Below is the full text of those portions of Paula Jones' deposition in Jones v. Clinton sexual harassment lawsuit that were made public by President Clinton's attorneys. The portions reproduced here were made public by President Clinton's attorneys in Federal District Court in Little Rock, Arkansas in support of their motion for summary judgment requesting that the Jones suit be dismissed. The rest of the transcript remains under seal.
The excerpts cover three major topics:
Some of the language in these excerpts is sexually explicit.
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(Starts on Page 24)
BY MR. BENNETT:
Q. I'm sorry. If I forgot to ask you that question. I don't have as good a memory as your counsel. But who was your supervisor there?
A. I'm trying to think. I don't remember who she was.
Q. Do you remember what year you worked there?
A. Probably 1988.
Q. And you were fired from that job as well, weren't you?
A. Well, it was actually a mutual thing, but yes. On the paperwork I believe it was that I was fired.
Q. And the reason they gave you for firing you?
A. For being late.
Q. And you were late a lot, weren't you?
A. Yes.
Q. All right. After you worked at Dillard's, where did you work?
A. Hertz car rental.
Q. And where was that?
A. At the Little Rock airport.
Q. And how long were you employed there? Do you remember?
A. About four months.
Q. And what did you do there?
A. I rented cars.
Q. Okay. And you were fired from that job too; is that right?
(Pages 25 to 32 are missing)
... the state gives to all employees before they hire them.
Q. And have you had an opportunity since you answered the interrogatories to review your employment records at AIDC?
A. No.
Q. You knew I'd be asking you questions today about your employment history at AIDC, didn't you?
MR. CAMPBELL: Objection. Assumes facts not in evidence and –
BY MR. BENNETT:
Q. Did you?
MR. CAMPBELL: – asks for speculation and conjecture as to what might be in the mind of another.
BY MR. BENNETT:
Q. I'm asking you what was in your mind?
A. No.
Q. You didn't think I would be asking you about your employment?
A. I didn't really think about what you would be asking me.
Q. Okay. Who did you first talk to about getting a job at AIDC?
A. I believe it was Pam Blackard.
Q. And is Pam the lady whose deposition was taken in these offices a short while ago?
A. Yes.
Q. And she's one of your best friends; is that right?
(Page 34 is missing)
A. I have no idea.
Q. All right. When did you start work at AIDC?
A. I think it was March of '90.
Q. March of '90?
A. I'm not sure, actually. I'm really not.
Q. Okay. Do you know how long you worked there?
A. Two years.
Q. And were you fired from there?
A. No.
Q. Did they force you out?
A. In a way.
Q. How?
A. I could tell that there was – I had applied for different other jobs within the agency and my supervisor would always try to discourage me, try to keep me over on that corner saying that I could grow and make something of myself if I stay over there and let her train me. And I never went anywhere. There was a lot of hostility it seemed between Cherry Duckett and I. She never would speak to me. I'd try to – I'd talk to anybody, you know, very outgoing. I would try to talk to her. There's several things that – I'm not a hyper – one of those schizophrenics that thinks that's something's wrong all the time. And you can tell when there's a lot of static in an office place when you go there every day for two years.
Q. Are there any other things you haven't just testified about? Tell me everything that causes you to think that they wanted you to leave. Is that what you are saying? They wanted you to leave?
MR. CAMPBELL: Objection. Multifarious.
BY MR. BENNETT:
Q. Is that what you're saying? Are you saying that they wanted you to leave?
A. I feel that they wanted to keep me in that area so I wouldn't get outside their little wing to where they could control me and make sure that I stayed right there and couldn't upgrade myself at all. Absolutely.
Q. All right. Now who do you think wanted to control you?
A. Either Dave Herrington or Cherry Duckett.
Q. Did you ever talk to Dave Herrington?
A. Very seldom.
Q. Did Dave Herrington ever say anything to you to suggest that he wanted to control you?
A. We never talked at length. It was just "hi" or something like that. That was it. Never had any conversations.
Q. Okay. Well now, who else do you think tried to control you.
A. Clydine Pennington.
Q. And was she your supervisor for the whole two years you were there?
A. Yes.
Q. Why did Clydine Pennington want to control you, do you know?
A. I don't know.
Q. What specific job did you apply for?
A. I applied for document examiner, document examiner, that was my initial thing that I had applied for.
Q. And you got that job?
A. Yes.
Q. But you have indicated in your answer – previous answers to me that in a way they wanted you out because you couldn't get certain positions you wanted. Did I understand you correctly?
A. Correct.
Q. And I'm asking you what those other positions were that you applied for that you didn't get. Would you give me specifics?
A. It was a grade higher, that I could make more pay. It was something that I know that maybe could broaden my skills and help me grow and I would try to apply for them because document examiner was at the very low entry level and I wanted to try to grow. And each time I would try to do that, I would talk to my supervisor about it and she would always discourage me and make me believe that I could grow within the administrative services, which in fact I didn't. I got degrade – downgraded.
Q. All right. Now what higher grade were you trying to get to?
A. Just the next grade. You know, there's always a pay level difference when you go to another step and another grade and that's want I was wanting.
Q. What was that grade?
A. I really don't know. It was higher than the grade that I was at and I don't remember what grade level I was at when I was hired.
Q. Do you know what grade level you were at?
A. No.
Q. And you don't know what the higher grade level was?
A. No. Ten or 11 maybe. Ten or – I don't recall exactly how it went now.
Q. Do you know what the qualifications were for the next higher grade?
A. Yes.
Q. What were they?
A. Well, it was the qualifications that I knew that I could – that I was qualified for. It was for typing and different things. It just had a higher grade level. There might not have been much of a job difference or in your job duties, but it would have a higher grade level. According to which position of the building, you know, an area that it was in.
Q. Did you ever write a letter or a request to any or your supervisors asking that you be permitted to apply for a higher grade?
A. I don't know if I put it in writing to Clydine Pennington, but I know I did two different times orally went into her office and asked her and told her what I would like to do, would it be okay with her, because I felt that I wanted to tell her instead of just leaving out of the department without her knowing. I was trying to be nice to her. And she would always discourage me. "No, you stay over here. We want to keep you over here. We like you. We want you to stay over here. You will grow with us. You stay over here and we'll teach you everything." That's how she would get me to stay. But then when I stayed, nothing ever happened.
Q. All right. Now when was the first conversation you had with Ms. Pennington, do you remember?
A. No.
Q. Do you remember when the second one was?
A. No.
Q. Do you remember exactly what you said to Ms. Pennington on either of those occasions?
A. What I repeated just a minute ago.
Q. Do you remember exactly what she said to you?
A. Yeah. She would tell me, "We like you over here. We want to keep you over here. We want to – if you stay over here, Paula, we can train you and help you grow with the company and we want to keep you over here." She would put it that way.
Q. Now on July 1st, 1991, you received a cost-of-living increase, didn't you?
A. Probably. I don't know what date it was. But I know I received what everybody else got each year.
Q. Now also on July 1st, 1991, you were upgraded from a Grade 9 to a Grade 11, the very grade you mentioned, weren't you?
A. I don't recall.
Q. Well, do you dispute that that's what the record show?
MR CAMPBELL: Objection. No foundation. No evidence in the record.
BY MR. BENNETT:
Q. Do you dispute – you can answer.
A. No.
Q. So you did get a Grade 11, didn't you?
A. That's what I'm saying. I don't really know how the grades went. I don't know how the grades went. I don't know what I came in as and I don't know what I left as. So I don't know.
Q. Well, you went from, on July 1, 1991, according to the records, you went from a Grade 9 to a Grade 11. Did you ever apply for a grade 12 or 13 or 14?
MR CAMPBELL: Objection. No foundation. No evidence in the record.
BY MR. BENNETT:
Q. Did you ever apply for a grade higher than 11?
A. Yes. I believe I did.
Q. When?
A. I don't know. I just – those few times when I would talk to Clydine and she would say that, I would go ahead and fill out an application maybe or something.
Q. All right. And on March 11th, 1992, you received a merit increase?
A. Um-huh.
Q. Didn't you?
A. Probably. That's what everybody else received too.
Q. And on –
A. Cost-of-living-raise.
Q. And on July – no. I said merit increase.
A. Oh, I don't what that is.
Q. You know there's a difference between a merit increase and a cost-of-living increase, you know that?
A. No.
Q. You don't know that you got both cost-of-living increases and merit increases when you worked at AIDC?
A. I don't know if I did or not.
Q. You resigned on February 2nd, 1993; is that correct?
A. Yes.
Q. You weren't fired, were you?
A. No.
Q. You weren't terminated, were you?
A. No.
Q. At no time that you worked for AIDC did you ever get demoted in pay, did you?
A. I'm not sure actually. I don't think so.
Q. Did they ever decrease your grade at any time at AIDC?
A. I think they did.
Q. When?
A. When I came back from maternity leave.
Q. All right. You think you went down in grade?
A. I was thinking I did, yes.
Q. What grade did you go down to?
A. To like a 9 or 10 or something like that, it seemed like.
Q. If I were to tell you that the records show that you didn't go down a grade, would you dispute that?
MR. CAMPBELL: Objection. Assumes facts not in evidence. No foundation.
THE WITNESS: Yeah.
BY MR BENNETT:
Q. You would dispute that?
A. Yes, I would.
Q. Do you know how much money you made before you went on maternity leave?
A. No, I don't.
Q. Do you know how much money you made after you came back from maternity leave?
A. No, I don't.
Q. At any time during the period you worked at AIDC, did anybody at AIDC ever mention to you the alleged incident with Governor Clinton?
