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Discovery Requests

Jones's Request for Admissions from Clinton

This is the complete and unedited text of the first set of requests for admissions from President Clinton filed by Paula Corbin Jones's lawyers. It is dated Oct. 8, 1997.

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 ADMISSIONS

 

TO: William Jefferson Clinton

Pursuant to Rules 26 and 36 of the Federal Rules of Civil Procedure, Plaintiff Paula Jones hereby requests that, on or before Monday, November 10, 1997, you serve a written response separately answering each of the requests enumerated below. Any matter admitted by you in response to these requests is conclusively established unless the Court on motion permits withdrawal or amendment of the admission. Any admission made by you in response to these requests is for the purpose of the above-referenced civil action only and is not an admission for any other purpose, nor may it be used against you in any other proceeding.

You are cautioned that if you fail to admit the truth of any matter as requested herein, and if Paula Jones thereafter proves the truth of the matter, Paula Jones may apply to the Court for an order requiring you to pay the reasonable expenses incurred in making the proof, including reasonable attorney's fees.

INSTRUCTIONS

1. Each of the matters set forth in the requests enumerated below shall be deemed admitted by you unless, on or before Monday, November 10, 1997, you serve upon Paula Jones (through her attorneys of record) a written answer or objection addressed to the matter, signed by you or by your attorney.

2. If you interpose an objection to a request for admission, you are required to state the specific reason(s) for the objection. Any and all objections should be interposed by the deadline for your initial response, or will be considered waived.

3. Your written answer shall specifically admit the matter, deny the matter, or set forth in detail the reasons why you cannot truthfully admit or deny the matter. A denial shall fairly meet the substance of the requested admission, and when good faith requires that you qualify an answer or deny only part of a matter of which an admission is requested, you shall specify so much of it as is true and qualify or deny the remainder.

4. You may not give lack of information or knowledge as a reason for failure to admit or deny unless you state that you have made reasonable inquiry and that the information known or readily obtainable by you is insufficient to enable you to admit or deny.

5. You may not object to a request solely because you believe that the matter of which an admission is requested presents a genuine issue for trial. You may, subject to the provisions of Rule 37(c) of the Federal Rules of Civil Procedure, deny the matter or set forth reasons why you cannot admit or deny it.

DEFINITIONS

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

"Defendant Clinton" means William Jefferson Clinton, a defendant herein.

"Defendant Ferguson" means Danny Ferguson, a defendant herein.

"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.

"Paula Jones" means the individual who is the Plaintiff in this lawsuit. Her name was Paula Rosalee Corbin until she was married on December 28, 1991.

REQUESTS FOR ADMISSION

REQUEST FOR ADMISSION NO. 1: Please admit or deny the following: On May 8, 1991, Defendant Clinton was the Governor of the State of Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 2: Please admit or deny the following: On May 8, 1991, the Governor of the State of Arkansas was the highest ranking officer of the executive branch of the government of the State of Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 3: Please admit or deny the following: On May 8, 1991, the Arkansas Industrial Development Commission was an agency of the government of the State of Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 4: Please admit or deny the following: On May 8, 1991, the Arkansas Industrial Development Commission was part of the executive branch of the government of the State of Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 5: Please admit or deny the following: On May 8, 1991, David Harrington was the Director of the Arkansas Industrial Development Commission.

RESPONSE:

REQUEST FOR ADMISSION NO. 6: Please admit or deny the following: Defendant Clinton appointed David Harrington to the position of Director of the Arkansas Industrial Development Commission.

RESPONSE:

REQUEST FOR ADMISSION NO. 7: Please admit or deny the following: On May 8, 1991, David Harrington was a friend of Defendant Clinton.

RESPONSE:

REQUEST FOR ADMISSION NO. 8: Please admit or deny the following: On May 8, 1991, Defendant Clinton attended a conference at the Excelsior Hotel in Little Rock, Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 9: Please admit or deny the following: On May 8, 1991, Defendant Clinton attended a conference entitled the "Governor's Quality Management Conference" which was held at the Excelsior Hotel in Little Rock, Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 10: Please admit or deny the following: On May 8, 1991, Defendant Clinton attended a conference entitled the "Third Annual Governor's Quality Management Conference" which was held at the Excelsior Hotel in Little Rock, Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 11: Please admit or deny the following: The conference which took place on May 8, 1991, at the Excelsior Hotel in Little Rock, Arkansas, was sponsored by the Arkansas Industrial Development Commission.

RESPONSE:

REQUEST FOR ADMISSION NO. 12: Please admit or deny the following: On May 8, 1991, Defendant Ferguson was a member of the Arkansas State Police.

