11.   Given their several communications in the weeks before the deposition, it is not credible that the President forgot the subject of their conversations during his civil deposition.

12.   Substantial and credible information demonstrates that the President made ... false statements under oath in his civil deposition regarding whether he had been alone with Ms. Lewinsky.

13.   The President referred to Ms. Currie on multiple occasions in his civil deposition when describing his relationship with Ms. Lewinsky.

14.   The President was questioned in his civil deposition about his conversations with Vernon Jordan regarding Ms. Lewinsky and her role in the Jones case.