MR. CAMPBELL: Objection. Ambiguous, vague, global. There's a number of alleged incidents with Governor Clinton.
BY MR. BENNETT:
Q. On the incident – the incident which allegedly occurred at the Excelsior Hotel on May 8th, 1991, did anybody at AIDC ever mention to you at any point in time while you worked there?
A. Pam Blackard.
Q. How did Pam Blackard know about it?
A. Because she was there.
Q. She wasn't in the room, was she?
A. No. But she was at the conference and knew what had took place that day.
Q. But you told Pam Blackard, didn't you?
A. What went on in the room?
Q. Yes.
A. Yes.
Q. You didn't tell her everything that went on in the room, though, did you?
A. Yes. Eventually. Yes, I did.
Q. At the time?
A. Oh, no, not at the time.
Q. All right. Now you were here for Pam Blackard's deposition, weren't you?
A. Yes.
Q. And did you hear Pam Blackard testify that she never told anybody at AIDC, that to swore her to secrecy, or words to that effect?
A. Yes.
Q. Do you believe Pam Blackard wouldn't have told anybody?
A. Yes. I believe that.
Q. Other than Pam Blackard, did you tell anybody at AIDC?
A. No, I did not.
Q. All right. Now my question to you is, during the period of time that you worked at AIDC, did any of your supervisors or anyone else mention to you that they were aware of the incident which allegedly occurred in the room at the Excelsior Hotel?
A. No.
Q. Did anybody say to you that you weren't getting a promotion because you wouldn't give sex to Governor Clinton?
A. No.
Q. Did anyone ever say to you that if you gave sex to Governor Clinton that you would get promoted or get a raise or get a better job?
A. No. But I'm sure they would never say that if they did know about it.
MR. BRISTOW: Objection. It's not responsive.
BY MR. BENNETT:
Q. Do you know of anybody at AIDC who knew about this incident other – let me finish – other than Pam Blackard?
A. Not to my knowledge. Personally, nobody mentioned it to me. That doesn't mean they didn't know.
Q. You don't know of anybody, though, do you?
A. Un-uh.
Q. How did you and Ms. Pennington get along during the two years?
A. At first we were – I really liked her at first. She was really nice and everything. But it seemed like after a few months, it started changing. She was more – not as friendly as she used to have been. She liked to talk too, you know. She had to go around to everybody's desk and chat and talk and stuff.
Q. Did Ms. Pennington interview you for your job?
A. Yes.
Q. Did you tell Ms. Pennington at the time of your interview that you had been fired from these several jobs?
A. If she asked me, yes, I did.
Q. On the application there is a line asking you the reasons for leaving, wasn't there?
MR. CAMPBELL: Objection. Objection. No foundation. Assumes facts not in evidence.
BY MR. BENNETT:
Q. Do you know if the application had a line where you were supposed to say why you left your prior employment?
A. No, I don't know.
Q. You didn't fill that out, did you?
A. I don't know if I did or not.
Q. Is it your testimony that if – that you – if Clydine Pennington asked you why you left those other jobs, you would have told her you were fired from some of them; is that correct?
A. I would have told her, yes, if she asked me.
Q. Did you tell Ms. Pennington that your experience in your other jobs was such that older women didn't like you?
A. What are you referring to?
Q. When you were interviewed by Ms. Pennington –
A. What older women?
Q. Well, I don't know. I'm asking you. Did you ever tell Ms. Pennington that in your other jobs you had difficulty with other older women?
A. In one job.
Q. Which job was that?
A. Hertz.
Q. And what did you tell Ms. Pennington?
A. I don't recall telling her anything actually.
Q. Now when you left, do you remember – AIDC – do you remember the month and the year you left?
A. AIDC?
Q. Um-huh.
A. I left in '93, probably February of '93.
Q. You left right before your second anniversary; is that right?
A. No.
MR. CAMPBELL: Objection. Misstates the evidence in the record.
BY MR. BENNETT:
Q. You may answer the question.
A. What anniversary are you talking about?
Q. When did you start at AIDC?
A. In March, I believe.
Q. Of what year?
A. Of '90?
Q. '91.
A. '91, something like that.
Q. And you left when? In February of '93; is that right?
A. I believe that's correct.
Q. So had you stayed another month, it would have been two years there. That's what I meant by anniversary. Is that right?
A. Yes. Yes. You're right.
Q. And you indicated to people at AIDC that you were looking for federal employment; is that correct, when you left?
A. No.
Q. You never told anybody that?
A. I never said that.
Q. Did you tell people that you were moving because your husband's job had changed?
A. Yes.
Q. And who did you tell that to?
A. I don't know. Just my friends and stuff probably and probably told my supervisor that I was going to quit.
Q. And what reasons did you give them for quitting?
A. Because my husband got transferred and we were moving to California.
Q. Was that true?
A. Absolutely.
Q. Now in the last few days at AIDC, you got in a big argument with Ms. Pennington about taking leave without pay; is that correct?
A. No. I don't recall that.
Q. Do you remember having an argument with anybody about your taking leave without pay?
A. No. I don't recall that.
Q. Do you remember calling Ms. Pennington a bitch?
A. I've never called her that.
Q. Do you remember yelling at her and telling her that she and AIDC, you'd get even with them?
A. No. Are you talking about this while I was still working with her?
Q. Right at the end, yeah.
A. No. This is after I quit.
Q. Oh. tell me about that.
A. This incident took place after I quit.
Q. Okay. Tell me what happened.
A. This is when I went back to clean out my desk after I had done quit AIDC. I had a confrontation with Dave Herrington and Clydine Pennington. I brought them both together so I could express the feelings that I had encountered while I was working there of how I felt that I was being treated, mistreated. And that's where that incident took place.
Q. Tell me, where did this take place?
A. Out in the – kind of like a hall area. There was a whole bunch of like dividers and stuff. It wasn't like office rooms. And I just did it right out there.
Q. And what did you say to Mr. Herrington and Ms. Pennington?
A. I explained to Mr. Herrington, whether he was aware of it or not, how Ms. Pennington treated me and that she was – I always tried to get jobs. I brought that up. And nobody would let me try to get another job and better myself. And I just spewed on them really. Because I was just very upset from how I had been treated up there by trying to better myself.
Q. What do you mean you "spewed on them"?
A. Well, just – I was upset and I was telling them and I wanted Mr. Herrington to know how Ms. Pennington was and I didn't feel that Ms. Pennington was a very good supervisor and I was just telling – I don't recall everything that was said. I just know that I wanted Mr. Herrington to know what Clydine Pennington, how I felt about the way I had been treated over in that section, whether he was aware of it or not, I wanted him to know that before I left the building.
Q. And did you yell in Ms. Pennington's presence?
A. Oh, I'm sure I did raise my voice probably.
Q. Did you use profanity?
A. I don't recall if I ever used any curse words.
Q. What did Ms. Pennington say when you spewed on her?
A. She – I think she tried to talk right back and defend herself and she got loud too as well. I think Mr. Herrington just kind of was shocked and surprised and was listening to both sides of it and everything.
Q. What did Mr. Herrington say?
A. I don't recall. I just know that he wished me well and that he was sorry that it turned out the way it did. That's what he had said. Something to that effect.
Q. You had quit some days before; is that right?
A. Yes.
Q. Do you remember how long before?
A. Maybe a few days or so before.
Q. Had you given them notice that you were going to quit because of you husband's transfer to California?
A. If I recall, it seems like they gave me a going away party thing. Yeah. They have it in a conference room and people in the thing, they had cake or whatever to wish me well or whatever.
Q. So you had told somebody that you were quitting and leaving?
A. Oh, yes. Yes. I told Clydine about the possible move.
Q. And what did she say to you?
A. I don't recall what she said to me.
Q. Tell me a little bit about this going-away party.
A. They would just have like snacks and different people from each section would bring snacks or dip or something and they would say good-bye and that would be about it.
Q. Was Ms. Pennington there?
A. I'm sure. I don't know. I don't recall. I'm sure she was.
Q. A lot of people were there?
A. I think so.
Q. Have a good time?
A. In and out. In and out. I mean, there wasn't a whole bunch of people there at one time.
Q. Have a good time at the party?
A. I don't recall. It wasn't a party. It was just, you know, to say bye and everybody to eat, you know.
Q. But it was a friendly gathering?
A. Yes.
Q. Was Pam Blackard there?
A. I don't recall.
Q. During this incident that you described where you spewed on Ms. Pennington, do you recall yelling at Mr. Herrington?
A. No. I don't think so. He was just listening. I was voicing to him how she – how I felt the way I had been treated by Ms. Pennington and he was very nice to listen.
Q. You didn't mention anything at that time, did you, about this alleged incident which occurred at the Excelsior Hotel with Governor Clinton?
A. Oh, no.
Q. Now tell me about your maternity leave. Just how many maternity leaves had you taken?
A. One.
Q. For just one child?
A. Right.
Q. The second child was born after you left; is that right?
A. Yeah. A long time after.
Q. And when you returned to work after maternity leave, did your duties change?
A. Yes, they did.
Q. Tell me how your duties changed.
A. I know I read the Arkansas handbook, state employee Arkansas handbook, before I left on maternity leave and I know I had six weeks. Well, in the Arkansas handbook under maternity leave, it stated that you are to return back to your same position after six weeks' leave and unless there was a reduce in staff or something like that. I don't remember the exact words. And when I came back, none of them called or nothing like that. I don't think I ever received a call from Clydine Pennington or anybody to tell me they were making changes while I was no longer – while I wasn't there. And when I came back, I no longer was at my desk. They had moved me completely to sit right outside Clydine's office, so she could watch me at all times. I was sitting right out front. And I didn't have any work to do. My work had been gone. I was sitting there doing nothing.
