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Excerpts From the Deposition of Danny Ferguson

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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 Danny Ferguson, an Arkansas state trooper and co-defendant with President Clinton in the Paula Jones case. The deposition was held Dec. 10, 1997 at a Little Rock law firm.

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 1 is longtime Clinton friend Marilyn Jo Jenkins; Jane Doe 2 is longtime friend Beth Coulson.

In these excerpts, Ferguson is being questioned by Jones Attorney Robert E. Rader, and then by his own attorney, Bill W. Bristow. Robert S. Bennett represented President Clinton.

Q. Let me ask you about the time you talked to [Los Angeles Times reporter] Bill Rempel here in Little Rock, I believe you said at the Marriott, right?

A. I believe that's correct.

Q. There were some other people at that meeting as well, weren't there?

A. Yes, sir.

Q. Who were those people?

A. Cliff Jackson, Lynn Davis, Roger Perry, Larry Patterson, Ronnie Anderson.

Q. What was the purpose of the meeting?

A. Purpose of that meeting, we'd had a prior meeting about getting information, see how much a book would bring in about the president. My understanding was that Mr. Rempel was going to write an article prior to the book being released, and he was doing background on that.

Q. Why did you ask him not to tape what you said?

A. I wanted everything off the record in case I changed my mind.

Q. Well, when you talked to Mr. Rempel, did you – were the things that you told him at that time true?

A. Yes, sir.

Q. So when you say you changed your mind, do you mean you changed your mind about what you were going to say?

A. No. What the deal was, they were supposed to do research on a book and get back with us, see how much a book would bring in. We was then going to make a decision on whether we would go forward with the book, depending on how much they thought the book would bring in.

Q. Who was going to do research on the book to see how much it would bring in?

A. David Brock,

Q. So David Brock was there, too, at the same time?

A. No. We had met with him earlier in the same day at the Holiday Inn-Airport.

Q. Who all was interested in doing this book? You and Roger and –

A. Larry Patterson and Ronnie Anderson.

Q. This was – you met with Rempel in August of '93?

A. I'm not sure.

Q. Well, it was after Bill Clinton had been elected to the White House, wasn't it?

A. Yes, sir.

Q. Do you recall that it was in the later summer?

A. I recall it being in the summer, yes, sir.

Q. During this time that you talked to Rempel, you-all talked about Clinton's extramarital encounters with different women, didn't you?

A. Yes, sir.

Q. What did you talk about specifically in that regard?

A. My part –

Q. Uh-huh.

A. – was about Paula Jones and Jane Doe 1.

Q. Well, what did you tell Rempel about Jane Doe 1?

A. That I had taken her – she had come up to the mansion after the governor had been elected president before he was sworn in and went in and saw the governor early in the mornings.

Q. Now, this happened how many times?

A. Best of my knowledge, probably four.

Q. Describe how that happened.

A. Usually it happened – all except one time it happened when I was working midnights. He would call out about five o'clock in the morning saying that Jane Doe 1 was coming by, and the procedure then was that the Secret Service was outside. And she would have to go to their gate, and they would call in and confirm that it was okay for her to come in. So the president-elect would let me know that she was coming to the gate, to let her – you know, let him know it was okay to come in.

She would come in, park over by the security shack. I would go out and meet her and then take her downstairs to – used to be the game room. They had turned it into an office space when he was running for president. I would then go upstairs. He was usually in the kitchen reading the paper. I'd tell him that she was there. I'd go back downstairs and wait in the outer office until she got ready to leave, and I'd walk her back out to her car.

Q. Did President-Elect Clinton tell you how she would be dressed?

A. I believe on the last day he did, yes.

Q. What did he say about how she would be dressed?

A. Long coat, baseball cap.

Q. Did she use her regular correct name when she made those trips?

A. I believe she did, except for the last one. She used her maiden name Roe.

Q. Why did she use her maiden name, do you know?

A. I have no idea.

Q. Did Clinton tell you that she would be coming in with a coat and a cap using her maiden name?

A. Yes, sir.

Q. Let's talk about that last time for just a minute. That's the one that you told Roger Perry about, wasn't it, that time that she came – I think it was the day that Clinton was getting ready to go to Washington?

