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Excerpts From the Deposition of L.D. Brown

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Related Links
_ Full Coverage: Clinton Accused

_ Full Text of Other Legal Documents

_ Jones Filing Details Sex Allegations (Washington Post, March 14)

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Released on Friday, March 13, 1998

Following are excerpts from the deposition of L.D. Brown, a former Arkansas state trooper, taken on Nov. 10, 1997 at the DoubleTree Hotel in Little Rock.

The text of the deposition was released on March 13 by Paula Jones's lawyers, as part of their response to the Clinton legal team's motion for summary judgement.

Jones's attorneys replaced the names of some women with the name "Jane Doe." Jane Doe 2 is longtime Clinton friend Beth Coulson.

In these excerpts, Ferguson is being questioned by Jones attorney Robert E. Rader. Robert S. Bennett represented President Clinton.

Q. What was the process that you would go through in soliciting women for Bill Clinton?

A. I would talk to them personally, sometimes give them my business card. If they were from out of town, I would find out where they were staying. If we were out of town and/or in town anywhere in Arkansas, I would try to get their telephone number and introduce them subsequently to the Governor.

Q. When you introduced yourself to them, would you just say that you're a member of the Governor's Security Detail and "The governor would like to meet you and talk to you" and that sort of thing? Can you give us a flavor for what you would say?

A. Well, usually it would be a situation where they, again, knew who he was and would see me come in with him, so I would usually say something like that I was his bodyguard or I was his state police officer. So it generally was a situation they knew who he was and saw that I was with him, and then I would give him the business card, as I said, same kind of procedure there.

Q. And you would get information from them about who they were and their phone number and so forth?

A. Right.

Q. Would you then give that to Governor Clinton?

A. Usually.

Q. Well, what would happen from there? I mean, do you have knowledge of Governor Clinton then actually meeting with these women, some of them?

A. Just from him, not any of those kind of solicitations, whatever you want to call it. I don't – one happened in Miami – not Miami, Boca Raton. That was an out-of-town thing.

Q. What was that incident?

A. We were there for a Southern Regional Education board meeting, I believe, and there were governors, as I remember, from around the country, and they were there. The governor was there, I believe, chairing the committee, and a trooper by the name of Ralph Parker and I traveled with the governor. They were going to go on vacation after this conference, and one night after Hillary, Chelsea, and her baby-sitter went to bed, we went out to a club, a disco kind of club, dance club. And I was driving the rental car, as I remember, and we went in the disco and sat down. And there was a table of women across the room from us, young women, and the governor asked me to ask this particular women – to go over and ask this particular woman if she wanted to meet the governor from Arkansas.

And I did, I gave her one of my cards, and again, this out of town as opposed to in-state where people knew who he was. And I think the girl said something, "Right, I'm the Queen of England, too," and someone at the table, which invariably would happen, actually noticed and knew who he was. And they said, "No, no, no. That's really Bill Clinton. I've seen him on television."

A couple of the girls came over, and when it was time to go and pay the bill, the governor got in the car with the girl that I had given the card to, and we followed them to an area that was under development. It was kind of a remote area from this club and pulled over, Ralph and I did. And around in front of them – she stopped, and then we pulled on around in front of them, and they stayed back there in the car for a few minutes. I can't remember how long, but – and then the governor came back and jumped in the backseat and we left and went back to the hotel.

Q. Well, now, the incident you've just described was one of the incidents that you described to The American Spectator. Do you recall that?

A. That's right.

Q. When Bill Clinton got back in the car with you after he left the car where he had been with the woman, what did he say to you about what they had done in there?

A. Well, he indicated in so many words that she had performed oral sex on him. I cleaned it up a little bit.

Q. And were there other instances when you would travel out of town with Bill Clinton and he would ask you to solicit a woman for him, make an approach?

A. Yes.

Q. Do you have any recollection of how many times that occurred? I'm just talking about the out-of-town instances.

A. Out of Little Rock or out of the state?

Q. Let's start with out of state.

A. Gosh, maybe ten of fifteen times out of state.

_     _     _

Q. Well, in your comments to The American Spectator, The American Spectator says that you said you solicited new sexual partners for Clinton throughout the state over a hundred times. Was that a true statement?