Q. All right. Now you learned when you went back that there had been some structural changes at AIDC, didn't you?
A. Like structural, what changes, what do you mean? As far as –
Q. That they had made some changes in functions in departments.
A. No, not that I know of. Just maybe – just mine. Just mine.
Q. Well, did you learn that they consolidated purchasing department responsibilities?
A. That's what they did, yes. Because that's what I was doing.
Q. And now, Mrs. Jones, isn't it a fact that when you came back, there was no change in your salary, was there?
A. No, there was not.
Q. There was no change in you supervisor, was there?
A. No. But I would just wonder why they would –
Q. There was no change in your title, was there?
A. – move me.
MR. CAMPBELL: Objection, counsel. Let the witness finish her answer.
BY MR. BENNETT:
Q. I'm sorry. I apologize.
A. Yeah, there was. I don't know what I was called. Probably a nobody sitting out in front of Clydine's office. Because Pam Hood got my job. And what is amazing to me is why it took place while I was on six months maternity leave when they could have done it before or after when I could have been there. They did it while I was away and unaware of what was going on.
Q. What was your title before you went on maternity leave?
A. Purchasing assistant.
Q. What was your title when you came back?
A. I don't know. I was not the purchasing agent anymore.
Q. Well, you still worked on purchasing things, didn't you?
A. No. I don't believe I did. That was all given to Pam Hood.
Q. Didn't you work on data both before and after you – the input of data?
A. No. Actually I worked for personnel at that point. I input applications that were brought in to AIDC for employment and that's what I did all day long. I sat there and input applications into the database. That's all I did.
Q. That's when you came back?
A. Right. I did no longer do purchasing at all.
Q. But when you were working in purchasing before you left, you were putting purchasing order, that's data input –
A. Right.
Q. – involving purchasing orders, right?
A. Um-huh.
Q. Is that correct?
A. Um-huh.
Q. You have to answer it –
A. That was my job. Oh, I'm sorry. Yes.
Q. So in both instances, you were doing data input; is that right?
A. Yes. But that was not my job title before I left. I had – I was a purchasing assistant. When I came back, I was no longer dealing with purchasing department, period. Without me transferring or asking to be moved, I was moved without anybody asking me if that's what I wanted to do.
Q. Now did you know what Pam Hood's title was?
A. She was the purchasing – I'm not really sure. Something with purchasing. She did all the major orders for the office supplies and stuff.
Q. And are you aware that she applied for that job?
A. That she did?
Q. Um-huh.
A. No.
Q. How did you get along with your co-workers at AIDC?
MR. CAMPBELL: Objection. Overbroad and global.
THE WITNESS: In general just, you know, the ones that I liked, I mean, we got along pretty good. I talked to everybody around.
BY MR. BENNETT:
Q. Were there any there that you didn't get along with particularly?
MR. CAMPBELL: Objection. Overbroad as to time.
BY MR. BENNETT:
Q. During the two-year period that you worked there.
A. Not really. Just, you know, working in a place for a while, there's always going to be talk or, you know, something, but, no, I can't think of anything specific.
Q. Did Ms. Pennington during the two-year period ever criticize you or reprimand you for any of you activities?
A. I don't recall at this moment. I don't recall right at this moment if she did or not.
Q. Did she ever reprimand you about your tardiness?
A. No.
Q. In two years, she never reprimanded you about your tardiness?
MR. CAMPBELL: Objection. Asked and answered.
MR. BENNETT:
Q. You can answer.
A. She may have talked to me about it, but I never got anything, I don't think any paperwork, or anything written up as far as I remember.
Q. I'm not asking you about paperwork. I'm asking you –
A. Okay. Yeah. She talked to me about it. She was late herself and she would bring me in there, "I know. I'm late too. I live out there by you and we have that long traffic," she said, "and I'm guilty of it too," she said, "but we've got to get us here, you know, sooner," or whatever and that's what the conversations, how they were.
Q. And she reprimanded you several times about your being late; isn't that right?
MR. CAMPBELL: Objection. Misstates the prior testimony.
MR. BENNETT: I'm not trying to state prior testimony.
BY MR. BENNETT:
Q. Didn't she reprimand you several times?
MR. CAMPBELL: Same objection.
BY MR. BENNETT:
Q. You may answer.
A. I don't recall.
Q. Did Ms. Pennington ever criticize you or reprimand you about the way you dressed?
A. No.
Q. Did anybody ever reprimand you about the way you dressed?
MR. CAMPBELL: Objection. Overbroad as to time and place.
BY MR. BENNETT:
Q. You know the place I'm talking about, don't you?
A. What are you talking about?
Q. AIDC.
A. Oh, yes.
Q. And you know the time I'm talking about, don't you? The two years you worked there?
A. Um-huh.
Q. Okay. Now, did anybody in those two years ever complain about how you dressed or criticized how you dressed?
A. No. As a matter of fact, even Dave Herrington I remember him one time saying how really nice I always tried to dress and everything when I was up there. And after I had the baby, I remember him commenting on how I had gotten back down – my weight back down and how nice I was looking.
Q. Did anybody ever criticize you while you were at AIDC during that two-year period about talking too much, gabbing too much?
A. Oh, I'm sure I got a lot of trouble – I'm sure I got in trouble for talking. But I never got like paperwork, I mean, like – stuff like that. Just – they would – she would talk to me.
Q. Right. They gave you a break on these occasions. They never formally punished you, did they?
A. Well, they would – I don't think. I don't know if there was a formal procedure to formally punish you if you were talking, but I know that they would talk to me about it.
Q. Who's "they," other than Ms. Pennington?
A. Clydine Pennington. That would be who I was talking about.
Q. And during the period of time you worked for AIDC for that two years, one of you primary functions was to deliver – as a courier to deliver things; isn't that right?
A. That's correct.
Q. And where would you deliver things to?
A. All over the state Capitol grounds.
Q. And that included the governor's office?
A. Yes.
Q. And did anybody during those two year period ever criticize you or complain to you about how long you took to do the runs?
A. I believe I heard it before. But it was – they were just speculating because they didn't know what my job duties were and my job duties were to stay in the spot I was going until I had to carry paper back. And if people didn't know exactly what my job duties was, they might have thought I was sitting there not doing nothing.
Q. But you would go and you would make the runs, you would very often deliver things and chitchat with the people that you delivered them to?
A. Yes.
Q. And then didn't people criticize you for taking too long in you deliveries?
MR. CAMPBELL: Objection. That's overbroad and vague as to "people."
THE WITNESS: No. Not to me personally, no.
BY MR. BENNETT:
Q. Nobody ever –
A. No.
Q. Let me finish. Nobody ever complained to you that you were taking too long in making your deliveries?
MR. CAMPBELL: Same objection.
BY MR. BENNETT:
Q. Go ahead.
A. My supervisor might have said something to me. Clydine Pennington may have. But I don't recall. She may have though.
Q. Did Ms. Pennington ever warn you that if you took additional leave without pay that you might have disciplinary action imposed on you?
A. I don't recall. Un-uh.
Q. Do you remember an incident when on February 22nd, 1993, you told your supervisor that you needed to have leave without pay because you didn't have any running water in your house?
MR. CAMPBELL: Objection. Assumes facts not in evidence. No foundation.
THE WITNESS: I think that incident you're talking about was the gas was out. There was no hot water. It was when we moved from our home in Vilonia to a rental house in Jacksonville just for like a month, to move – to make the move because we sold our home and we had to get out. And I didn't have any – when I woke up to go to work to take a shower or whatever, there was no hot water so I couldn't go to work if I couldn't take a shower. It was real cold too. And that might have been the incident you're talking about. That's the only one I can think of.
BY MR. BENNETT:
Q. What did you do? Did you call Ms. Pennington?
A. I don't recall. I may have. Or I may have talked to Sherry Enderle, who was her personal secretary.
Q. And did you get in an argument about whether you should be given leave without pay for that reason?
A. No, I don't think. You're allowed to have, I think, leave without pay. But you know leave without pay. But if you do it enough times, I think you can get in trouble for it. But I don't think I had done it at all or very often.
Q. Now you were aware, weren't you, that AIDC had various complaint procedures which were available to employees if they had grievances.
A. Yes. As a matter of fact, I thought about doing that before, but I was just kind of scared to do that.
Q. You never filed any kind of grievance procedure during your two years at AIDC, did you?
A. No.
Q. Now since you have left AIDC, since you quit and went to California with your husband, have you applied for any other jobs?
A. Yes. I was with a temporary agency when I first moved out there.
Q. And what was the name of that agency?
A. Oh, I don't even know. It's been like four years ago. I could not even tell you.
Q. And did you get a job?
A. Yes. I worked at the Sheraton. I think it was the Sheraton. I worked in the executive offices. I was the reception – the main secretary out front, the receptionist.