RESPONSE:

REQUEST FOR ADMISSION NO. 13: Please admit or deny the following: On May 8, 1991, the Arkansas State Police was an agency of the State of Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 14: Please admit or deny the following: On May 8, 1991, the Arkansas State Police was part of the executive branch of the government of the State of Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 15: Please admit or deny the following: On May 8, 1991, Defendant Ferguson was an employee of the State of Arkansas (or an agency thereof).

RESPONSE:

REQUEST FOR ADMISSION NO. 16: Please admit or deny the following: On May 8, 1991, Defendant Ferguson was a member of the Security Detail for Defendant Clinton.

RESPONSE:

REQUEST FOR ADMISSION NO. 17: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel in Little Rock, Arkansas, Defendant Ferguson worked in his capacity as a member of the Arkansas State Police.

RESPONSE:

REQUEST FOR ADMISSION NO. 18: Please admit or deny the following: On May 8, 1991, while on duty as a member of the Arkansas State Police, Defendant Ferguson spoke to Paula Jones (whose name at that time was Paula Rosalee Corbin).

RESPONSE:

REQUEST FOR ADMISSION NO. 19: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel in Little Rock, Arkansas, Defendant Clinton spoke to Defendant Ferguson.

RESPONSE:

REQUEST FOR ADMISSION NO. 20: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel in Little Rock, Arkansas, Defendant Clinton spoke with Defendant Ferguson about Paula Jones (whose name at that time was Paula Rosalee Corbin).

RESPONSE:

REQUEST FOR ADMISSION NO. 21: Please admit or deny the following: On May 8, 1991, Paula Jones (whose name at that time was Paula Rosalee Corbin) was an employee of the State of Arkansas (or an agency thereof).

RESPONSE:

REQUEST FOR ADMISSION NO. 22: Please admit or deny the following: On May 8, 1991, Paula Jones (whose name at that time was Paula Rosalee Corbin) was working for the Arkansas Industrial Development Commission.

RESPONSE:

REQUEST FOR ADMISSION NO. 23: Please admit or deny the following: As of May 8, 1991, Paula Jones (whose name at that time was Paula Rosalee Corbin) reported to Clydine Pennington while working for the Arkansas Industrial Development Commission.

RESPONSE:

REQUEST FOR ADMISSION NO. 24: Please admit or deny the following: As of May 8, 1991, Clydine Pennington reported to David Harrington while working for the Arkansas Industrial Development Commission.

RESPONSE:

REQUEST FOR ADMISSION NO. 25: Please admit or deny the following: On May 8, 1991, Paula Jones (whose name at that time was Paula Rosalee Corbin) worked at the registration desk at a conference at the Excelsior Hotel in Little Rock, Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 26: Please admit or deny the following: On May 8, 1991, Paula Jones (whose name at that time was Paula Rosalee Corbin), in the course and scope of her employment with the Arkansas Industrial Development Commission, worked at the registration desk at a conference at the Excelsior Hotel in Little Rock, Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 27: Please admit or deny the following: On May 8, 1991, Pamela Blackard was an employee of the State of Arkansas (or an agency thereof).

RESPONSE:

REQUEST FOR ADMISSION NO. 28: Please admit or deny the following: On May 8, 1991, Pamela Blackard was working for the Arkansas Industrial Development Commission.

RESPONSE:

REQUEST FOR ADMISSION NO. 29: Please admit or deny the following: On May 8, 1991, Pamela Blackard attended a conference at the Excelsior Hotel in Little Rock, Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 30: Please admit or deny the following: On May 8, 1991, Pamela Blackard worked with Paula Jones (whose name at that time was Paula Rosalee Corbin) at the registration desk at a conference at the Excelsior Hotel in Little Rock, Arkansas.

REQUEST FOR ADMISSION NO. 31: Please admit or deny the following: On May 8, 1991, Pamela Blackard, in the course and scope of her employment with the Arkansas Industrial Development Commission, worked with Paula Jones (whose name at that time was Paula Rosalee Corbin) at the registration desk at a conference at the Excelsior Hotel in Little Rock, Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 32: Please admit or deny the following: Before May 8, 1991, Defendant Clinton had never met Paula Rosalee Corbin.

RESPONSE:

REQUEST FOR ADMISSION NO. 33: Please admit or deny the following: On May 8, 1991, Defendant Clinton talked with Paula Jones (whose name at that time was Paula Rosalee Corbin) in a room at the Excelsior Hotel in Little Rock, Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 34: Please admit or deny the following: On May 8, 1991, Defendant Clinton talked with Paula Jones (whose name at that time was Paula Rosalee Corbin), in a room at the Excelsior Hotel in Little Rock, Arkansas, and no one else was present in the room.

