.

Q. Did Mr. Clinton ever place his hands on any part of your legs?

A. No.

Q. Did Mr. Clinton ever place his hands on any part of your buttocks?

A. I don't remember. . . .

Q. You can't categorically say he did not; is that correct?

A. Correct.

Q. Did Mr. Clinton ever seek to take either of your hands and place it on his body anyplace?

A. Yes.

Q. Please describe that. . . .

A. He put his hands – he put my hands on his genitals.

Q. Which hand?

A. I don't recall.

Q. And approximately how long did that last?

A. I don't recall.

Q. What was your reaction?

A. It was very unexpected.

Q. Were you surprised?

A. Yes.

Q. Did you resist?

A. Yes.

Q. How?

A. I just resisted.

Q. Did you try to push him away?

A. Yes.

Q. Were you successful?

A. Yes.

Q. Immediately successful?

A. I don't recall the time frame.

Q. Did you attempt to withdraw your hand from his genital area?

A. Yes.

Q. Promptly?

A. Yes.

Q. Were you successful?

A. As best I recall.

Q. Immediately successful?

A. I don't recall. I don't know what you mean by "immediate."

Q. Well, were you able to remove your hand from his genital area within a second or two?

A. Probably.

Q. Could you tell whether he was aroused?

A. Yes.

Q. And was he?

A. Yes.

Q. After you withdrew your hand from his genital area, what's the next physical thing that happened during that encounter?

A. I left.

Q. Before you left, did he attempt to kiss you again?

A. No.

Q. Did he attempt to take either of your hands again?

A. No.

Q. Did he attempt to hug you again?

A. I don't recall.

Q. Did you have to gain release from his embrace in order to leave the room?

A. Yes.

Q. And how did you accomplish that?

A. I just got out from his embrace.

Q. Did you have to physically push him away?

A. I don't recall.

Q. Do you recall whether you had to struggle at all?

A. No.

[Robert Bennett, Clinton's attorney]: Well, I'm sorry, no you don't recall or no, you didn't have to struggle?

A. No, there was not a struggle. I don't think there was a struggle. . . .

Q. And can you tell me whether you discerned any attempt on his part to resist your attempt to escape from his embrace . . .

A. He did not resist my attempt.

Q. Can you give me any concept of the time frame that was involved in this specific incident?

A. No.

Q. Did Mr. Clinton attempt to touch your breasts?

A. I think so.

Q. And what's the basis for your thinking so?

A. I have a recollection of that.

Q. Was he successful?

A. Yes.

Q. With one hand or both hands?

A. I don't recall.

Q. And can you give me any time concept as to how long that contact took place?

A. No.

Q. Was that during this hug incident that we're talking about right now?

A. Yes.

Q. Can you tell us whether the touching of your breasts occurred before or after Mr. Clinton took your hand and put it on his genitals?

A. I don't recall.

Q. At the time beginning with the time that you broke away from Mr. Clinton until the time you exited his presence, did you say anything to him?

A. I think I expressed surprise.

Q. Can you recall anything else that you expressed to him?

A. No.

Q. Did you ask him to stop?

A. I don't think I verbally did.

Q. Do you think you did non-verbally?

A. Yes.

Q. By what?

A. By resisting.

Q. At any time during – from the beginning of this hugging incident that you're just now describing up through to the point in time that you broke away and left the room, did he say anything to you?

A. Yes.

Q. Please tell us what he said.

The Court: If you recall, now you've got to tell us Ms. Willey. We've got to move along.

A. I recall him saying that he had wanted to do that for a long time.

Q. Was he referring to the physical contact?

A. I don't know.

Q. That's to the best of your recollection as to what he said?

A. Yes. . . .

Q. When you broke away and started your exit, please tell us exactly how you accomplished the exit.

A. I opened the door.

Q. You opened the door from the private hallway into the Oval Office?

A. Yes. . . .

Q. And then where did you go?

A. I stood in front of his desk.

Q. And then what happened?

A. He sat down behind his desk. . . .

Q. And then what happened?

A. I left. . . .

Q. Did you say anything to him during that period of time?

A. I think I thanked him for taking the time to talk to me. . . .

Q. Did he say anything to you during that time?

A. I don't remember.

Q. You don't recall one way or the other whether he said anything to you as he said –

A. I think he said "goodbye." I think he responded to my thanking him in some way. I mean, he didn't just sit there. . . .

Q. And then after that brief interchange within the Oval Office again, is it correct that you turned and left the room?

A. Yes.

Q. Did he remain seated behind his desk?

A. Yes.

Q. Was there anyone at the door when you exited?

A. Yes.

Q. Who was that?

A. I recall seeing I believe it was Lloyd Bentsen. I saw about six people standing there. I recall him and I think Leon Panetta. . . .