A. That's what I estimated it at, but not all of them came to their fruition, if you will, that I know of.

Q. Some of them did, according to what Clinton would tell you?

A. Right.

_     _     _

Q. Did Bill Clinton ever talk to you about where he had had a sexual relationship with Sherry Wright?

A. Not that I recall.

Q. Did you ever take Bill Clinton to the Riviera Apartments and he would go inside to meet someone?

A. I've taken him there, and he's gone inside.

Q. Did he ever say anything to you that suggested to you he was meeting a woman there?

A. Not that I recall.

Q. How about Liz Ward? Have you ever heard the name "Liz Ward?'

A. Yes.

Q. Did Bill Clinton ever say anything to you that he was having a sexual relationship with Liz Ward?

A. Not that I recall.

Q. Do you have any information or knowledge about whether he was having a sexual relationship with Liz Ward?

A. I had heard from someone.

Q. Do you remember who you heard from?

A. No, I don't remember.

Q. Did you ever drive Bill Clinton around – well, let me back up. When you'd ride around with Bill Clinton, was there a limousine that the governor would ride? What kind of car would you travel in?

A. We had an unmarked state police car that we would travel in most times on business, and then we had a Lincoln Town Car that we would drive sometimes, usually at night.

Q. Did you ever go out with Bill Clinton where you were driving in the Lincoln Town Car and he was riding in the car, just the two of you?

A. Yes.

Q. Did you ever pick up any women? Did he ever ask you to stop and pick up a woman or meet a woman under these circumstance?

A. Not that I recall.

Q. Do you know the name "Deborah Mathis?"

A. Yes.

Q. Do you have any knowledge whether Bill Clinton had sexual encounters with Deborah Mathis?

A. I had heard it, but I don't have any personal knowledge.

Q. Do you recall where you heard it?

A. No.

Q. Did you ever see Bill Clinton with Deborah Mathis?

A. I can't remember specifically.

Q. Did you ever take Bill Clinton to meet Deborah Mathis?

A. Not that I remember, not knowingly.

Q. How about the name "Shala" – S-h-a-l-a is the way I have it spelled – "Brummett"? Have you heard that name?

MR. BENNETT: What's the last name?

MR. RADER: B-r-u-m-m-e-t-t, I think.

A. I've heard the name.

Q. Do you have any knowledge about whether Bill Clinton had a sexual relationship with her?

A. I just heard that he did.

Q. Do you recall where you heard it?

A. No.

Q. Was there any evidence of that other than somebody told you that?

A. Not that I have.

Q. Did Bill Clinton ever talk to you about the fact that he had had a sexual – or whether he had had a sexual relationship with her?

A. I can't remember that he did. He may have.

Q. Did Bill Clinton ever say that he had had a sexual relationship with Sherry Wright?

A. Not that I remember.

Q. Did he ever say that he had had a sexual relationship with Liz Ward?

A. Not that I remember.

Q. Or Deborah Mathis?

A. No.

Q. How about the name "Lencola Sullivan"? I'm not certain how you spell that. I understand she was Miss Arkansas at one time.

A. Right.

Q. Do you know that name?

A. Right.

Q. Do you have any knowledge whether Bill Clinton had had a sexual relationship with her?

A. I just heard that he had.

Q. Do you recall where you heard it?

A. No.

Q. Did Bill Clinton ever talk to you about her?

A. Not that I remember.

Q. Did you ever travel to New York City with Bill Clinton?

A. I don't think I ever did.

Q. Now, you mentioned earlier the name "Robyn Dickey". Do you have any knowledge whether Bill Clinton had a sexual encounter or sexual affair with Robyn Dickey?

A. Yes.

Q. What is your knowledge?

A. She told me she had, and she said she was one of the people that came into the mansion under the circumstances outlined earlier. And he – I don't remember the words, but he and I talked about it as well.

Q. So Robyn Dickey and Bill Clinton both made comments to you that they were having a sexual relationship or had had? Is that what you are saying?

