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Discovery Requests

Jones's Request for Records from Clinton

This is the complete and unedited text of the first set of requests for "documents and things" from President Clinton filed by Paula Corbin Jones's lawyers. It is dated Oct. 1, 1997.

Among the information requested: Records of any medical procedure on Clinton's genitalia and any videotape on which Paula Jones appears. Jump to the requests.


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

FIRST SET OF REQUESTS FROM PLAINTIFF TO DEFENDANT
CLINTON FOR PRODUCTION OF DOCUMENTS AND THINGS

 

TO: William Jefferson Clinton

Pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure, Plaintiff Paula Jones hereby requests that you produce, for inspection and copying, all of the documents and tangible things described in the enumerated requests below. You are required to serve a written response, in full compliance with the applicable rules of procedure, on or before Monday, November 3, 1997.

Paula Jones requests that the production begin at 10:00 a.m. on Tuesday, November 4, 1997, and that the production take place at the offices of your attorney, Robert S. Bennett, Skadden, Arps, Slate, Meagher & Flom LLP, 1440 New York Avenue, N.W., Washington, D.C. 20005-2111.

 

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

A request for any particular document or thing is a request for the original, for each and every photocopy or duplicate of that document or thing, and for each and every draft of the document or thing.

The documents and things to be produced should, at the time of production, be organized and labeled to correspond to the enumerated requests below. In the alternative, they may be produced as they are kept in the ordinary course of business, if it is possible to do so.

You are to produce not only the documents and things in your immediate possession, but also those over which you have custody or control, including but not limited to documents and things in the possession, custody, or control 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 requests are continuing. After serving your initial response to these requests, please supplement your response whenever any document(s) or thing(s) meeting any of the enumerated descriptions below come into your possession, custody, or control.

If, in response to a particular request, an objection is interposed, and the objection applies to some but not all of the documents requested, please produce all responsive documents and things 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.

REQUESTS FOR PRODUCTION

REQUEST FOR PRODUCTION NO. 1: Please produce each and every record of any surgery or other medical procedure performed after May 8, 1991, on the genitalia of Defendant Clinton.

RESPONSE:


REQUEST FOR PRODUCTION NO. 2: Please produce each and every record of any treatment received by Defendant Clinton after May 8, 1991, for a disease or abnormality of the genitalia.

RESPONSE:


REQUEST FOR PRODUCTION NO. 3: Please produce each and every medical record of any diagnosis of a disease or abnormality of the genitalia of Defendant Clinton.

RESPONSE:


REQUEST FOR PRODUCTION NO. 4: Please produce each and every document referring to any disease or abnormality of the genitalia of Defendant Clinton.

RESPONSE:


REQUEST FOR PRODUCTION NO. 5: Please produce each and every document, if any, containing notes of any conversation during which was mentioned any one or more of the following individuals:

a. Paula Jones;

b. Frank Tappin;

c. Larry Patterson;

d. Roger Perry;

e. Danny Ferguson;

f. Ronnie Anderson;

g. Pamela Blackard;

h. Debra Ballentine;

i. Raymond L. "Buddy" Young.

RESPONSE:


REQUEST FOR PRODUCTION NO. 6: Please produce each and every document, if any, containing or describing the terms of any agreement, arrangement, or "deal" between or among any two or more of the following individuals:

a. William Jefferson Clinton;

b. Frank Tappin;

c. Larry Patterson;

d. Roger Perry;

e. Danny Ferguson;

f. Ronnie Anderson;

g. Pamela Blackard;

h. Debra Ballentine;

i. Raymond L. "Buddy" Young;

j. Mark Brown.

RESPONSE:


REQUEST FOR PRODUCTION NO. 7: Please produce each and every videotape in which appears any one or more of the following individuals:

a. Paula Jones;

b. Frank Tappin;

c. Larry Patterson;

d. Roger Perry;

e. Danny Ferguson;

f. Ronnie Anderson;

g. Pamela Blackard;

h. Debra Ballentine;

i. Raymond L. "Buddy" Young.

RESPONSE:


REQUEST FOR PRODUCTION NO. 8: Please produce each and every audio tape on which can be heard the voice of any one or more of the following individuals:

a. Paula Jones;

b. Frank Tappin;

c. Larry Patterson;

d. Roger Perry;

e. Danny Ferguson;

f. Ronnie Anderson;

g. Pamela Blackard;

h. Debra Ballentine;

i. Raymond L. "Buddy" Young;

j. Mark Brown.

