Excerpt From Kathleen Willey's Deposition to Paula Jones' Lawyers
March 15, 1998


On Nov. 29, 1993, Kathleen Willey arrived at the White House to meet with President Clinton and to ask for a full-time job with the federal government.

At the time, her family was going through a rough period: Her husband, Edward E. Willey Jr., had recently declared bankruptcy; and, reportedly, the two were having marital problems.

Both Edward and Kathleen Willey were prominant Democratic fund-raisers and long-time supporters of the president.

Unbeknownst to the president or Ms. Willey, Edward Willey had committed suicide that afternoon.

The following excerpt picks up after Ms. Willey has been greeted by the president, and then taken briefly to the Oval Office and served coffee.

The "private office" mentioned in the first question is not the Oval Office but a smaller office down the hall.

 

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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. . . .






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