A. Right.

Q. How many times did she come to the Governor's Mansion? Do you have any recollection of that?

A. Well, she worked there for part of the time that I was there as the mansion administrator, so she was there almost every day while she worked there. I assume you're talking about the late nights?

Q. Right.

A. Several times. I can't remember exactly how many times.

Q. Did she go – what would she do? Would she go home at the end of the day and then come back late at night?

A. Right.

Q. Were these instances where Bill Clinton would call and tell you that she was coming, or could she get on the grounds without his prior approval?

A. Well, while she was working there, but she came there after she left the employment as well.

Q. After she was no longer employed as the administrator for the mansion, she still came back?

A. Right.

Q. Late at night?

A. Right.

Q. You also mentioned the name "Regina Blakely Hopper." What knowledge, if any, do you have about a sexual relationship between Bill Clinton and Regina Blakely? Or Regina Hopper Blakely I guess is the correct way of saying that.

A. Regina Hopper at the time. She would come to the mansion under those circumstances, not nearly as many times as Robyn did, and I knew Regina. We talked to Regina, and the governor would say something along the same lines as we were talking about earlier.

Q. Let's be specific for the record. Would the governor make comments to you that he was having a sexual relationship with Regina Hopper?

MR. BENNETT: I object to the form. I mean, that's about as leading a question –

Q. I'm just asking you to be as specific as you can about the governor's comments.

A. When he would talk to me about her after she had been there or after she had come to the mansion, in so many words that's what we would talk about would be that he had had sexual relationships with her.

Q. Did she ever say anything to you along the same lines that confirmed that she had had a sexual relationship with Bill Clinton.

A. Yes.

Q. Do you know Regina Hopper's father's name?

A. Bobby Hopper.

Q. Did he had a job with the State of Arkansas?

A. Well, he was appointed to a state highway commission job.

Q. Who appointed him to that position?

A. Governor Clinton.

Q. Do you know the name Jane Doe 4?

A. Yes.

Q. Do you have any knowledge whether she had a sexual relationship with Bill Clinton?

A. Just what some people had told me.

Q. Do you remember who told you that?

A. Larry Paterson, as I remember, told me that.

Q. Do you know Jane Doe 4 personally?

A. She worked at the governor's office while I was there.

Q. Do you know where she is now?

A. I think she work's in the president's office here in Little Rock. I'm not sure of that.

Q. Did Bill Clinton ever say anything to you that he had had a sexual relationship with Jane Doe 4?

A. He may have. I'm not sure.

Q. What was Jane Doe 4 – did she work for the state of Arkansas?

A. I believe she was the assistant scheduling secretary for the governor's office.

Q. Did she travel with the governor when he traveled?

A. She may have. I don't remember her doing that.

Q. Do you have any knowledge of whether Bill Clinton would meet women when he would go out jogging?

A. He told me that he had before, and I picked him up, I believe, here, I'm sure the Excelsior. After he would leave jogging by himself, he would call me and have me come pick him up, and that's, more or less, what he would say.

Q. What would he say?

A. That he had just seen someone, had Hillary called, same kind of questions. "Has Hillary called? Where is she? Let's get back to the mansion."

Q. You say he said that he had just seen someone. Did he say anything that he had had a sexual encounter with them?

A. Not in so many words. Sometimes he would call me again to let me know where he was. Didn't say that. He'd call me and tell me he'd be at the Excelsior for a while, pick him up at such and such a time.

Q. Well, what makes you think, if you do, that he was having sexual encounters in these cases?

A. Because he's give me the room number where he was going to be.

Q. You didn't think this was just some business meeting with somebody with the Arkansas Democratic Party?

A. Not in his jogging shorts. I'm not trying to be flip about it, and, again, we would talk later, and I don't remember – I never saw any women there, if that's what you're asking me.

Q. Well, I'm just asking the basis for your belief that he had had a sexual encounter in these cases.

A. Afterward when I would pick him up, we would talk in generalities about that. He would not come out and say, "I just had sex with some woman, " but –

Q. What kind of things would he say? Can you recall?

A. He would be real concerned about where Hillary was and if she had called. "Do I look like I've been running?" things like that.