Q. Was that the Sheraton Hotel?
A. Yeah. I was in the offices, though. I wasn't in the hotel part.
Q. And where exactly that was?
A. It was in Long Beach.
Q. Excuse me?
A. It was in Long Beach.
Q. How long did you work there?
A. Maybe a week or two. But it was because they were – I was just a temp until they found a permanent replacement. Because I wasn't qualified for the job and I wasn't trying to get the job. They just needed a temp until they hired somebody qualified for the job.
Q. All right. Did you ever apply for any other jobs after that?
A. I don't believe so. Because after I got my paycheck for that one week, it was not feasible to work and pay day care when day care took up that whole week's pay.
Q. How much pay did you get from them at the Sheraton?
A. I don't recall. But I remember day care for that one week was like $124 for a week and I don't think I made a whole lot over that. And it just wasn't feasible for me to drive and take my son to day care and me work. It would eat up the money.
Q. You made a lot less there than you did at AIDC, didn't you?
A. No. I was making $9 an hour at the Sheraton for just a week.
Q. So you were making more money –
A. For just a week, though.
Q. I see. All right. Did you apply for any other jobs?
A. I don't know if I did or not. I didn't apply. It's just that they would send me out, you know. Because they had my application at the temporary agency and they would send my application if they thought there was a job that I was interested in or something I –
Q. When is the last time you worked at a job other than –
A. The Sheraton.
Q. – other than being a mother of two children, which is a big job. I understand that.
A. Right. The Sheraton.
Q. Sheraton. So after you worked at the Sheraton, did you try to get any other employment?
A. I went to another interview and I know they liked me the first time I went in. And they didn't call me back and then about a week later, they did call me back, and then they interviewed me again and they didn't hire me for some reason. I don't know.
Q. And do you remember what year that was?
A. It was the same year. Probably in '94, '93, early '94, before – it was right after this – the lawsuit, I remember. Because they were talking about it up there and stuff.
Q. All right. Since you filed the law suit, have you applied for any other jobs?
A. No.
Q. Have you worked in any other jobs?
A. No.
Q. Do you have any intention of applying for any other jobs as you sit here today?
A. Oh, not until my kids go to school.
Q. And when will that be?
A. Well, neither one are in school yet. My oldest starts next year kindergarten and my youngest won't start for five more years, I want to stay home with my children.
(Pages 66-67 are missing.)
Q. Mr. Campbell doesn't know. I guess he never bounces.
MR. CAMPBELL: Objection to the sidebar.
BY MR. BENNETT:
Q. Did you ever bounce a check?
MR. CAMPBELL: Same objection.
MR. BENNETT: She knows what I mean, Mr. Campbell.
MR. CAMPBELL: I don't need that either, counsel.
MR. BENNETT: I mean, your silly objections, they're – you're just trying to harass me.
MR. CAMPBELL: I don't understand what you mean by bounce a check.
BY MR. BENNETT:
Q. Did you ever write a bad check at AIDC? A check where there were insufficient funds?
A. I don't recall.
Q. Do you recall an instance where you were asked to reimburse them for personal phone calls that you had made?
A. Yes. As well as everyone else had to do that.
Q. And did you give them a check for that, do you remember?
A. Yes.
Q. Do you remember if that check didn't go through for insufficient funds?
A. It could have at one time or something, but I don't recall.
Q. Do you remember asking for a picture of Governor Clinton from his office during one of your courier runs?
A. No.
Q. Do you deny that occurred?
A. It occurred the way you said it, yeah. I deny that. Yes.
Q. The way I said it?
A. Yeah. They way you said it.
Q. Well, do you have any recollection of asking anybody for a picture?
A. No.
Q. Did you get a picture?
A. Carole Phillips.
Q. Tell me about it.
A. Had a picture signed for me and just gave it to me. Of course, she did not know about the incident because I never talked to her about this. But she had, I guess on her own doings, had a picture sitting there waiting on me, signed from the governor, thinking that I would be very excited to get that picture. She did that on her own freewill. But I don't even know if I took the picture. I think I may have because she did not know about what had happened.
Q. And that was after the incident?
A. Yes.
Q. And do you remember signing a birthday card for Governor Clinton?
A. I believe I did.
Q. It's a big card?
A. Yes. I believe I did.
Q. And that was after the incident as well?
A. Yes.
Q. Wasn't it?
A. Um-huh. The reason was Carole Phillips was so excited. "You've got to sign this. You've got to sign this." She was a very jovial person and I didn't want her to lead on that there was something wrong. So I said, "Well, okay. I'll sign it." And I just signed my name or whatever to it. I don't remember or whatever.
Q. Did you write a note on it?
A. I don't think so.
Q. Now other than what you've already testified to this morning, can you identify for me any specific detriment or adverse action which you say you suffered at work because you refused to have sex with Governor Clinton?
MR. CAMPBELL: Objection. Overbroad. Vague as to which work.
BY MR. BENNETT:
Q. You can answer.
A. Just every day when I went there, it just seemed like there was a lot of smoke in the air, just cloudy, you know, the way my supervisor treated me. It was just a day-to-day thing. I know when I came back from maternity leave, I know they downgraded my job duties. Maybe not my pay but they did it knowingly, that I was coming back in six weeks. They could have done it before then or after I came back. They did that intentionally. Just the way, Cherry Duckett would walk right in front of me and I would look right at her and say, "Hi, how are you doing today," and she would hold her head down, "hi," and keep walking. That's not very professional. And that's not very nice, you know, if you've got employees working underneath you, it's good to be nice to them every day to make them feel comfortable about working in that area. And she made me feel so uncomfortable and I couldn't think of any other reason except for maybe that she knew about the incident. She was told to act like that.
Q. Now do you have any reason to believe that any of these people knew about this incident?
A. Well, Governor Clinton told me that Dave Herrington was a good friend of his and he appointed him to that job. So, yeah, I have every reason in the world to believe that they could have found – known about it.
Q. Well, we'll get to that. But when –
A. Well, I'm answering the question that you asked.
Q. No, you didn't answer the question.
MR. CAMPBELL: Yes, she did.
THE WITNESS: Yeah, I did.
BY MR. BENNETT:
Q. The question is, you have described to me, Mrs. Jones, what you perceived as the attitude of people towards you.
A. Right.
Q. You were uncomfortable; is that right?
A. Right.
Q. Did any of those people ever mention the incident with Governor Clinton?
A. No. But they wouldn't.
Q. Did any of these people say anything to suggest to you that they knew about the incident?
A. No. But like, for instance, one time on Secretary's Day, I'm a secretary and had been there nearly two years, and after the incident happened and everything, everybody in my section got flowers on Secretary's Day. I'm the only one out there did not get any flowers. And everybody noticed it and was coming around and saying, "That is so cruel of them. I cannot believe they did that to you." Now what other reason would they do that? Just to leave me out intentionally knowing that I'm a secretary. I'm sitting there. Things like that they would do. There had to be a reason for it. I know I wasn't doing anything wrong. So that's why I feel that there was things – somebody knew something. And it's very, you know, I don't know for a fact that they knew about it. But there had to be something for me to be treated that way. And I know that he was good friends with Bill Clinton because it came out his mouth hisself.
Q. Now what year was it you didn't get flowers on Secretary's Day?
A. Probably '93. Or no, no, no, '92. I'm sorry.
Q. Now you weren't a secretary, were you?
A. Yeah. I was considered a secretary in – none of the other people were considered secretaries except for Clydine's personal secretary. And even the accountant, even the insurance lady, everybody got flowers but me. I was the only one. My husband sent me flowers because it hurt me, so he sent me flowers and surprised me because nobody else bothered to send me flowers.
Q. Did you ask anybody why you didn't get flowers?
A. No. But people would come around and ask me, you know, "I can't believe," you know, they knew how Clydine was very kind of devious sometimes. They'd say, "I can't believe she did that. That was really mean." And I remember people around the office would come by and say, "I cannot believe you did not get flowers. That is so cruel and so cold."
Q. Who is responsible for giving flowers out?
A. Clydine Pennington.
Q. Do you believe as you sit here today under oath that the reason you did not get flowers on Secretary's Day is because you would not engage in sex with Governor Clinton in May of 1991?
A. I believe that has something to do with it, yes.
Q. And what is the basis for – what are the facts on which you base that belief?
A. Because Bill Clinton said that him and Dave Herrington were really good friends and Dave Herrington, he said that he had appointed him to that position. And Clydine and – Dave Herrington was Clydine's ultimate boss.
Q. Other than Secretary's Day, did any of the employees ever get flowers or little gifts on other occasions?
A. I think it was just Secretary's Day or maybe a birthday or something.
Q. Did you ever get any birthday presents or gifts of any kind while you worked at AIDC?
A. No. I don't recall at this moment.
Q. You did have that going-away party, though, didn't you?
A. I think it was a going-away party. I may be thinking about my maternity leave party.
Q. But you had a party?
A. Yes. It wasn't a party. It was a get-together.
Q. Did anybody – did Governor Clinton or anyone else at AIDC ever tell you that you had to submit to sexual advances of the governor in order to receive a job benefit?
A. No.
Q. Did anybody – did the governor or anyone else tell you that the governor would use his relationship with David Herrington to penalize you? Did anybody ever say that to you?
A. No. But nobody would say that.
Q. Did the governor or anyone else tell you that your refusal to submit to sexual advances would cause you to lose your job or have a negative effect on your job?
A. No.
Q. Did anybody tell you – the governor – did the governor tell you or anybody tell you that he would use his relationship with Herrington to have you demoted or reduced in salary in any way?
