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Excerpts From the Deposition of Roger Perry


Related Links
_ Full Coverage: Clinton Accused

_ Full Text of Other Legal Documents

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


Released on Friday, March 13, 1998

Following are excerpts from the deposition of former Arkansas State Trooper Roger Perry. The deposition was held Nov. 11, 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." The "Jane Doe 1" mentioned below is longtime Clinton friend Marilyn Jo Jenkins. In these excerpts, Perry was being questioned by Jones Attorney Robert E. Rader. Robert S. Bennett represented President Clinton.

Q. During the time that you were with Governor's Security – I guess the years would be '89 until '92 when Bill Clinton was governor – did you travel with him?

A. Yes, sir.

Q. As a member of his security force?

A. Frequently, yes sir.

Q. Did there come a time when you traveled with Bill Clinton when he would point out a pretty woman to you and ask you to get information about that woman?

A. Yes, sir.

MR. BENNETT: Object to the leading nature of the question.

Q. Was this something that happened more than once?

A. To actually ask me to get a woman's name and number, one time – there were several times that he wanted to know a woman's name. I would get that. I mean as far as asking for a phone number, just once and actually trying to find out who the person was and give him the information.

Q. What was that specific instance, do you recall that?

A. It was in Augusta, Arkansas, at a Christmas parade. The year would be '89 or '90. I'm not real sure. '89, I believe. I think I had been back in Governor's Security just a short period of time. There was a lady in the crowd. The governor was in a convertible. He was riding in the convertible, and it was crowded, real cold, and he got out. We were walking, and he noticed this lady in the crowd, was talking about how beautiful she was, how pretty she was.

And he said, "Find out who that is." After the reception – I mean, after the parade, we went to a local bank lobby where they had a reception for the governor, and I talked to the lady. The lady's name was Holly Cain. I believe the last name is Cain.

Q. C - a - i - n?

A. That's been so many years ago. Yes, sir. And I talked to her and asked her for her phone number, and she was interested in a state job. The lady's name was Holly Cain. I believe the last name was Cain.

Q. Did she say she was interested in a state job?

A. Yes, she graduated from, I believe –

MR. BENNETT: Excuse me, I'm going to object to just him giving the narrative. I think you should ask him questions, and he should give you answers. I don't think he's being responsive to the question.

MR. RADER: Well, I'm asking him to describe the incident, Mr. Bennett. That's what he's doing.

MR. BENNETT: That's not what you asked him. You asked him a specific question, and he's just running on.

Q. You say you talked to her in the bank lobby?

A. Yes, sir. There was a reception, like I say. There was refreshments and hors d'oeuvres, things like that.

Q. And she stated that she was interested in a state job?

A. I had – just talking to her, casual conversation, and she was interested in which I did and being a bodyguard for the governor. And I asked her – I said, "Well, give me your name and phone number, and I'll pass it to the governor, and maybe there's an opening or something." And when we left the reception driving back to Little Rock, before we got out of the city limits of Augusta, which is a very small town, I handed him the business card with her name and number on it.

Q. Now, when you say you handed him –

A. Handed Gov. Clinton.

Q. Did you tell him that she had said she was interested in a state job?

A. Right, I said, "You are going to" – my exact words were, "You're going to like this." I said, "She's wanting a state job," and he said, "All right."

Q. Did you ever see this woman, Holly Cain, after that?

A. Yes, I did .

Q. Can you describe those circumstances?

A. The next time I actually saw Holly Cain was – again, I'm not real sure on the last name. She was at the State House, the old State House right next to here, between Camelot – excuse me, the DoubleTree and the Excelsior, and she was working on Gov. Clinton's presidential campaign.

Q. Do you talk to her at that time?

A. Yes, I did, briefly. I was with the governor. I was there, and she was on the – she was passing out pamphlets, talked to her briefly, probably two, three minutes.

Q. Did you ask her what she was doing? What was she –

A. I said, "I see you've got the job," and she said, "Yeah. Maybe it'll turn into something better," just casual conversation about – I don't remember – I think just asking her if she was working for his campaign. She responded by saying, "Yes."