A. Yes, sir.

Q. And you told Roger Perry about that when he came on duty that morning didn't you?

A. I could have. I don't know who relieved me, but I could have.

Q. Well, you were present at Roger's deposition?

A. Yes, sir.

Q. You remember he said that you told him that morning when he came in?

A. I won't dispute that.

Q. Now, Jane Doe 1 came into the mansion that morning, and you took her down to the game room? Was that what you called it?

A. Well, it used to be the game room. They changed it to an office when he started running for president. It was in the lower level of the mansion.

Q. What time did you take her there?

A. Right around five-fifteen.

Q. And was Clinton there, or was he in the kitchen reading the paper? Where was he?

A. He was in the kitchen reading the paper.

Q. So after you took Jane Doe 1 to the basement, I'll say, you went and told Mr. Clinton that she was down in the basement?

A. Yes, sir.

Q. Then what did you do?

A. I went downstairs with him, and there's an outer office outside of the – I'll call it the game room. I sat there until she got ready to leave.

Q. Why did you stay there instead of going back to the guard shack?

A. He told me to wait and walk her back out.

Q. Is that exactly what he said. "I want you to just wait here so you can walk her back out?"

A. On that occasion, yes, sir.

Q. Well, did he say something different on the previous occasions when you took her down to the basement?

A. On one occasion he had me stay on the stairwell because Chelsea was there alone, and she was sick. I had to stay there. He wanted me to listen for her.

Q. Well, did he say that he wanted you to listen in case she came down looking for him?

MR. BENNETT: I object. I mean, leading is one thing, but that's –

Q. What did he say?

MR. BENNETT: Don't put works in the witness' mouth. Let's hear what he has to testify to.

A. I really don't know if he said that or if he was just worried about her being sick and up there, upstairs.

_     _     _

Q. What was the book you-all were talking about going to be about?

A. Trash. We were going to trash the president.

Q. Going to be about his extramarital involvement with other women?

MR. BENNETT: I object, because that assumes a fact not in evidence.

MR. RADER: Mr. Bennett, I asked him what it was going to be about, and I specifically asked him –

MR. BENNETT: No. That is an objectionable question.

MR. RADER: This is an adverse witness. I'm entitled to ask him leading questions. It is a proper question.

MR. BENNETT: I don't object to leading questions. I object to the form of the question. You're assuming facts that are simply not in evidence. That's an objection your Mr. Campbell has made every other question, so I'm making the same one.

Q. When you say the book was going to be to trash the president, what was it going to be about, Mr. Ferguson?

A. Every rumor we have ever heard about him.

Q. Weren't you concerned about libel if you just wrote a book base on rumors?

A. I don't think we was concerned about anything then.

Q. How did the idea of the book first come up?

A. Roger Perry approached me. They had already had several meetings when they approached me about it.

Q. Who is "they?"

A. Roger Perry, Lynn Davis, Cliff Jackson, Ronnie Anderson, Larry Patterson.

Q. Did you-all sit around in the guard shack and talk about the book?

A. Probably did.

Q. Did you-all sit around in the guard shack and talk about Mr. Clinton's involvement with different women?

MR. BRISTOW: Let me object to the form of that question, because when you say "you-all," which is a good southern expression that I use a lot, but in fairness to the witness, I'm not sure who "you-all" is in this particular question.

MR. RADER: That's a valid point. I'll rephrase the question.

Q. Did you ever sit around the guard shack with Roger Perry and Larry Patterson and other troopers who were on duty at the time and talk about Mr. Clinton's involvement with women other than Hillary?

MR. BENNETT: Object to the form, assumed a fact not in evidence.

A. Yes, sir.

Q. And what would your conversations be? I mean, give me an idea about what everyone would say. Give me a flavor for those conversations.

A. Like. Larry told us about taking him over to Jane Doe 2's house and Jane Doe 4' s house. Of course I told about Jane Doe 1 and Paula Jones. It was just right along those lines.

Q. How many times would you have conversations like this?

A. Well, we didn't work together all the time. It wasn't anything that happened every day or every week.

_     _     _

Q. What did you tell Bill Rempel about Paula Jones that time when you met with him in '93?

A. I have no idea.

Q. Well, what's your recollection at this point in time about what happened when you met Paula Jones?

A. You want me to go through the whole thing?

Q. Let's start – first of all, explain to me about the conference and what you and the governor were doing at the conference.