A. Yeah, he kind of made that statement. Clinton did.
Q. What exactly was the statement he made?
A. Well, when the incident happened in the hotel room, he reminded me that Dave Herrington was his good friend. If I had any trouble, have Dave Herrington call me immediately. I mean, how else would I take that? Why would he even mention it if he wasn't trying to make a point?
Q. All right. Well, my question to you, though, was whether Governor Clinton or anyone else ever said that he would use the relationship with David Herrington to have you fired or demoted or –
A. Not in those words. Not in those words. But you can read between the lines, you know.
Q. And that's what you're doing, you're reading between the lines?
A. Well, because I know what he meant.
Q. The fact of the matter is, Mrs. Jones, is following May 8th, 1991, you were not demoted or reduced in salary, were you?
MR. CAMPBELL: Objection. Asked and answered.
BY MR. BENNETT:
Q. What's your answer?
A. Yeah. After I come back from maternity leave, yes.
Q. You didn't lose salary, did you?
A. But I was demoted. I might have kept the salary, but I was demoted.
Q. You believe your employment records, which you have not looked at, show you were demoted; is that correct?
A. I don't know how they did it. I just know I was demoted. Everybody in the building probably knows I was demoted.
Q. All right. Now do you know of any women at AIDC who benefited in their jobs because they were having sex with Governor Clinton?
A. No, not to my knowledge.
Q. Do you know any woman who got a raise or a job or a benefit of any kind because they were having sex with Governor Clinton?
A. Are you –
MR. CAMPBELL: Objection. Overbroad and global as to "any women."
BY MR. BENNETT:
Q. Any of the women that you worked with.
A. Are you talking about just within AIDC? Or other –
Q. Within AIDC, yes.
A. Oh, not within AIDC, no, I don't know of any.
Q. All right. Now let's go outside of AIDC. Do you know anybody who got a job because they were having sex with President Clinton – then-Governor Clinton?
A. Yes. From what I have been told.
(Lines 12 to 22 on page 77 are missing)
Q. Where did you get that information?
MR. CAMPBELL: Objection to the extent that – if you have to answer that question in a fashion that would reveal confidential communications with your counsel, I instruct you not to answer that.
BY MR. BENNETT:
Q. Other than learning that from your lawyers, you never heard that before, did you?
A. Correct.
Q. What's your answer?
A. Correct.
Q. Anybody else? Any other women?
MR. CAMPBELL: Objection. Overbroad and global.
MR. BENNETT: Do you want to take a break?
MR. CAMPBELL: That would be great.
(Off the record.)
|
|
BY MR. BENNETT:
Q. Mrs. Jones, on May 8th, 1991, you went to a room in the Excelsior Hotel where you met Governor Clinton; is that correct?
A. That's correct.
Q. And how long were you in the room total?
A. Between 10 and probably 15 minutes.
Q. And did you voluntarily go up to the room?
A. With the guidance of a state trooper, yes.
Q. And why did you go up to the room?
A. Because I wanted to meet the governor and he wanted – he asked to meet me.
Q. And why did you want to meet the governor?
A. Because it was exciting. I had never met the governor before. It's exciting. So I was going to go up there.
Q. And I believe you've stated publicly that you thought maybe it would help you get a better job; is that right?
A. That's correct.
Q. How long were you in the room before you first saw the governor's exposed penis?
A. Probably about five – between five and six or seven minutes.
Q. And how far were you away from the governor?
A. He sat down right beside me.
Q. So you were just a couple of feet away?
A. Not even that far, I don't think. He sat right down nearly on top of me.
Q. So he exposed himself while he was down on the seat with you; is that right?
A. As he was sitting down, he pulled his pants down.
Q. Oh, so you saw him pull his pants down?
A. As he sitting down, I mean, it was real quick.
Q. And he pulled his pants all the way down to his ankles?
A. I know I saw his legs, so I think either to his knees or his ankles. I don't know.
Q. Well, was his penis coming through his shorts or did he take his shorts off?
A. He took his whole pants off. He was naked from here to
(Pages 80 to 82 are missing)
... the governor's penis went into his body? Did you look at the whole penis?
A. I just – no. I didn't get down there and examine it, but you could see what I saw from across the room. Standing completely across the room.
Q. How long would you say you looked at the penis?
A. Five seconds.
Q. Did he have his hands on it?
A. Yes.
Q. Did you ever see him without his hands on it?
MR. CAMPBELL: Objection. Overbroad and global as to time.
BY MR. BENNETT:
Q. Did you ever see him –
A. No. I believe he had his hands on it most of the time.
Q. And one hand or two hands?
A. I think – it seems like maybe, he put his hand over there to me to try to pull me to touch it or something, but I jumped up, so he didn't have time to even get me. So – but he had his hands on it most of the time, either one or two.
Q. Do you remember ever seeing his penis without his hands on it?
A. Yeah. I saw it. Because when he pulled his pants down, I saw it without his hands on it and I saw what it looked like.
Q. And then his – one or two hands were on it?
A. Yeah. Because he pulled his pants down with both hands and when he sat back, I mean, it's there and then he starts putting his hands all over it.
Q. All right. And what was he doing?
A. He was fondling himself.
Q. Did he have an erection?
A. Yes, he did.
(Page 84, lines 9 to 25, Pages 85 to 92, and Page 93, lines 1 to 9, are missing)
Q. Now how long was it that you said you were in the room before you saw the exposed penis of the president – of the governor?
A. Five or six minutes. Five to seven minutes.
Q. What did you do as soon as you saw that?
A. I jumped up and I said, "I'm not that kind of girl," after I looked at it and he was trying to grab me. But, I mean, I went on ahead and jumped up and I turned around and that's when I – that's the thing I drew there from this perspective of standing up, looking down on the couch at him.
Q. So you didn't see it before you stood up?
A. Yes. I looked at it. It was pointing my direction. But when I stood up, it was pointed to the left.
Q. So then –
A. So.
Q. You stayed in the room for another five or 10 minutes?
A. Oh, no. I started to leave. And he pulled up and I was fixing to go out and I said, "I've got to be going. I've got to go back to the registration desk. I'm going to get in trouble." He pulled up, you know, stood up. And he was just red as he could be. You could tell I had embarrassed him so bad, because he probably expected me to do something. And he pulled up his pants, trying to situate himself. And I don't think he tucked in his pants. He just pulled them up and zipped his pants up, still with an erect penis.
And he said, "Well, you know, if you have any trouble, I want you to have Dave Herrington call me immediately." And that was the second time he had mentioned Dave Herrington. And then I proceeded to go on to the door and he rushed up behind me. I started to open up the door, he put his hand on the door to where I could not open it up any further, and he stopped me and he says, "You're a smart girl, let's keep this between ourselves." And when I went out the door, the state trooper was there, which is Trooper Ferguson. And he was standing out there.
Q. Are you saying that the governor did not let you go out the door?
A. Not for a split second, yeah. He confined me for a moment to let me know that I'm a smart girl and let's just keep this between ourselves.
Q. And the governor had his hand on –
A. On the door. When I opened the door, he stopped it, the back of the door, long enough to let me know what he wanted to tell me.
Q. Now have you ever said that before?
A. Yes, I have.
MR. CAMPBELL: Whoa, whoa, objection.
THE WITNESS: I'm sorry.
MR. BENNETT: Could I finish the question?
MR. CAMPBELL: Surely.
BY MR. BENNETT:
Q. In any of the many press conferences you gave, did you say that before?
A. I don't recall if I have or not.
Q. Did he let you go out the door?
A. Yes. After he told me what he told me.
Q. And what did you understand him to have meant by that?
A. Well, he was threatening me. He said, "You're a smart girl. Let's keep this between ourselves." Apparently he didn't want this to get out.
Q. Did you stay – how long did you stay in the room after you saw the exposed penis?
A. Minute and a half or something like that maybe. Because it took about two or three minutes to even just get back down to where my registration desk was because it's a big hotel.
Q. No. I mean, outside the door of the room.
A. How long did I stay –
MR. CAMPBELL: Objection. Vague.
BY MR. BENNETT:
Q. How long after you saw the exposed penis, how much longer did you stay in the room before leaving the room after you saw the exposed penis? Did you leave right away? Did you hang around for a couple of minutes?
A. No, I did not hang around. He told me – I was there long enough where he pulled his pants up. This couldn't have been 30 or 40 seconds or maybe a minute and he told me about Dave Herrington, if I have any trouble have him call, and then when I got to the door, he stopped the door long enough – I don't know how long it took to do that – but he stopped the door to tell me, "You're a smart girl. Let's keep this between ourselves." And then I left the room.
Q. And Ferguson was right outside the door?
A. Yes, he was.
Q. Was he blocking the door?
A. No.
Q. Was the door locked when you went out?
A. No. I don't believe it was.
Q. Was the door locked when you went in?
A. No. The door was ajar when I went in. It was cracked open.
Q. And how did you get out the door? Did you just turn the handle and walk out the door?
A. Yeah. After he tried to hold me in there for a few minutes.
Q. Now you say he tried to hold you in there for –
A. Well, he held the door –
Q. Let me finish.
A. – for a few seconds.
Q. Are you saying that he tried to hold you in that room for a few minutes? Is that what you're saying?
A. I'll redo that. A few seconds. Long enough to tell me what he wanted to say to me.
Q. Did you express to him in the room that you were concerned about being away from your desk?
A. Yes.
Q. What did you say?
MR. CAMPBELL: Objection. Asked and answered.