RESPONSE:


REQUEST FOR PRODUCTION NO. 9: Please produce each and every document containing a reference to Paula Jones.

RESPONSE:


REQUEST FOR PRODUCTION NO. 10: Please produce each and every document which (1) was provided by, or on behalf of, Defendant Clinton to anyone (including but not limited to the White House press office) and (2) contains a reference to Paula Jones.

RESPONSE:


REQUEST FOR PRODUCTION NO. 11: Please produce each and every document containing a statement by any person who has had, or who claims to have had, sexual relations with Paula Jones.

RESPONSE:


REQUEST FOR PRODUCTION NO. 12: Please produce each and every document mentioning the name of any person who has had, or who claims to have had, sexual relations with Paula Jones.

RESPONSE:


REQUEST FOR PRODUCTION NO. 13: Please produce each and every photograph (including but not limited to negatives and slides) in which Paula Jones or her husband, Stephen Jones, appears.

RESPONSE:


REQUEST FOR PRODUCTION NO. 14: Please produce each and every document which (1) was obtained by you (or your attorney) either directly or indirectly from any employee of any publisher of any newspaper, magazine, or other publication, and (2) contains a reference to actual or supposed extramarital sexual relations by Defendant Clinton while he was Attorney General or Governor of the State of Arkansas.

RESPONSE:


REQUEST FOR PRODUCTION NO. 15: Please produce each and every document which (1) was obtained by you (or your attorney) either directly or indirectly from any employee of any television network, and (2) contains a reference to any actual or supposed extramarital sexual relations by Defendant Clinton while he was Attorney General or Governor of the State of Arkansas.

RESPONSE:


REQUEST FOR PRODUCTION NO. 16: Please produce each and every document which (1) was obtained by you (or your attorney) either directly or indirectly from Betsy Wright, and (2) contains a reference to any individual who had, or who has claimed to have had, extramarital sexual relations with Defendant Clinton while he was Attorney General or Governor of the State of Arkansas.

RESPONSE:


REQUEST FOR PRODUCTION NO. 17: Please produce each and every document (other than pleadings and formal discovery responses in this civil action) containing a statement by, or on behalf of, Defendant Clinton denying any of the allegations by Paula Jones in this case.

RESPONSE:


REQUEST FOR PRODUCTION NO. 18: Please produce each and every document containing or describing the test itself and/or the results of any lie-detector or polygraph test taken by either of the defendants in this case concerning any of the facts alleged by Paula Jones in this case.

RESPONSE:


REQUEST FOR PRODUCTION NO. 19: Please produce the entire contents of each and every file having as its title or identification (or as a part of its title or identification) the name Paula Jones.

RESPONSE:


REQUEST FOR PRODUCTION NO. 20: Please produce each and every written statement by anyone about Paula Jones.

RESPONSE:


REQUEST FOR PRODUCTION NO. 21: Please produce each and every document containing, or purporting to contain, a statement by Paula Jones about any of the facts alleged by her in this case.

RESPONSE:


REQUEST FOR PRODUCTION NO. 22: Please produce each and every videotape, and each and every audio tape, in which Defendant Clinton mentions, or responds to a question about, any of the following:

a. This civil action;

b. Paula Jones;

c. Any woman with whom Defendant Clinton had sexual relations when he was Attorney General of the State of Arkansas, Governor of the State of Arkansas, or President of the United States;

d. Any woman (other than Hillary Rodham Clinton) who has claimed that Defendant Clinton had, or attempted to have, sexual relations with her;

e. Any law or policy against sexual harassment and/or sex discrimination.

RESPONSE:


REQUEST FOR PRODUCTION NO. 23: Please produce each and every written statement by Defendant Clinton in which he mentions, or responds to a question about, any of the following:

a. This civil action;

b. Paula Jones;

c. Any woman (other than Hillary Rodham Clinton) with whom Defendant Clinton had sexual relations when he was Attorney General of the State of Arkansas, Governor of the State of Arkansas, or President of the United States;

d. Any woman (other than Hillary Rodham Clinton) who has claimed that Defendant Clinton had, or attempted to have, sexual relations with her;

e. Any law or policy against sexual harassment and/or sex discrimination.