Q. Do you have any idea where Holly Cain is now?

A. I have no idea.

Q. Do you know the name Jane Doe 1?

A. Yes, sir, I do.

Q. Do you know who she is?

A. Yes, sir.

Q. Have you ever seen her come to the governor's mansion while you were on Governor's Security?

A. Personally just to see her come in to visit the governor, no sir.

Q. Did you ever take the governor to where she lived?

A. Jane Doe 1?

Q. Yes.

A. Not that I recall, no, sir.

Q. Did you ever have a conversation with Danny Ferguson about Jane Doe 1?

A. Yes, sir.

Q. Would you describe that conversation?

A. It was the governor, then president-elect Clinton. I think he was leaving at approximately two o'clock that afternoon. I had come in that morning. I believe Danny had worked the midnight shift. There were two other people in the room. To recall their names or even their faces, I won't be able to do anything with it. He was either an ATF agent, a customs agent, or an IRS agent who acted as the on-ground security for President Clinton.

I walked in the guard shack that morning to relieve Danny and Danny said, "You're not going to believe what the son of a bitch has done now," and they – it was kind of a laughing, joking type like we had done in the past. Danny and I were friends. And the other two people in the room were privy to the conversation. He said that he – president-elect Clinton had had him – that's not the words Danny use. He used, "The governor had me call Jane Doe 1 and told me what – even told her to wear a trench coat, a hat, and to use her maiden name when she pulled up to the checkpoint."

And Danny would O.K. it with the checkpoint for her to come in, that she was going to be doing some work that morning. And Danny escorted her to the basement area of the governor's mansion. There's usually a game room downstairs, what we call a game room, and delivered her to Gov. Clinton.

Q. Did Danny Ferguson say whether he had to stand guard?

A. He told me he stood on the stair just in case Chelsea woke up.

Q. Did he say what the governor and/or Jane Doe 1 were –

A. No, I don't think he had. I don't think he was allowed in the game room.

_     _     _

Q. Did Bill Clinton ever talk to you about having sexual encounters with women other than Hillary Clinton?

A. Yes.

Q. Can you relate those conversations?

Q. Told me in – I was having trouble with my marriage at the time, and we were talking about women in general and the things that go wrong in people's lives in marriages. And he was asking me questions about my problems, and he said, "A lot of times I'm in the same position," and he didn't give me a name or anything. He just told me that he loved another woman.

Q. He told you that he loved another woman?

A. Yes, sir.

_     _     _

Q. What kinds of things would you do to conceal these encounters from Hillary Clinton?

A. Lie to her on the phone about his whereabouts – late at night. Sometimes on a midnight shift he would tell me he was going to be gone for a couple of hours. If Hillary woke up, to call him. He would have the cellular phone with him.

Q. Did that ever happen?

A. Yes. He did it on a few occasions, and nothing ever happened. One night Hillary did wake up and called downstairs and asked me, and she said, "Roger, where's Bill?" and that's the exact works she used, "Where's Bill?" And I said, "Hillary, he had insomnia. He couldn't sleep, so he went for a drive."

She started screaming and cussing and slammed the phone down. I got the phone and called him, and I said, "Governor, Hillary's up." And he said, "Oh my God. Oh, God. Oh, God," and he came in the back gate probably five or ten minutes later.

Q. Where was he when you called him, do you know?

A. Sir, I would hate to speculate on that. I mean, I don't know definitely where he was at.

Q. That's what I'm asking, if you know.

A. No.

Q. You called him on a cell phone?

A. Yes.

Q. Did he indicate why – first of all, did he appear on the phone to be upset that –

A. Very much upset, yes.

Q. Did he indicate to you why he was upset that –

A. No. All he was saying was, "My God. My God. I'll be right there. I'll be right there."

Q. Other than the instance that you've talked about where Danny Ferguson reported that Jane Doe had come to the governor's mansion, do you have any knowledge of any other instances when women would come to the governor's mansion to see Gov. Clinton?

A. Well, I mean, here were several women, Mr. Rader, that came to the governor's mansion. For me to sit here and tell you that they went in the house – and I know Hillary wasn't there when a lot of these women would show up, but to say that they went in the house and actually had a sexual relationship with Bill Clinton, I can't say that.

_     _     _

Q. To your knowledge, did there come a time in Little Rock when Gennifer Flowers told the press that she'd had a relationship with Bill Clinton?

A. Yes, sir. I was working at the time.

Q. When that occurred, did Bill Clinton ever comment on that in your presence?

A. Well, we had a conversation outside of the guard shack when the Gennifer Flowers story was in the limelight. And we were talking, and I said, "Do you think this is going to hurt you, Governor?" I mean, he was running for president, and he said, "I don't think so." And I said, "Well, you know, one woman destroyed Gary Hart, and you make him look like a saint." And he was getting ready to jog that morning with the Secret Service, and he turned and was walking off, and he turned around and looked at me, and he said, "Yeah, I do, don't I?"...

© Copyright 1998 The Washington Post Company

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