A. Best of my knowledge, he was giving the opening or the welcoming statement at this conference. It was in the morning. We got there late like usual. He went in, did his speech. I stayed in there with him, because we tape-record everything.

He came back outside of the conference room, and I believe they had doughnuts, coffee all set up, and he was out there doing that, talking to the press. And then there's people from the conference that was coming out to talk to him. Ms. Jones was sitting at the table with another female. I recognized her just by face. I didn't know her by name at that point.

I went over and started small-talking with her, and they were kind of giggling about the governor's pants being too short. And they – she said that she thought he was good-looking, had sexy hair, wanted me to tell him that. Also, wanted me to – that's when she said she'd like to meet him, so I told him that. And he had come back that she had that come-hither look, and there's a few things said back and forth.

He stayed out there – I really don't know how much longer – talking to people and he motioned for me to come over to him. He asked me to see if I could get him a room, that he was expecting a call from the White House and that he had several phone calls that he needed to make, for me to go to the car, get his briefcase because his phone messages were in there. So I got the briefcase.

I went to the front desk. I told them what the governor needed. They gave me to I guess, the manager, assistant manager, who gave me the key to a room. I went back and got him, took him upstairs to the room. I believe it was then that he told me that if Paula wanted to meet him, that she can come up. So I wrote the number down on a piece of paper, went down to her, gave it to her thinking if she wanted to go up, she'd go up. She said that she didn't know whether she could get away from the desk there. I told her, "It's no big deal. I'll just tell the governor." I said, "I'm going around the corner to sit on a couch." He had told me to come back down to the second floor in case somebody from the conference needed him. I had the cellular phone in case he needed me.

It wasn't, oh, three or four minutes she came around the corner. I was sitting on the couch. I asked her, "How did you get away?" She said she told then that she wasn't feeling well, that she needed to go to the bathroom. I thought she'd go on up, but she kept staying. I said, "Do you want me to walk up with you?" and she said, "Yeah."

So I walked up to the – we rode the elevator. I believe it was the eighth floor, I believe it was. We got off the elevator. I pointed in the direction of the room. I immediately turned and went back downstairs to the second floor where the governor told me to wait. I could watch the elevators and also be close to the conference.

About fifteen, twenty minutes later, maybe a little bit longer – I'm not sure – she came back down. She was smiling. She walked up to me and asked me if the governor and I were going to be at the conference the remainder of the day, and I said that his schedule had that on there, except for we'd go back to the mansion around lunchtime for a – I believe it was a photo op. And then she asked me if the governor had any girlfriends. I said, "No." She said that she would be his girlfriend.

She went on back to the direction of the conference. I waited there probably five, ten more minutes. I went upstairs and told the governor that is was time to go back to the mansion for the photo op., and when we got back to the mansion, I don't know if he came back to the conference or not. If he did, my working partner brought him back, because I didn't.

_     _     _

Q. After you talked to Paula Jones, then you went back, and you at some point told the governor, "This woman over here would like to meet you," right?

A. Yes, sir.

Q. What he say at that point?

A. That's when he said, "She's got that come-hither look."

Q. What does that mean?

A. That's just a word he used.

Q. Did he use it a lot?

A. Yes, sir.

Q. Come hither?

A. Come hither.

Q. Did he always use that in connection with women?

A. Yes, sir.

Q. But you don't know what he meant by it?

A. No, sir.

Q. So he said, "She's got that come-hither look," and then what did he say? What all did he say at that point?

A. That's all I can remember.

_     _     _

Q. When is the next time you saw Paula Jones?

A. About a week or two later at the governor's office.

Q. As I understand it, she's a courier? She would be in and out of the governor's office a lot, right?

A. Yes, sir.

Q. And I presume that's where you had seen her in the past when she was in and out as part of her job?

A. Yes, sir.

Q. And did you-all have any discussion the next time you saw her?

A. Yes, sir. She called me out of the – I was in the reception area. She called me out the door into the hallway.

Q. She called you out into the hallway?

A. She motioned for me to come outside as she was leaving the governor's office.

Q, What did you say, and what did she say?