BY MR. BENNETT:
Q. Go ahead.
A. After, you know, when I said I had to be leaving, I said, "I'm going to get in trouble. I need to go back down to my registration desk." I had to find something to try to get away from him.
Q. Is that when he said, "If you have any trouble" –
A. Have Dave Herrington, he would take care of it for me.
Q. And you interpreted that as a threat?
A. I interpreted that as that he's the governor and he can do what he wants to and he's got the power to do and if I got in trouble to have Dave Herrington, his good friend, call him and he'll just take care of it, if I got in trouble by my immediate supervisors where I was working at the hotel that day.
Q. So in other words, you interpreted it as a threat rather than as his saying, "If you get in trouble with your bosses, I'll help you out?"
A. Right.
Q. And what did you say, if anything, to Mr. Ferguson, Trooper Ferguson, when you left?
A. I didn't say anything to Mr. Ferguson. He was sitting down, as I recall, on a bench or a chair that had been put out there, waiting for, I guess, Bill to do his thing and when I walked past him, he looked up and give me a smirk.
Q. Was he right outside the door?
A. Oh, just a few feet away maybe. He was there guarding. Absolutely.
Q. Well, was he sitting down?
A. I think he was sitting down, yes. He was sitting down.
Q. And how far away from the door was he?
A. I don't know. A few feet maybe.
Q. And you had no conversation with him at all?
A. No. He looked at – he looked at me, looked up at me
(Pages 99 to 100 are missing)
A. Okay. He come over to – the first time he come over to say anything to me and Pam Blackard was when Clinton was in the ballroom speaking and he come over just to chat or something and he said that he was the governor's bodyguard and I think he said what his name was. And we said, "Oh, do you have a gun?" Because he was in plain clothes and we wanted to know. He said yeah. So I think Pam said, "Well, let's see your gun" or whatever. And he pulled back his coat and he showed us his gun that he was carrying. And then I think he kind of walked away and it just some small chat or whatever. Because he was standing out there by himself. And we were out there.
And then the second time was when he come to hand me a note and tell me that the governor wanted to meet with me and on the note was a four-digit number. I remember looking at it. He said, "The governor" – I don't know if he used the word Bill or the governor – "wants to meet with you in this room number."
I said, "What for? What does he want to meet with me for?" And I was excited, though. You know, but I thought why would he want to meet with me? And I asked him that question as well as I voiced it to Pam.
And he said, "It's okay. We do this all the time."
And so then when – he left – I said, "Well, I'll think about it for a while."
Discussed it with Pam. She said, "Good, maybe we can find a job. You know, maybe we can get a better job." And I'm not stupid, yeah, I was going to go up there and see if I could maybe get another job or find a way to put applications to better myself and to get another job, a higher-paying job. And I thought maybe I could help my friend out and stuff. And I was excited to meet the governor. So Pam said, "Now you go up there, I'm going to watch the desk and everything, but don't stay too long." That's why I know I was not up there longer than maybe, you know, 10 minutes at the most, up in the room itself, because Pam didn't want me to be gone very long either because she didn't want to get in trouble and have to explain to somebody where I was.
That was the conversation that me and Ferguson had had. And then when he come back to see if I was going to go up there and then me and Pam had decided, yeah, I'll go up there and then me and Pam had decided, yeah, I'll go up there. So then he escorted me up and around the corner and up the elevator.
Q. Now did you tell anybody downstairs why you were leaving the desk? Did you give any excuses to anyone –
A. I didn't.
Q. – as to why you were leaving the desk?
A. Un-uh. I didn't talk to anybody about where I was going or what, except for Pam.
Q. Do you know whether Pam did?
(Page 103 is missing)
A. Yeah, He seemed like he was unloosening his tie as soon as I – you know, he come to the door and opened it because it was already ajar and I knocked on the door facing and he opened up the door and it seemed like he was loosening his tie with one hand and he acted like he had known me for years. You know. Right off the bat. And I had never met the guy in my life. And he shook my hand. And he introduced hisself or whatever.
Q. How did he introduce himself?
A. "I'm Bill Clinton." I think it was that. I don't think he said, "I'm the Governor." "I'm Bill Clinton."
Q. And then what happened?
A. "Nice to meet you" or whatever. And then we proceeded to – I proceeded to go on in. And went –
Q. Did you say something to him when he said, "Hi. I'm Bill Clinton"?
A. I said, "I'm Paula Corbin" or whatever.
Q. Okay.
A. And I think he had said something about – he asked me where I was worked and I told him I was over at AIDC and he said that he knew – Dave Herrington was a good friend of his and he had appointed him to that job. And then when we went in, oh, a couple of minutes, we went over by the window and I remember looking out the window because there's a pretty view up there, because it was really high up. And that's when he ... made his first pass at me at the window.
Q. Okay. Tell me exactly what he did.
A. He sat down on the windowsill, leaned up against it with his bottom. And I was standing in front of him just talking because I was the one looking out the window. And he proceeded to – he just reached right over while we were talking and we were just talking in general and I don't know what exactly everything we were talking about but nothing sexual. And –
Q. Do you remember anything you were talking about?
A. I think we were talking about the job or whatever and about working with the state or something. I really don't know exactly, but it wasn't nothing bad that we were talking about. Because what was so shocking to me I'm sitting here talking to this man but nothing related to what's on his mind and he's over here while he's answering my questions pulling me over like he has done this a million times and grabs me and pulls me over to him to the windowsill and tries to kiss me and just didn't ask me or nothing. And I was just really shocked. And I pulled away. That was the first time I pulled away. I said, "No." I said, "What are you doing?"
Q. Now he was still –
A. I was so scared and nervous.
Q. Was his back to the window?
A. Yes.
Q. So why didn't you just go right out the door?
A. You know what? This is the governor we're talking about. I had just met the man. A state trooper sitting outside the door with a gun. I know that. I'm terrified. And so what I'm thinking next is what was happening here and what am I going to do next to get out of the room? Is he going to stop here? I didn't know but that would be it. But the man kept on and on until he dropped his pants. That's why I didn't run out the door. I was scared.
Q. After he made a pass at you, you didn't go right out the door, did you?
A. No. Because the state trooper was out there and I knew he was out there. And I did not know but what they were taping and had him out there to – all kinds of stuff was going through my mind. Because I'm thinking, this is not happening to me. This cannot be happening to me. And I thought if I run out that door, he's going to catch me, because Bill will know I'm fixing to run tell somebody. I'm not that stupid. I was not going to run out the door. I was scared to death.
Q. So instead of running out the door, what did you do?
A. I just moved away from him and got completely away from him. He was still sitting on the windowsill.
Q. All right. Then what happened?
A. And I went way over like to the middle of the living area. And I was talking to him about Hillary. I mean, I was just kind of trying to ignore what he had just done. And I was talking to him about Hillary and she was working with children's things or something, children's schools at the time, and I remember I was complimenting her on how she was really good with children. And the next, you know –
Q. Then what happened?
A. I was – he come over by the wingback chair close to where I was at. Then it's like he wasn't even paying attention to what I was saying to him. Then he goes, "Oh, I love the way your hair flows down your back. And I was watching you," and stuff like that. Downstairs. And then he did it again. Then he started – he pulled me over to him while he was leaning up against the wingback chair and he took his hands and was running them up my culottes. And they were long. They were down to my knees. They were long, dressy culottes. And he had his hand up, going up to my middle pelvic area, and he was kissing me on the neck, you know, and trying to kiss me on the lips and I wouldn't let him. And then I backed back. I said, "Stop it. You know. I'm not this kind of girl." I mean. And it still – and then I ran right over to where the couch was. I thought what am I going to do? I was trying to collect my thoughts. I did not know what to do. After the second time – after the first time, I had rebuffed him. And then when I got over there and I kind of sat right there by the end of the couch on the – seemed like on the armchair part. And the next thing you know it, I turn around because he was kind of back over here, and he come over there, pulled his pants down, sat down and asked me to perform oral sex.
Q. What did he say exactly?
A. He asked me would I kiss it. He goes – you know, I can see the look on his face right now. He asked me, "Would you kiss it for me?" I mean it was disgusting.
Q. Were those the actual words he used?
A. Yes.
Q. He didn't use other words?
A. I think that was it.
Q. Okay. What did you say?
A. I said, "No. I'm not that kind of girl." And that's when I said, "I'm going to get in trouble. I've got to be going. I've got to get back to my registration desk." And then he said – then he was – you know, you could tell he was embarrassed and everything. And he was pulling up his pants. And he said, "Well, if you have any trouble, you have Dave Herrington call me immediately." And you could tell he was so embarrassed because of what he had just done, because I had rejected him.
Q. All right. Now then you went downstairs and you told Pam part of this story; is that right?
(Pages 109 to 119 are missing)
A. He wanted me to do something against my will.
Q. That's not my question. Did he require you to do something against your will?
A. Well, he tried to kiss me against my will. Is that what you're saying? I'm not quite sure.
Q. You said when he –
A. Absolutely, but he still wanted me to do it. Three times he tried to make me do it against my will. I would say so after the first time of rejection, yes, he did.
Q. Did he make you kiss his penis?
A. No.
Q. Did you kiss his penis?
A. No.
Q. All right. What other damages or injuries did you sustain?
A. He threatened me about – when I opened the door, he held his hand up there and said, "You're a smart girl. Let's keep this between ourselves." That's a threat. He don't want me to tell anybody.