RESPONSE:

REQUEST FOR ADMISSION NO. 35: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel, Defendant Clinton directed Defendant Ferguson to tell Paula Jones (whose name at that time was Paula Rosalee Corbin) that Defendant Clinton would like to meet her (or words to that effect).

RESPONSE:

REQUEST FOR ADMISSION NO. 36: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel, Defendant Clinton directed Defendant Ferguson to tell Paula Jones (whose name at that time was Paula Rosalee Corbin) that Defendant Clinton would like to meet her in a certain numbered room (or words to that effect).

RESPONSE:

REQUEST FOR ADMISSION NO. 37: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel, Defendant Clinton asked Defendant Ferguson to tell Paula Jones (whose name at that time was Paula Rosalee Corbin) that Defendant Clinton would like to meet her (or words to that effect).

RESPONSE:

REQUEST FOR ADMISSION NO. 38: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel, Defendant Clinton asked Defendant Ferguson to tell Paula Jones (whose name at that time was Paula Rosalee Corbin) that Defendant Clinton would like to meet her in a certain numbered room (or words to that effect).

RESPONSE:

REQUEST FOR ADMISSION NO. 39: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel, Defendant Ferguson told Paula Jones (whose name at that time was Paula Rosalee Corbin) that Defendant Clinton would like to meet her (or words to that effect).

RESPONSE:

REQUEST FOR ADMISSION NO. 40: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel, Defendant Ferguson told Paula Jones (whose name at that time was Paula Rosalee Corbin) that Defendant Clinton would like to meet her in a certain numbered room (or words to that effect).

RESPONSE:

REQUEST FOR ADMISSION NO. 41: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel, Defendant Ferguson escorted Paula Jones (whose name at that time was Paula Rosalee Corbin) to a certain numbered room.

RESPONSE:

REQUEST FOR ADMISSION NO. 42: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel, Defendant Ferguson escorted Paula Jones (whose name at that time was Paula Rosalee Corbin) to a certain numbered room where Defendant Clinton was waiting.

RESPONSE:

REQUEST FOR ADMISSION NO. 43: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel in Little Rock, Arkansas, Defendant Ferguson carried a firearm.

RESPONSE:

REQUEST FOR ADMISSION NO. 44: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel in Little Rock, Arkansas, Defendant Clinton exposed his penis to Paula Jones (whose name at that time was Paula Rosalee Corbin).

RESPONSE:

REQUEST FOR ADMISSION NO. 45: Please admit or deny the following: On May 8, 1991, at the Excelsior Hotel in Little Rock, Arkansas, Defendant Clinton asked Paula Jones (whose name at that time was Paula Rosalee Corbin) to have sexual relations with him (or words to that effect).

RESPONSE:

REQUEST FOR ADMISSION NO. 46: Please admit or deny the following: On May 8, 1991, Paula Jones (whose name at that time was Paula Rosalee Corbin) did not have sexual relations with Defendant Clinton.

RESPONSE:

REQUEST FOR ADMISSION NO. 47: Please admit or deny the following: Paula Jones (whose name at that time was Paula Rosalee Corbin) has never had sexual relations with Defendant Clinton.

RESPONSE:

REQUEST FOR ADMISSION NO. 48: Please admit or deny the following: After May 8, 1991, Defendant Ferguson said to Paula Jones (whose name at that time was Paula Rosalee Corbin), "Bill would like to see you" (or words to that effect).

RESPONSE:

REQUEST FOR ADMISSION NO. 49: Please admit or deny the following: After May 8, 1991, Defendant Ferguson said to Paula Jones (whose name at that time was Paula Rosalee Corbin), "Bill wants your phone number" (or words to that effect).

RESPONSE:

REQUEST FOR ADMISSION NO. 50: Please admit or deny the following: After May 8, 1991, but while he was still Governor of the State of Arkansas, in the Rotunda of the Arkansas State Capitol Defendant Clinton touched Paula Jones and said "Don't we make a beautiful couple – beauty and the beast" (or words to that effect).

RESPONSE:

REQUEST FOR ADMISSION NO. 51: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with at least one woman (other than Hillary Rodham Clinton), and at least one member of the Arkansas State Police arranged at least one meeting between Defendant Clinton and the woman.

RESPONSE:

REQUEST FOR ADMISSION NO. 52: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with at least one woman (other than Hillary Rodham Clinton), and at least one member of the Arkansas State Police facilitated at least one meeting between Defendant Clinton and the woman.