RESPONSE:


REQUEST FOR PRODUCTION NO. 24: Please produce each and every document, if any, containing notes of any conversation between Defendant Clinton and any woman (other than Hillary Rodham Clinton) with whom Defendant Clinton had sexual relations when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 25: Please produce each and every document, if any, containing notes of any conversation during which was mentioned any woman (other than Hillary Rodham Clinton) with whom Defendant Clinton had sexual relations when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 26: Please produce each and every videotape in which appears any woman (other than Hillary Rodham Clinton) with whom Defendant Clinton had sexual relations when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 27: Please produce each and every audio tape on which can be heard the voice of any woman (other than Hillary Rodham Clinton) with whom Defendant Clinton had sexual relations when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 28: Please produce each and every photograph (including but not limited to negatives and slides) in which appears any woman (other than Hillary Rodham Clinton) with whom Defendant Clinton had sexual relations when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 29: Please produce each and every document (including but not limited to letters, memoranda, postcards, and e-mails) sent at any time by Defendant Clinton (or on behalf of Defendant Clinton) to any woman (other than Hillary Rodham Clinton) with whom Defendant Clinton had sexual relations when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 30: Please produce each and every document (including but not limited to letters, memoranda, postcards, and e-mails) sent at any time to Defendant Clinton by any woman (other than Hillary Rodham Clinton) with whom Defendant Clinton had sexual relations when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 31: Please produce each and every document (including but not limited to receipts, bank statements, wire-transfer records, and canceled checks) referring to, or generated in connection with, any payment or gift at any time by Defendant Clinton, or on behalf of Defendant Clinton, to any woman (other than Hillary Rodham Clinton) with whom Defendant Clinton had sexual relations when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 32: Please produce the entire contents of each and every file having as its title or identification (or as a part of its title or identification) the name or pseudonym of any woman (other than Hillary Rodham Clinton) with whom Defendant Clinton had sexual relations when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 33: Please produce each and every document, if any, containing notes of any conversation between Defendant Clinton and any woman (other than Hillary Rodham Clinton) who has claimed that Defendant Clinton had, or attempted to have, sexual relations with her when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 34: Please produce each and every document, if any, containing notes of any conversation during which was mentioned any woman (other than Hillary Rodham Clinton) who has claimed that Defendant Clinton had, or attempted to have, sexual relations with her when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 35: Please produce each and every videotape in which appears any woman (other than Hillary Rodham Clinton) who has claimed that Defendant Clinton had, or attempted to have, sexual relations with her when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 36: Please produce each and every audio tape on which can be heard the voice of any woman (other than Hillary Rodham Clinton) who has claimed that Defendant Clinton had, or attempted to have, sexual relations with her when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 37: Please produce each and every photograph (including but not limited to negatives and slides) in which appears any woman (other than Hillary Rodham Clinton) who has claimed that Defendant Clinton had, or attempted to have, sexual relations with her when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 38: Please produce each and every document (including but not limited to letters, memoranda, postcards, and e-mails) sent by Defendant Clinton, or sent on behalf of Defendant Clinton, to any woman (other than Hillary Rodham Clinton) who has claimed that Defendant Clinton had, or attempted to have, sexual relations with her when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 39: Please produce each and every document (including but not limited to letters, memoranda, postcards, and e-mails) sent to Defendant Clinton by any woman (other than Hillary Rodham Clinton) who has claimed that Defendant Clinton had, or attempted to have, sexual relations with her when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 40: Please produce each and every document (including but not limited to receipts, bank statements, wire-transfer records, and canceled checks) referring to, or generated in connection with, any payment or gift of money or anything of value at any time by Defendant Clinton, or on behalf of Defendant Clinton, to any woman (other than Hillary Rodham Clinton) who has claimed that Defendant Clinton had, or attempted to have, sexual relations with her when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 41: Please produce each and every public statement by Defendant Clinton, made when he was either Attorney General or Governor of the State of Arkansas, mentioning any existing or proposed law against sexual assault, sexual harassment, and/or sex discrimination.

RESPONSE:


REQUEST FOR PRODUCTION NO. 42: Please produce each and every executive order issued by Defendant Clinton, when he was Governor of the State of Arkansas, mentioning sexual assault, sexual harassment, and/or sex discrimination.

RESPONSE:


REQUEST FOR PRODUCTION NO. 43: Please produce each and every opinion issued by Defendant Clinton, when he was Attorney General of the State of Arkansas, mentioning sexual assault, sexual harassment, and/or sex discrimination.