Q. Okay. What else?
A. He told me about his boss – my boss, ultimate boss was his dear friend and to me – it seemed to me that if anything – if I was going to get in trouble for anything whatsoever for being up there, his boss could have took care of it one way or the other, either got me fired or helped – helped me not get in trouble for being away from the registration desk. That was a threat.
Q. Okay.
A. That was intimidation.
Q. What other injuries?
A. Just psychological of him dropping his pants and doing what he did. I mean there was a few minutes of conversation and the man dropping his pants. That's mentally abusive and I felt shame. I felt like I was the bad person after I left that room. I thought I was the bad person here and I was the one that was at fault for going up there and I would have never thought that – I would have never expected that. I didn't expect to go up there with sex on my mind, but intentionally, he had that on his mind apparently or he would have never wanted to see me.
Q. What psychological damage did you sustain? Could you be more specific?
A. Absolutely. I mean I was horrified. I was – I was scared to death. I would have to think about that. Every time I look at this man on TV – I don't even look. I just turn it off because it brings back that terrible day of when I had to look at his private parts, a strange man without me asking for it.
Q. All right. Now, have you ever consulted a psychiatrist for this?
A. No.
Q. Have you ever consulted a psychologist about this?
A. No.
Q. Have you ever had any medical bills as a result of this?
A. No.
Q. Has this affected your marriage?
MR. CAMPBELL: Well, I will object to the extent that that would cause you to violate the husband/wife privilege. I will instruct you not to answer as to any private communications, verbal or non-verbal, between you and your husband.
BY MR. BENNETT:
Q. Are you making any claims in this case that either Danny Ferguson or Governor Clinton are responsible for any damages as it may relate to your marriage?
A. No
Q. Do you take medication?
A. No.
Q. Have you ever taken any medication because of this?
A. No.
Q. Have you ever had any psychiatric treatment –
A. No.
Q. – for any reason?
A. I'm sorry. No.
Q. Have you ever had any prior incidences in your life which have caused you emotional distress such as molestation or incest or date rape?
A. No.
Q. After the alleged incident, you never took any time off work because of it, did you?
A. No.
Q. Never had any physical ailments because of it, did you?
A. Mentally, yes, thinking about it and when I would see the man on TV and then when he got reelected for President and I just couldn't understand how America could vote a man in for president, but they did not know what he did to me and I thought if they only knew what I know he's done and he's the President of the United States.
Yeah, it caused emotional pain and stress, but I didn't want to go tell anybody about it because I just wanted to let it go away. I wanted to keep it a secret and not let anybody know about it.
Q. Do you still have this emotional distress?
A. Absolutely. Every time I see that man on TV.
Q. Every time you talk about this incident or think about this incident, it causes you stress –
A. Emotional.
Q. – is that correct?
(Pages 124 to 225 are missing)
...he's an actual police officer and whether he has a gun and that Pam wanted to see the gun; is that right?
A. That's correct.
Q. Was it Pam who asked to see his gun or was that you?
A. I think it was her that asked, but I'm not for sure.
Q. And he did open his coat in response to that banter and show that he had a gun; is that correct?
A. Yeah. Well, I don't know if we asked – I don't know if she asked him to show it or he said yeah and he just pulled back his coat and showed it to us.
Q. Did you in any way take this to be intimidating or threatening or coercive in any fashion?
A. Not at that point, no.
Q. So this is just light banter between – all the convention delegates are in the hall listening to the Governor speak and you and Pam are outside and I guess the only other person outside is Danny Ferguson. Is that your recollection?
A. Yes.
Q. Okay. So he's being friendly with you and you and Pam are being friendly with him?
A. Right.
Q. Okay. Now, how many minutes do you recall this conversation taking place?
A. Five minutes or something because he wouldn't stay there the whole time.
Q. In the – in the context of this conversation with a man that you know to be Governor Clinton's bodyguard, did you make any statements about you would like to meet the Governor or had you hoped to see that Governor? Did you say something to that effect?
A. No.
Q. Did Mr. Ferguson say anything to you in this five-minute conversation about whether or not you would like to meet the Governor?
A. Not at that conversation, he didn't.
Q. Okay. All right. So in that five-minute conversation, nothing has – nothing is said about you meeting him or him – him wanting to meet you, talking about Governor Clinton; is that correct?
A. Oh, I don't think so, not in that portion of it.
Q. All right. Then how much time went by from this five-minute conversation until you saw State Trooper Ferguson again?
A. I don't know. It could have been an hour. It was awhile.
Q. Could it have been as little as 30 minutes?
A. Yes. I really don't know. It was awhile though. I mean he didn't just hang around the whole time.
Q. Okay. It could have been as little as 30 minutes.
(Pages 228 to 235 are missing)
Q. Now, you say that he reached and pulled you to him. What part of your body did he place his hands on?
A. He pulled my hands up to – to pull me up to him.
Q. All right. Now, did he in any way hurt your hands when he did that?
MR. CAMPBELL: Objection, asked and answered.
THE WITNESS: No.
BY MR. BRISTOW:
Q. Now, did he try – when he pulled your hands toward him, did he try to kiss you at that time?
A. He was just trying to hug up to me at that point and I said, "What are you doing?"
Q. Okay. And what did he say?
MR. CAMPBELL: Objection, asked and answered.
THE WITNESS: I don't think he even answered me.
BY MR. BRISTOW:
Q. Then what did you do?
MR. CAMPBELL: Objection, asked and answered.
THE WITNESS: I proceeded to walk over to where – oh, between the chairs and the couch, you know, closer to the end of the door, over in the middle of the living room and he walked over there towards me and he leaned up against the back of a wingback chair and then he started proceeding to tell me how he liked the way my curves and my hair was down my back and then that's when he pulled me up again. He was trying to run his hand up to the middle of my, you know, my pelvic area and he was trying – he was kissing me on the neck and started to kiss me on the lips and I just – I said, now, "what are you doing? Stop it. I'm not that kind of girl" or whatever. I said –
BY MR. BRISTOW:
Q. How many times did you tell him that you were not that kind of girl?
A. I think I said that twice.
Q. And what provoked your saying that twice?
A. Well, I wasn't that kind of girl to do that with a strange man that I just met within five minutes.
Q. Well, what did you – what did he do that caused you to say you were not that kind of girl? You say that – you say that he put his hands up your culottes?
A. Uh-huh.
Q. What did he touch when he –
A. He was trying to touch my private area.
Q. Well, did he do that?
A. Well, he was on his way to trying. If I hadn't have stopped him, he would have.
Q. And that's when you said that you were not that kind of girl?
A. Absolutely.
Q. Now, what else did he do when you said the second time that you were not that kind of girl?
MR. CAMPBELL: Objection, asked and answered.
BY MR. BRISTOW:
Q. Go ahead.
A. When he exposed himself to me and I got up off the couch, off the end of the couch and I said, "I'm not that kind of girl. I've got to be going."
Q. Okay. And you said that at that point in time that you were only able to be away a short time, is that right; you might get in trouble at work –
A. Right.
Q. – if you didn't go?
A. Right.
Q. And at that point in response to that, what did he say?
MR. CAMPBELL: Objection, asked and answered.
THE WITNESS: Well, he said – he said, "Dave Herrington is a good friend of mine" or whatever he said. "If you have any trouble, have your boss, Dave Herrington, call me immediately."
BY MR. BRISTOW:
Q. Okay. Now, at any point while you were in the room, did he say – did Mr. Clinton say anything about Danny Ferguson?
A. I don't recall, no.
Q. Did you say anything about Danny Ferguson while you were in the room?
A. No.
Q. Now, you say that when you left the room that you saw Mr. Ferguson and did not have any conversation with him?
A. That's correct.
Q. And then you came back downstairs and you finished – finished up your shift?
A. That's right.
Q. If the personnel records at AIDC indicate that you worked on Thursday and Friday and all the following week, you would not dispute that, would you?
A. No.
MR. CAMPBELL: Objection. No foundation, misstates the evidence in the record, no evidence in the record.
By MR. BRISTOW:
Q. And go ahead.
A. That's correct.
Q. You would not dispute that if that's what the record showed?
A. No.
MR. CAMPBELL: Same objections.
THE WITNESS: No.
|
|
BY MR. BRISTOW:
Q. Now, in addition, when you went back to work, you continued to run the rounds as a courier which took you to the Governor's office; is that correct?
A. That's correct.
Q. Okay, And in fact, continued on a daily basis to go to the Governor's office; is that correct?
A. Yes.
Q. Now, when is the next time after the incident at the Excelsior that you spoke with Governor Clinton?
A. After the incident at the hotel?
Q. Yes.
A. Let me get which one come first. I think it was – it was when I was walking through the state capitol. I was on my way to the treasurer's office and to deliver or pick up some checks, payroll checks because that was my job too and they were – Trooper Patterson and Clinton were walking up to the front of the state capitol and I was walking – the rotunda is round, so I was walking this direction. They were coming up on the opposite side and he would have came, you know, back this way to go to the Governor's office. Instead, he hollered my name out and diverted and come back around this way and hugged me, put me in a full brace hug. And I don't think I hugged him back and then –
Q. Now, at that point in time, did you know who Trooper Patterson was?
A. No.
Q. So what you remember about this incident is that the Governor was accompanied by a trooper, correct?
A. I knew his name was Roger.
Q. Well, the trooper's name was Roger; is that right?
A. Yes.
Q. All right.
A. I mean – I'm sorry – Larry. I get them confused.
Q. Well –
A. I'm sorry.
Q. Okay.
A. Larry.
Q. So all you really know is that the Governor had a trooper with him and you did not know the name of the trooper?
A. Well –
MR. CAMPBELL: Objection, misstates prior testimony.