_     _     _

Q. During the time that you were on the governor's Security Detail, was there a women who worked for Bill Clinton named Betsey Wright?

A. Yes.

Q. What did she do? What was her job?

A. She was chief of staff I believe the entire – no, not the entire time I was there, but she was chief of staff or a top assistant or aide.

Q. Did you – in addition to trying to keep these meetings and encounters with women from Hillary, did you also try to keep these encounters from Betsey Wright?

A. Yes.

Q. Did Betsey Wright ever ask you whether Bill Clinton had been out to see women or a particular woman?

A. Yes.

Q. What would she ask?

A. Well, of we had been out of town, she'd ask me if we had stayed out of trouble or, particularly, if I had kept him out of trouble, her words. After an event that she either didn't attend or we parted company from, she might ask me the next day if we went over to Jane Doe 2's house, things of that nature.

Q. Did she ever specifically ask you whether Bill Clinton had seen a woman or was seeing some women or had had an encounter with a woman on one of these trips?

A. I don't recall specifically, no. That would be the standard thing for her to ask me if she knew that I was with him.

Q. Well, I mean, you said a minute ago, "Did you keep out of trouble?" That could mean lots of different things. Did she ever ay anything to you that indicated that she was afraid that Bill Clinton was seeing women or having sexual encounters with women?

MR. BENNETT: Object to the form of the question.

A. She did ask me specifically about Jane Doe 2 again, generally she would ask me if we stayed out of trouble, and I took that to mean had we done anything wrong. And the only trouble I knew we could get in, since I was a police officer, would be – again, coupling that with what she would ask about Jane Doe 2 was if we had messed around with any women or whatever you want to call it.

Q. Did you ever tell her that you had taken Bill Clinton to see Jane Doe 2?

A. No, not that I remember.

Q. Even if you had, you wouldn't tell her?

A. Right.

Q. Well, do you know whether Betsey Wright knew of any of the women that Bill Clinton was seeing?

MR. BENNETT: I object, asking him –

MR. RADER: I'm asking him about his knowledge, Mr. Bennett.

MR. BENNETT: Well, you're asking him his knowledge about her knowledge. You're not asking him if she ever said anything to him, so I object to the form of the question.

Q. You can answer the question.

A. If you don't mind asking that again.

Q. Do you have any knowledge whether Betsey Wright knew about the women that Bill Clinton was having encounters with?

A. The only way I can answer that is I know that she knew I knew, if that makes any sense. Now, I don't know what was in her head as far as particular women or anything like that, any names, any instances, anything like ...

Q. You don't know whether she knew of specific women that Clinton had had a sexual encounter? You don't know that?

A. I believe she knew about Jane Doe 2.

Q. How about Regina Hopper? Did she know about her, do you know?

A. Not that I recall, no.

Q. How about Robyn Dickey.

A. I don't recall her talking to me about Robyn.

Q. Did Betsey Wright ever make any comment to you or to Bill Clinton about the consequences if he had been to see Jane Doe 2?

A. Not that I remember.

Q. Did she ever express her concern about what Bill Clinton's meetings with all these women could do to his political career?

A. Not in so many words, no.

Q. Why did she care, then? Why was she asking you these questions?

MR. BENNETT: Object to the form of the question.

A. I don't know why she did. I assume that is because that is the reason. That's what I took the reason to be, that she wanted to know what we were doing while she wasn't there.

_     _     _

Q. In the American Spectator article entitled "Love and Hate in Arkansas, L.D. Brown's Story" by Daniel Wattenberg, have you read that article?

A. Yes.

Q. Page 35 in that article, according to you, said that Clinton's extramarital sexual partners were, quote, "purely to be graded, purely to be chased, dominated, conquered," unquote. What did you mean by that?

A. Well, grading, as degrading as it may sound, is something that he and I both would do. Every – pretty much every pretty woman that we would see, eight, nine, ten, seven, six, whatever.

Q. Well, you're saying that as far as Clinton was concerned, they were purely to be graded, chased, dominated, and conquered?