Q. Was there any other time during your knowing of Mr. Clinton that you were ever alone with him?

A. That day?

Q. No, ma'am, any time.

A. The day I went back to work. [after her husband's death]

Q. And when was that, roughly?

A. About the 10th of December.

Q. Of 1993?

A. Yes.

Q. And you saw Mr. Clinton that day?

A. Yes.

Q. Where?

A. In his Oval Office. In the Oval Office.

Q. And about what time of day was that?

A. I don't remember.

Q. Morning or afternoon?

A. I don't recall. Afternoon I think.

Q. And had you set up that meeting in advance?

A. No.

Q. Did you just walk down the hall from your office to his office to see him?

A. I don't remember. . . .

Q. What did you do once you got inside the Oval Office?

A. I sat down in the chair across from his desk.

Q. And where was Mr. Clinton?

A. Behind his desk.

Q. Did you speak to him.

A. Yes.

Q. What did you say, to the best of your recollection?

A. I think I told him about what had happened with my husband and what had – the things I learned since his death. . . .

Q. Your husband's death. Do you recall anything else that you said –

A. That I wanted to stay there; that at that point my best opportunity for employment was there.

Q. When you say "there," what do you mean?

A. At the White House or in the system someplace.

Q. In the federal government system?

A. Yes.

Q. Can you recall anything else that you said to Mr. Clinton on that occasion?

A. No.

Q. Did Mr. Clinton say anything to you?

A. He expressed his sympathy.

Q. Did he say anything else to you on that occasion?

A. He asked me how my children were.

Q. Did he say –

A. He asked me how I was.

Q. Did Mr. Clinton respond to your information that you would like to stay within the governmental system of employment?

A. Yes.

Q. What did he say?

A. He said, 'We'll do all we can for you." Something like that. I don't think that was the exact words, but that's –

Q. Something to that effect?

A. Right.

Q. On that occasion, can you recall whether Mr. Clinton said anything else other than what you just described to you?

A. No. . . .

Q. Approximately how long did that meeting last?

A. I don't know.

Q. Less than half an hour?

A. I think so.

Q. During that meeting, was there any physical contact between you and Mr. Clinton?

A. I don't remember.

Q. Do you recall that whether he hugged you when you came in?

A. I can't recall if he did or did not.

Q. Do you recall whether you affirmatively tried to hug him at any time during that meeting . . .

A. No.

Q. Is is true that you can't say for sure that he did not try to hug you?

A. That's true.

Q. Was there any other, other than the possible hug, was there any other physical contact –

A No.

Q. – between you and him.

A. No, sir.

Q. On that occasion, did Mr. Clinton take you anywhere other than the Oval Office proper?

A. I think we went back to his – we went and got coffee and sat in his office off of the Oval Office.

Q. The private office?

A. Yes. . . .

Q. And then went into the private office?

A. Yes.

Q. What happened when you were in the private office?

A. We just had a conversation about my husband's death and what had led up to it and what had happened since and my state of mind and how my children were and the state of everything. It was a – I was – it was a very chaotic time for me. . . .

Q. And what happened then?

A. I left. . . .

Q. All right. Starting with the time that you and Mr. Clinton were still within the OVal Office proper, continuing through the time when you went down the private hall to the galley, got the coffee, and then went to his private office and including the time that you then left the private office and went back to exit the Oval Office, was there any physical contact between you and Mr. Clinton at all?

A. No.

Q. When you came back into the Oval Office proper, did you immediately exit through the main Oval Office door?

A. Yes. . . .

Q. Other than what you just told us already, did Mr. Clinton say anything to you as you were leaving the private office and then the Oval Office proper?

A. I think he was very concerned and solicitous. A feeling that I had.

Q. On the way out, did he hug you?

A. I don't remember.

Q. Other than the two occasions that you've now testified about where you were alone with Mr. Clinton, have there been any other times that you have been alone with Mr. Clinton? [Willey was subsequently offered a part-time paid position in the White House counsel's office]

A. When I left, the day I left the White House.

Q. And when was that?

A. November of '94.

Q. And where did you see him that day?

A. In the Oval Office. . . .

Q. Was the door closed ever?

A. I don't remember.

Q. Okay. When you were inside the Oval Office on that occasion, it was just you and Mr. Clinton; is that right?

A. Yes.

Q. And where was Mr. Clinton?

A. He was sitting behind his desk when I walked in.

Q. Did he get up when you walked in?

A. Yes.

Q. And what happened next?

A. I said that – he came around to my side of the desk and stood there, and I thanked him for what he and the administration had done for me and that even though I was leaving then that I hoped to come back in some way.

Q. Some way?

A. In some capacity.

Q. And did he say anything to you?

A. He said that they would try to help me.

Q. Come back in some capacity?

A. Yes. . . .

Q. And approximately how long did that meeting last?

A. I don't know.

Q. Five or ten minutes?

A. Maybe.

Q. Were you sitting or standing?

A. Standing.

Q. In front of the desk?

A. Yes.

Q. On that occasion, was there any physical contact at all between you and Mr. Clinton?

A. He hugged me goodbye.

Q. For a brief period of time or –

A. Yes.

Q. Did you hug him back?

A. Yes.

Q. Did he attempt to kiss you on that occasion?

A. No.

Q. Did he attempt to have any other type of sexual contact with you on that occasion?

A. No.

Q. And did you attempt to have any type of sexual contact with him on that occasion?

A. No.

Q. During that meeting with Mr. Clinton, did he again take you down the private hallway?

A. No. . . .

Q. And after he hugged you goodbye, did you exit the office?

A. Yes. . . .

Q. Was there ever an occasion beginning immediately after the sexual incident that you have described for us. ever an occasion that you discussed that incident with Mr. Clinton again?

A. I think that when I went back my first day of work I think I may have made a reference to that. I don't know in what way – I mean, I don't know how I said it but I basically said I just wanted that to be –

Q. Over?

A. Right.

Q. In the past?

A. Yes. And that I was in a very desperate situation and that I still needed to work there.

Q. And did Mr. Clinton say anything to you that would indicate to you that he agreed to have that incident be in the past?

A. No.

Q. Other than the occasions that you have just now described to us when you were alone with Mr. Clinton, were there any other occasions you were ever alone with Mr. Clinton?

A. No.