BY MR. BRISTOW:
Q. And you can go ahead. Isn't that – at the time it occurred, going back to the time the incident in the rotunda occurred, at that point in time, you did not know who the trooper was, did you?
Mr. CAMPBELL: Objection, Misstates prior testimony.
BY MR. BRISTOW:
Q. Go ahead.
A. I knew who he was because Clinton looked at him and said, "Hey, Larry, don't we make a good looking couple?" So I knew what his first name was. I didn't know what his last name was though.
Q. And you had never met that trooper before that occurrence?
A. That's right.
Q. All right. Now, what else did Governor Clinton say other than "hey, Larry, don't we make a good couple?"
A. He said, "Hey, Larry, don't we make a good looking couple?" And he was hugging me side to side then and then he said, "We look like beauty and the beast." And I didn't know what to say. I looked up at him and I said, "You just don't – you don't look like the beast." That was the only comment I made – I made and I think Larry, he smiled or something.
Q. Okay. And you said you don't know – you remember him hugging you, but you don't know whether that you may have hugged him back?
A. I don't think I did.
Q. But you don't know one way or the other?
A. No, I don't believe I did.
Q. Okay, And everybody is smiling about this. Larry is smiling, the Governor is smiling and you were smiling; is that correct?
A. I don't know if everybody was smiling or not.
Q. Well, when you made the statement "you don't look like the beast," you were smiling about that. It was all in a light vein; isn't that right?
A. Yeah, probably, but I wasn't, you know, smiling real big or laughing or anything.
Q. Okay. And then the Governor and Patterson walked off and you went on about your rounds; is that correct?
A. Oh, well, Clinton made a point to tell me how he thought I looked that day.
Q. What did he say?
A. He said I looked really nice and he liked what I had on.
Q. Okay. Anything else was said that day?
A. And I think that was it.
Q. Okay. All right. And what did you say when he told you that he thought you looked very nice and he liked what you had on? Did you say thank you?
A. I don't know if I did or not. I could have said thank you, but I don't recall saying anything to him back.
Q. But you may have thanked him and been polite?
A. I may have.
Q. Okay. Now, what is the next incident when you personally saw the Governor?
A. Now, I don't know what time – point in time this was, but one instance, I was in the Governor's office like I did every day. I would go there twice a day and sometimes I would have to wait. That was my job to wait, have documents signed by whoever was in the Governor's office and I was sitting in there one day right in a chair like this right at the door and there was windows right here, right at the door and I was probably chatting with Carole Phillips. We talked a lot and there was some bright lights coming and we looked behind and that was – he was coming up there, Clinton was, and when he – as soon as he walked in the door – and this is probably on film somewhere. As soon as he walked in that door, he patted me on the thing. He said, "How are you doing, Paula?" He remembered my name again and that's on film somewhere.
Q. Okay. Now, what did you say?
A. I don't think I said anything or I may have said hi, but that's it.
Q. All right.
A. He acknowledged me and everything.
Q. And anything else that was said?
A. No.
Q. Okay. And did he do anything unfriendly or intimidating when he acknowledged you? I mean you say he was being filmed.
A. Not in the front of the cameras, I doubt if he would do that.
Q. So when he patted you on the shoulder and said "How are you doing, Paula –"
A. Uh-huh.
Q. – he did that in a friendly fashion, correct?
A. Yeah.
Q. And you responded in a friendly fashion. Correct?
A. I guess.
Mr. Campbell: Objection, misstates prior testimony.
BY MR. BRISTOW:
Q. Go ahead.
A. I don't know how I responded. I don't know if I said anything. I may have just looked at him.
Q. Okay. You don't recall how you may have responded?
A. Huh-uh, no, I don't.
Q. By the way, what was the outfit you were wearing when he said you looked nice when you were in the presence of Roger Patterson – Larry Patterson, do you remember?
A. Yeah. I think it was an Easter outfit I had. It was a white, like a long cullote thing. Those were in style then and it was made out of like a silk type material. It was a dressy outfit. It was long, about down to my knees.
Q. Okay.
A. Had a big wide belt around it.
Q. When you wore that outfit, was it unusual for you to receive compliments that you looked good in that outfit?
A. I don't remember anybody really said anything.
Q. You don't remember one way or the other?
A. Huh-uh.
Q. Okay. All right. Tell me about any other incidences in which you met Governor Clinton.
A. That was it.
Q. All right. Now, let's go back from the day at the Excelsior Hotel. Tell me about the next time that you saw Danny Ferguson.
A. After I left the hotel room, he was sitting out there and he looked up with a smirk on his face. I went down to the elevator. I did not see him any more that day at all whatsoever. I left and the next time I saw him was – it seemed like it was quite awhile, a few months or something.
I was over at the Governor's office and he was not sitting in the Governor's office and usually he doesn't sit out there. I think they sit in the back. And I was sitting there and I left – when I went to leave, I heard somebody holler my name and he rushed out and it was Ferguson and he said, "The Governor wanted me to ask you if he could get your phone number because Hillary is out of town a lot and he would maybe like to meet with you." And I told him no, that I was living with my boyfriend and I did not mention his name and he responded by saying, "well, how is Steve doing" and I did not tell him who he was.
Q. Okay. Anything else that was said in that conversation?
A. No. I think that was it.
Q. Okay. When is the next time that you saw Danny Ferguson?
(Pages 248 to 260 are missing)
... and Clinton makes him do it and –
Q. But you said the case –
MR. CAMPBELL: Counsel, it's after 5:00 now
MR. BRISTOW: Just about two or three minutes will be a good breaking point.
BY MR. BRISTOW:
Q. You said that the reason that you sued Mr. Ferguson was because he had lied about you, but – and that that had hurt your reputation; is that right?
A. Right.
Q. Were you not aware that there has been a motion filed in this case to take your reputation out of it, to take away anything about your defamation or reputation? Are you aware of that?
MR. CAMPBELL: Objection, misstates the motion at issue, misstates the evidence in the record and no foundation.
BY MR. BRISTOW:
Q. Isn't it true that a motion has been filed to take away the reputation issue and to drop the defamation claim against Mr. Ferguson?
MR. CAMPBELL: Same objections.
THE WITNESS: Yes.
BY MR. BRISTOW: Was that filed with your permission and your consent?
A. It was filed, but I didn't really care if it was dropped or not personally.
Q. Well, if you don't care about whether you are suing Mr. Ferguson for defamation or not, why are you suing Mr. Ferguson? Why do I have to be here? Why does Mr. Ferguson have to be in this lawsuit? What is it you're wanting from Mr. Ferguson?
MR. CAMPBELL: Objection, multifarious. That's about four questions. Also, objection, asked and answered. She already told you, counsel, she was suing him for his conspiracy.
BY MR. BRISTOW:
Q. If you are willing to drop the defamation count as your lawyers have represented to the federal judge, why are you suing my client, Danny Ferguson, at this point in time?
MR. CAMPBELL: Same objections, asked and answered.
BY MR. BRISTOW:
Q. Go ahead.
A. Because he did escort me up there knowing full well why. He said he did it all the time. So he knew exactly what was going to take place. Him and Bill Clinton apparently conspired together to get me up there and tell
(Pages 263 to 299 are missing)
A. I think so. I don't recall.
Q. Now I want to ask you about some facts and I want to – I want you to tell me every fact that you have that you think supports these allegations. And generally it is my understanding that you believe that Governor Clinton and Danny Ferguson or Danny Ferguson that you were, I think – I think that you believe that you were stalked, that you were under surveillance, that you were investigated, that you were harassed. Am I correct that you are making those allegations against Mr. Clinton and Mr. Ferguson?
A. That's the way I felt personally.
Q. Okay. Now what I want you to do is tell me the facts that you are aware of to indicate that you were under some sort of surveillance.
A. Okay. Well, first of all, Ferguson said – he asked me how Steve was doing. I never told him Steve's name. That was the incident in the state Capitol. And apparently he knew who he was. And I didn't tell him. And we weren't married at that point. So I don't know how he found out who my boyfriend was. So apparently somebody had looked into something to –
Q. All right. Now that is an assumption you are making; is that correct?
A. Yes. But you're asking me what assumptions do I have that would make me think that. Now that is an assumption that I have that would make me believe that somebody knew something because nobody knew who Steve's name was and surely he wouldn't –
Q. Okay. Well now, a fact is something you have seen or something you have heard. And so you have told me a fact, and it's your testimony that Mr. Ferguson asked you how was Steve doing. And I accept that as a fact that you have. Now what other facts do you have that you either saw or heard or someone reported to you to indicate that you were under some fort of surveillance?
A. I don't have any substantial facts, because I really don't. But that's just the way I felt. I know I've been followed in Long Beach, California, by unmarked-looking cars.
Q. Unmarked cars followed you in Long Beach and when did that take place?
A. Well, it was a little bit, oh, probably a year or so ago.
Q. Now are you in any way accusing my client, Mr. Ferguson, of having something to do with that?
A. No. I'm just – yeah. I'm answering your question. If I felt like I was followed or anything.
Q. Okay. Or are you accusing the President of having something to do with unmarked cars following you in Long Beach?
A. Possibly. Well, somebody was following me probably.
(End of Excerpts)