A. Well, in the sense of a game, in the sense of that any of these people that I'm talking about, say, Jane Doe 2 , it was not a love relationship. It was a sexual relationship alone.

_     _     _

Q. Would you say he was a sexual predator?

MR. BENNETT: Objection.

A. In my personal opinion. That's all I can give you.

MR. BENNETT: I object.

Q. That's what I'm asking for.

A. I don't think he was a sexual predator, no. I think he just liked good-looking women, as I did, and that's about all I can say.

_     _     _

Q. After you left Governor's Security, were you ever approached by Betsey Wright or someone that you understood was a representative of Betsey Wright about whether you were going to talk about all these sexual encounters that you knew about?

A. Yes.

Q. Describe that to me.

A. It was in 1992 during the campaign. A lady by the name of Kathy Ford, who had worked at the governor's office while I was there for Betsey, after meeting me somewhere, I assume at – the first time she was at a local tavern here called Diego's, and I assumed after the first time she came in it was just – she was just in town for the campaign, which she had told me, that she had came back from San Diego, I believe is where she was living, to work for Betsey or downtown during the campaign.

Well, she came back twice more, sat by herself, and kind of motioned me over, and the third time she – I asked her – I had enlisted a friend, that I was going to follow her and see what was up, because it was obvious to me that these weren't just chance encounters. She was meeting no one there. She would order, like, a beer and drink half of it and leave after she chatted with me.

And so I just – the last time she came in, which I believe was the third time, she – I walked down to her, and I said, "How's Betsey?" and she said, "Oh, she's fine. L.D., what is it you want?" And I told her – not exact words, but I just told her I wanted to be left alone. I didn't want anything at the time. I think I made a joke about, "Well, you're assuming he's going to win," or something like that.

So she left, and I followed her. I didn't need the other person to help me. She drove a half block from where this place was – it's not there anymore – to like a little 7-Eleven, quick, E-Z shop thing. I think it's a Stax store now. Got out of her car and walked to a pay telephone, and Betsey was waiting for her. Got out of her car and met her at the phone. They both get on the telephone.

I thought it was kind of comical, and I just – went ahead and pulled in and walked up to the door. As I went inside the Stax store or E-Z Mart, I just yelled, "Hi, Betsey. How are you?" and she – oh, busted, you know, kind of look, and she said, "Oh, hi, L.D." So I just thought it was pretty funny.

Q. Was this in close proximity to the presidential campaign?

A. This was in the presidential campaign.

Q. Well, again, referring to The American Spectator article, it reports that after you departed from the Governor's Security staff, it says then Clinton chief of staff Betsey Wright summoned you to a meeting in her Hill Road home to make sure that you would not squeal about Clinton's state-subsidized harem. That's their language. Do you recall that meeting?

A. Right. Colonel Goodwin, Tommy Goodwin, who was a friend of mine – still is, but he was director of the state police at that time, and, again, he and I were friends socially – he asked me if I would be willing to meet with Betsey, that they were concerned, upset that I had left. And I said, "I really don't want to, but if it'll help you stay out of hot water as someone who works directly under the governor, yes, I'll do it."

So I met with Betsey – she lived, I believe, on Hill Road at that time – and a guy by the name of Jim Clark, who was integral to this new job opening up for me. He was the director that I would have been working for and a former state trooper who worked on the Governor's Security with me and a friend.

And so I went over and met with the both of them, and this was not long after I left. And she said, "Oh, L.D., you're not going to talk, and it would be so bad if you talk. We don't want to do that." I don't think she ever mentioned women or anything embarrassing. To me it was obvious. She said, "We'll get you another state job," and I said, "Listen, I've been through all this. No promises. I don't want anything else to do with it. Just leave me alone."

I thought the bar thing was what you were asking about first, but that happened in '85 after I left the mansion.

Q. So you had a meeting with Betsey Wright in '85 when you left the mansion, and they wanted to talk to you about not talking at that time, right?

A. Right.

Q. And then you were approached again as the presidential campaign was ongoing?

A. Right.

© Copyright 1998 The Washington Post Company

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