RESPONSE:

REQUEST FOR ADMISSION NO. 53: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with at least one woman (other than Hillary Rodham Clinton), and at least one member of the Arkansas State Police concealed at least one meeting between Defendant Clinton and the woman.

RESPONSE:

REQUEST FOR ADMISSION NO. 54: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with at least one woman (other than Hillary Rodham Clinton), and at least one member of the Arkansas State Police assisted Defendant Clinton in concealing at least one meeting between Defendant Clinton and the woman.

RESPONSE:

REQUEST FOR ADMISSION NO. 55: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with at least one woman (other than Hillary Rodham Clinton) who was, at the time of the sexual relations, an employee of the State of Arkansas (or an agency thereof).

RESPONSE:

REQUEST FOR ADMISSION NO. 56: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with at least one woman (other than Hillary Rodham Clinton) who later became an employee of the State of Arkansas (or an agency thereof).

RESPONSE:

REQUEST FOR ADMISSION NO. 57: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with women (other than Hillary Rodham Clinton), and members of the Arkansas State Police arranged meetings between Defendant Clinton and the women.

RESPONSE:

REQUEST FOR ADMISSION NO. 58: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with women (other than Hillary Rodham Clinton), and members of the Arkansas State Police facilitated meetings between Defendant Clinton and the women.

RESPONSE:

REQUEST FOR ADMISSION NO. 59: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with women (other than Hillary Rodham Clinton), and members of the Arkansas State Police concealed meetings between Defendant Clinton and the women.

RESPONSE:

REQUEST FOR ADMISSION NO. 60: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with women (other than Hillary Rodham Clinton), and members of the Arkansas State Police assisted Defendant Clinton in concealing meetings between Defendant Clinton and the women.

RESPONSE:

REQUEST FOR ADMISSION NO. 61: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with women (other than Hillary Rodham Clinton) who were, at the time of the sexual relations, employees of the State of Arkansas (or an agency thereof).

RESPONSE:

REQUEST FOR ADMISSION NO. 62: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with women (other than Hillary Rodham Clinton) who later became employees of the State of Arkansas (or an agency thereof).

RESPONSE:

REQUEST FOR ADMISSION NO. 63: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with a woman whom he, as Governor, appointed to a position as a judge in the State of Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 64: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with a woman whom he, as Governor, later appointed to a position as a judge in the State of Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 65: Please admit or deny the following: While he was Governor of the State of Arkansas, Defendant Clinton had sexual relations with a woman whom he, as Governor, had previously appointed to a position as a judge in the State of Arkansas.

RESPONSE:

REQUEST FOR ADMISSION NO. 66: Please admit or deny the following: On January 8, 1994, at the Golden Corral Steakhouse in North Little Rock, Arkansas, Defendant Ferguson talked with Paula Jones in the presence of Debra Ballentine.

RESPONSE:

REQUEST FOR ADMISSION NO. 67: Please admit or deny the following: After Paula Jones publicly accused Defendant Clinton, in January 1994, of sexually harassing her, Defendant Clinton had at least one telephone conversation with Defendant Ferguson.

RESPONSE:

REQUEST FOR ADMISSION NO. 68: Please admit or deny the following: After Paula Jones publicly accused Defendant Clinton, in January 1994, of sexually harassing her, Defendant Clinton had at least one telephone conversation with Defendant Ferguson, and Defendant Clinton initiated the conversation.

RESPONSE:

REQUEST FOR ADMISSION NO. 69: Please admit or deny the following: After Paula Jones publicly accused Defendant Clinton, in January 1994, of sexually harassing her, Defendant Clinton had at least one telephone conversation with Defendant Ferguson during which Defendant Clinton mentioned one or more job opportunities for Defendant Ferguson.

RESPONSE:

REQUEST FOR ADMISSION NO. 70: Please admit or deny the following: After Paula Jones publicly accused Defendant Clinton, in January 1994, of sexually harassing her, Defendant Clinton had more than one telephone conversation with Defendant Ferguson.

RESPONSE:

REQUEST FOR ADMISSION NO. 71: Please admit or deny the following: After Paula Jones publicly accused Defendant Clinton, in January 1994, of sexually harassing her, Defendant Clinton had more than one telephone conversation with Defendant Ferguson and the conversations were initiated by Defendant Clinton.

RESPONSE:

REQUEST FOR ADMISSION NO. 72: Please admit or deny the following: After Paula Jones publicly accused Defendant Clinton, in January 1994, of sexually harassing her in May 1991, Defendant Clinton had more than one telephone conversation with Defendant Ferguson during which Defendant Clinton mentioned one or more job opportunities for Defendant Ferguson.

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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