Jones's Second Set of Questions for Clinton

This is the complete and unedited text of the second set of interrogatories for President Clinton filed by Paula Corbin Jones's lawyers. It is dated Oct. 1, 1997.

Among the information requested: The name of any doctor who has performed a medical procedure on Clinton's genitalia and the name of any individual with whom he has had sexual relations while holding elected office. Jump to the questions.

PAULA CORBIN JONES, Plaintiff, v. WILLIAM JEFFERSON CLINTON and DANNY FERGUSON, Defendants.

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CIVIL ACTION NO. LR-C-94-290 Judge Susan Webber Wright

TO: William Jefferson Clinton

Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Plaintiff Paula Jones hereby propounds the following written interrogatories to you. You are required to serve a written response, in full compliance with the applicable rules of procedure, on or before Monday, November 3, 1997.

DEFINITIONS

For the purposes of these requests, the following definitions apply:

"Defendant Clinton" means William Jefferson Clinton.

"Document" means any tangible thing on which appears, or in which is stored or contained, any words, numbers, symbols, or images. The term "document" includes any and all writings, drawings, graphs, charts, photographs, phono records,

and other data compilations from which information can be obtained and translated, if necessary, through detection devices, into reasonably usable form.

"Person" means any identifiable entity, including but not limited to individuals, corporations, partnerships, sole proprietorships, and unincorporated associations.

"You" means William Jefferson Clinton.

INSTRUCTIONS

Please answer each of the following enumerated interrogatories separately and fully, in writing, and under oath. A request for identification of any particular document or thing includes a request for identification of the original of that document or thing, as well as identification of each and every photocopy or duplicate of that document or thing, and each and every draft of the document or thing.

In answering the following interrogatories, you are to provide not only the information within your direct personal knowledge, but also the information within the knowledge of your attorney(s), any investigator employed by you or by your attorney(s), or any consultant or expert witness employed by you or by your attorney(s).

The following interrogatories are continuing. After serving your initial response to these interrogatories, please supplement your response whenever any information responsive to them is recalled or received by you or your attorney(s).

If, in response to a particular interrogatory, an objection is interposed, and the objection applies to some but not all of the information requested, please provide in your answer all responsive information to which the objection does not apply. Any and all objections should be interposed by the deadline for your initial response, or will be considered waived.

INTERROGATORIES

INTERROGATORY NO. 7: If, based on a claim of privilege or exemption from discovery (including but not limited to the attorney-client privilege and the work-product exemption), you are withholding from production any document or thing requested in the First Set of Requests from Plaintiff to Defendant Clinton for Production of Documents and Things, then please state the following for each and every document or thing:

a. A description of the general nature of the document or thing (for examples, "letter," "memorandum," "photograph," "cassette tape");

b. The date on which the document or thing was created;

c. The name and address, and telephone number of the person(s) who created the original of the document or thing;

d. The name of each and every individual who has seen, or had possession of, the original or a copy of the document or thing.

ANSWER:

INTERROGATORY NO. 8: Please state the name, address, and telephone number of each and every medical doctor who has performed any surgery or medical procedure on your genitalia at any time after May 8, 1991.

ANSWER:

INTERROGATORY NO. 9: Please state the name, address, and telephone number of each and every medical doctor who has examined your genitalia at any time after May 8, 1991.

ANSWER:

INTERROGATORY NO. 10: Please state the name, address, and telephone number of each and every individual (other than Hillary Rodham Clinton) with whom you had sexual relations when you held any of the following positions:

a. Attorney General of the State of Arkansas;

b. Governor of the State of Arkansas;

c. President of the United States.

ANSWER:

INTERROGATORY NO. 11: Please state the name, address, and telephone number of each and every individual (other than Hillary Rodham Clinton) with whom you proposed having sexual relations, or with whom you sought to have sexual relations, when you held any of the following positions:

a. Attorney General of the State of Arkansas;

b. Governor of the State of Arkansas;

c. President of the United States.

ANSWER:

INTERROGATORY NO. 12: Please state whether you, your defense fund, or any other person (other than Danny Ferguson) has paid, or contributed to pay, attorney fees incurred by Danny Ferguson in connection with this civil action.

ANSWER:

INTERROGATORY NO. 13: Please state whether you, your defense fund, or any other person (other than Kathleen E. Willey) has paid, or contributed to pay, attorney fees incurred by Kathleen E. Willey in connection with Civil Action No. 97-MC-16 in the United States District Court for the Eastern District of Virginia, Richmond Division.

ANSWER:

INTERROGATORY NO. 14: Please state the name, address, and telephone number of each and every individual (if any) whom you will or may call to testify as an expert witness at any hearing in, or at the trial of, this civil action.

ANSWER:

INTERROGATORY NO. 15: For each and every individual named in your answer to the preceding interrogatory, please state:

a. The subject matter on which the expert witness is expected to testify;

b. The substance of the opinions and mental impressions of the expert witness;

c. Each and every fact which is relied upon by the expert as part or all of the basis for any one or more of his or her opinions; and

d. The specific terms under which the expert witness has been, or will be, compensated as a result of his or her work in connection with this case.

ANSWER:

INTERROGATORY NO. 16: Please state the name, address, and telephone number of each and every female (other than Hillary Rodham Clinton) whom you kissed during a private meeting between you and the female at any time when you held any of the following positions:

a. Attorney General of the State of Arkansas;

b. Governor of the State of Arkansas;

c. President of the United States.

ANSWER:

INTERROGATORY NO. 17: Please state the name, address, and telephone number of each and every person who was asked by you to arrange a private meeting between you and any female (other than Hillary Rodham Clinton), attended by no one else, at any location other than your office, at any time when you held any of the following positions:

a. Attorney General of the State of Arkansas;

b. Governor of the State of Arkansas;

c. President of the United States.

ANSWER:

INTERROGATORY NO. 18: Please state the name, address, and telephone number of each and every person who worked in the Governor's Mansion in Little Rock, Arkansas, when you were Governor of the State of Arkansas.

ANSWER:

INTERROGATORY NO. 19: On May 8, 1991, did you enter a numbered suite or room – not a conference room, but a suite or room furnished for overnight lodging – at the Excelsior Hotel in Little Rock, Arkansas? If so, please state:

a. Why you entered the suite or room;

b. The name of each and every other person who was present in the suite or room at any time when you were there;

c. The name of each and every person who arranged to make the room available to you; and

d. Whether the Excelsior Hotel was paid for the suite or room and, if so, the name of the person who paid for it.

ANSWER:

Respectfully submitted,

[Application for Admission Pending]
Donovan Campbell, Jr.
State Bar of Texas No. 03725300

[Application for Admission Pending]
James A. Fisher
State Bar of Texas No. 07051650

[Application for Admission Pending]
David M. Pyke
State Bar of Texas No. 16419700

T. Wesley Holmes
State Bar of Texas No. 09908495

[Application for Admission Pending]
J. McCord Wilson
State Bar of Texas No. 00785266

RADER, CAMPBELL, FISHER & PYKE
(A Professional Corporation)
Stemmons Place, Suite 1080
2777 Stemmons Freeway
Dallas, Texas 75207
Telephone: (214) 630-4700
Facsimile: (214) 630-9996

ATTORNEYS FOR PLAINTIFF
PAULA JONES

OF COUNSEL:

John W. Whitehead
Steven H. Aden
THE RUTHERFORD INSTITUTE
Post Office Box 7482
1445 East Rio Road
Charlottesville, Virginia 22906-7482
Telephone: (804) 978-3888
Facsimile: (804) 978-1789