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Discovery Requests

Jones's Third Set of Questions for Clinton

This is the complete and unedited text of the third set of interrogatories for President Clinton filed by Paula Corbin Jones's lawyers. It is dated Oct. 13, 1997.

Jump to the questions.


IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF ARKANSAS
WESTERN DIVISION

PAULA CORBIN JONES,
Plaintiff,

v.

WILLIAM JEFFERSON CLINTON
and DANNY FERGUSON,
Defendants.












CIVIL ACTION NO. LR-C-94-290

Judge Susan Webber Wright

THIRD SET OF INTERROGATORIES
FROM PLAINTIFF TO DEFENDANT CLINTON

 

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, not later than the thirtieth day after service hereof.

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. 20: Please state the name, address, and telephone number of each and every person who has, or who is likely to have, discoverable information relevant to one or more disputed facts alleged with particularity in the pleadings in this case.

ANSWER:

INTERROGATORY NO. 21: Please state the name, address, and telephone number of each and every person to whom you have made one or more statements (regardless of whether or not they were written, oral, formal, informal, on-the-record, or off-the-record) about anything that happened on May 8, 1991, at the Excelsior Hotel in Little Rock, Arkansas.

ANSWER:

INTERROGATORY NO. 22: Please state the name, address, and telephone number of each and every person to whom you have made one or more statements (regardless of whether or not they were written, oral, formal, informal, on-the-record, or off-the-record) about anything that you said to Paula Jones, or anything that you did in the presence of Paula Jones, on May 8, 1991, at the Excelsior Hotel in Little Rock, Arkansas.

ANSWER:

INTERROGATORY NO. 23: For each and every conversation (either in person or by telephone) that you have had with Defendant Ferguson at any time after you became President of the United States, please state the following:

(a) The date of the conversation;

(b) Whether the conversation was in person or by telephone;

(c) If the conversation was by telephone, who initiated the call;

(d) The number of the telephone from which the call was placed; and

(d) Everything that was said during the conversation. (If you do not remember exactly what was said, please state the substance of what was said.)

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

© Copyright 1997 Digital Ink Company

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