RESPONSE:


REQUEST FOR PRODUCTION NO. 44: Please produce the entire contents of each and every file having as its title or identification (or as a part of its title or identification) the name or pseudonym of any woman (other than Hillary Rodham Clinton) who has claimed that Defendant Clinton had, or attempted to have, sexual relations with her when he 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.

RESPONSE:


REQUEST FOR PRODUCTION NO. 45: Please produce each and every document (including but not limited to receipts, bank statements, wire-transfer records, and canceled checks) referring to, or generated in connection with, any payment or gift or perquisite at any time by Defendant Clinton, or on behalf of Defendant Clinton, to any person who was a member of Defendant Clinton's security detail when he was Governor of the State of Arkansas.

RESPONSE:


REQUEST FOR PRODUCTION NO. 46: Please produce each and every document, if any, containing terms of an agreement between you and any attorney or law firm (regardless of whether other persons are also parties to the agreement) with respect to attorney fees and/or expenses charged, or to be charged, for representing you in this case.

RESPONSE:


REQUEST FOR PRODUCTION NO. 47: Please produce each and every document, if any, stating an amount of time spent by any attorney on your behalf in the course of rendering legal services in furtherance of any claim or defense asserted by you in this lawsuit.

RESPONSE:


REQUEST FOR PRODUCTION NO. 48: Please produce each and every document, if any, summarizing or totaling the amount of time spent by any attorney on your behalf in the course of rendering legal services in furtherance of any claim or defense asserted by you in this lawsuit.

RESPONSE:


REQUEST FOR PRODUCTION NO. 49: Please produce each and every statement of fees charged by your attorney in the course of rendering legal services in furtherance of any claim or defense asserted by you in this lawsuit.

RESPONSE:


REQUEST FOR PRODUCTION NO. 50: Please produce each and every record of time expended, either before or after this lawsuit was commenced, by an attorney in the course of rendering legal services for which you are seeking to recover attorney fees in this lawsuit.

RESPONSE:


REQUEST FOR PRODUCTION NO. 51: Please produce each and every document, if any, stating the amount of expenses paid by any attorney in the course of preparing or investigating this lawsuit on your behalf.

RESPONSE:


REQUEST FOR PRODUCTION NO. 52: Please produce each and every document, if any, stating the amount of one or more expenses paid by any attorney in the course of representing you in this lawsuit.

RESPONSE:


REQUEST FOR PRODUCTION NO. 53: Please produce each and every document, if any, summarizing or totaling the amount of expenses paid by any attorney in the course of representing you in this lawsuit.

RESPONSE:


REQUEST FOR PRODUCTION NO. 54: Please produce each and every document, if any, containing terms of an agreement between you (or your attorney) and any person whom you may or will call to testify (by affidavit, by deposition, or in person) as an expert witness at any hearing or at the trial of this lawsuit.

RESPONSE:


REQUEST FOR PRODUCTION NO. 55: Please produce each and every document, if any, containing notes of any conversation with any person whom you will call to testify as an expert witness at trial or any hearing or in any affidavit in this case.

RESPONSE:


REQUEST FOR PRODUCTION NO. 56: Please produce each and every document which you or your attorney has sent to any person whom you will call to testify as an expert witness at any hearing or trial or in any affidavit in this case.

RESPONSE:


REQUEST FOR PRODUCTION NO. 57: Please produce each and every document which you or your attorney has received from any person whom you will call to testify as an expert witness at any hearing or trial or in any affidavit in this case.

RESPONSE:


REQUEST FOR PRODUCTION NO. 58: Please produce each and every document which was examined or considered by any person whom you will call to testify as an expert witness at any hearing or trial or in any affidavit in this case, in the course of forming his or her opinions to be expressed in this case.

RESPONSE:


REQUEST FOR PRODUCTION NO. 59: Please produce each and every document which was created in the course of working on this case by or on behalf of any person whom you will call to testify as an expert witness at any hearing or trial or in any affidavit in this case.

RESPONSE:


REQUEST FOR PRODUCTION NO. 60: Please produce each and every insurance agreement under which any person carrying on an insurance business may be liable to satisfy part or all of a judgment which may be entered in this civil action or to indemnify or reimburse for payments made to satisfy a judgment which may be entered in this civil action.

RESPONSE:


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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