A. She asked me if the governor had asked about her. I said, "No." She asked me for a piece of paper. She wrote her phone number down and said, "If he wants to talk to me, he can call me at this number. If my boyfriend answers, either hang up or tell him you've got the wrong number."

Q. When was the next time you saw her after that? Excuse me for interruption you, Mr. Ferguson. When she gave you that information, did you convey it to the governor?

A. No, sir. I threw it away as soon as I walked back in the door.

Q. When was the next time you saw Paula Jones?

A. At the Golden Corral.

Q. Just bumped into her there?

A. My wife and I were eating, and I didn't even know she was there. My wife first noticed her.

Q. Did your wife know Paula Jones?

A. No, sir.

Q. You say she noticed her. I mean, how did she –

A. Well, I was sitting with my back to where Paula was, and she said – my wife told me, said, "That girl over there keeps looking at you." So I turned around and looked, and it was Paula. She waved and I waved.

Q. Did she come over to your table?

A. About four or five minutes later – she didn't come to my table – she walked right past us and waved as, I guess, she went up to the food bar. Then she went back to her table. I just continued eating with my back to her, and my wife says, "That girl is trying to get your attention." So I looked over there. She motioned for me to come to her table. She had another lady there, also, and I believe there was a baby there.

Q. So you went over to her table –

A. Yes, sir.

Q. – and talked to her there?

A. Yes, sir, I did.

Q. What did you say, and what did she say then?

A. I apologized to her for her name being in the American Spectator. I said that David Brock never identified himself as writing for The American Spectator. He was doing background for a book. To put the words, I said, "I got screwed," and I apologized to her for her name being in the book – in the magazine article.

Q. Is that all you said?

A. She asked me then how much money I thought she could make. I told her that Roger and – Roger had told me that the National Enquirer was paying five hundred thousand, something like that. But I told her, I said, "You better think about your family, because I've been through it, and they was starting to dig up dirt." I said, "You need to think about your family," because she said she was thinking about coming forward.

And she said that she would have to tell her husband all of it, all of the truth. She said that she had told him that Clinton had asked her to come up to the room, that she had not told him that she went up to the room. And I think our final – she wanted the number to Roger Perry, how to get in touch with Roger Perry. I told her, "Just call headquarters."

Q. You say she said she was going to come forward. What did you understand she meant by that? Did she say?

A. Identify herself as the "Paula" in The American Spectator.

Q. Let me back up to the day when you took Paula to Clinton, to the eighth floor to meet with Clinton. You said a few minutes ago that you saw her come down fifteen, twenty minutes later.

A. Twenty, twenty-five or something like that. I'm not sure.

Q. How much longer was Clinton in the room before he came down?

A. He didn't – I waited five or ten minutes. Then I went back upstairs to get him, because we had to be at the mansion.

Q. Did Clinton discuss with you what had gone on in the room with him and Paula?

A. All he said to me is when I went in the room, I said, "Gov, we need to go." He said, "She came up here, and nothing happened." He was there another five minutes working on some paperwork that he had spread out on the desk, and then we went to the governor's mansion.

Q. What did you understand he meant when he said "Nothing happened"?

A. I don't know.

_     _     _

Cross Examination by Mr. Bristow

Q. Danny, you have been asked about an occurrence and a conversation at the Golden Corral with Paula Jones, and there were some conversations that you repeated about the National Enquirer and that they might pay five hundred thousand dollars. Do you recall that?

A. Yes, sir.

Q. Would you tell, for the record, specifically what you remember being said by Paula Corbin Jones with regard to that – to the issue of money?

A. She said that five hundred thousand dollars would last her a long time.

Q. Just kind of repeat that conversation about the money, if you would.

A. She had called me over to the table. I had apologized to her for the article and told her how – what had happened. And she asked me how much money I thought she could get out of it, and I told her that Roger told me about the National Enquirer or some other tabloid was paying as much as five hundred thousand. She said five hundred thousand would last her a long time.

And I tried to tell her that, you know they would get dirt on her and dig it up, and she needed to think about her family. She said nothing in her background would hurt her. She said that she would have to tell her husband the whole truth, that she had told him that Clinton had asked him to come up – or her to come up, but she had not told him that she went up to the room...

© Copyright 1998 The Washington Post Company

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