Back Mr. Clinton referred to Dave Harrington, Mrs. Jones accepted that he was cogent her that he had ascendancy over Mr. Harrington and over her job, and that he was accommodating to use that power. JONES DECL. ¶ 18. From that point Mrs. Jones was actual aflutter that her abnegation to abide to Mr. Clinton’s advances could accident her career and alike attack her employment. Id.
Mr. Clinton’s advances to Mrs. Jones were unwelcome. JONES DECL. ¶ 19. Mrs. Jones never said or did annihilation to advance to Mr. Clinton that she was accommodating to accept with him. Id. During the time they were calm in the auberge suite, Mrs. Jones resisted his advances although she was abashed by them and abashed by who he was. Id.
Back Mrs. Jones larboard the auberge suite, she was in shock and agitated but she approved to advance her composure. JONES DECL. ¶ 20. Mrs. Jones saw Trooper Ferguson cat-and-mouse alfresco the suite. Id. He did not escort Mrs. Jones aback to the allotment desk. Id. Mrs. Jones said annihilation to him and he said annihilation to her. Id.
Afterwards Mrs. Jones larboard the auberge room, Mr. Clinton told Trooper Ferguson, afterwards actuality asked, “She came up here, and annihilation happened.” FERGUSON DEP. at 63.
As Mrs. Jones alternate to the allotment board Ms. Blackard could acquaint “from far off” that “she aloof looked different.” BLACKARD DEP. at 68. As she got closer, Ms. Blackard could acquaint that Mrs. Jones was shaking. Id. Blackard anon asked Mrs. Jones what was wrong. JONES DECL. ¶ 21; BLACKARD DEP. at 68. Afterwards attempting to aggregate herself, Mrs. Jones told Blackard abundant of what had happened, but Mrs. Jones was too agitated to acquaint her everything. JONES DECL. ¶ 21; BLACKARD DEP. at 70. Jones said that she acquainted ashamed by what had happened. BLACKARD DEP. at 69. Blackard attempted to abundance Mrs. Jones. JONES DECL. ¶ 21. Afresh Mrs. Jones became “real quiet.” BLACKARD DEP. at 77.
Mrs. Jones larboard the Conference and went to the abode of a acquaintance alleged Debra Ballentine. JONES DECL. ¶ 22; BALLENTINE DEP. at 42-44. Mrs. Jones was still actual agitated emotionally addled and nervous. Id. Ms. Ballentine knew commodity was amiss immediately. BALLENTINE DEP. at 44. Mrs. Jones told her that she capital to allocution to her anon about commodity that had aloof happened and capital to altercate it achieve privately. JONES DECL. ¶ 22; BALLENTINE DEP. at 44. Ms. Ballentine and Mrs. Jones went to a clandestine breadth in the arrangement and talked for awhile, and afresh they went alfresco and talked for awhile. BALLENTINE DEP. at 44. Mrs. Jones had agitation cogent Ms. Ballentine what had happened because she was agitated and crying. Id. at 46. She batten in a whisper. Id. Eventually, Mrs. Jones told Ms. Ballentine what had happened with Mr. Clinton in the auberge suite. Id. at 46-5 1. Mrs. Jones was “shaking” and “crying” and “beside herself.” BALLENTINE DEP. at 13.
Ms. Ballentine apprenticed Mrs. Jones to address the adventure to the badge or to her superiors at the AMC. JONES DECL. ¶ 23; BALLENTINE DEP. at 50. Mrs. Jones was abashed to do so because it was the Accompaniment Badge themselves who had aloof helped Mr. Clinton advance her, and because Mr. Clinton had aloof told her that the arch of the AIDC was his “good friend.” JONES DECL. 12-3. What Mr. Clinton and Trooper Ferguson had said and done fabricated Mrs. Jones abashed to book charges. Id. Mrs. Jones begged Ballentine not to acquaint anyone what had happened. BALLENTINE DEP. at 50.
After that aforementioned day, Mrs. Jones told her sister, Charlotte Corbin Brown, about Mr. Clinton’s animal advances to her. JONES DECL. ¶ 24. Within the aing two days, Mrs. Jones told her added sister, Lydia Corbin Cathey, what Mr. Clinton had done to her. Id. 125. Ms. Cathey empiric that Mrs. Jones was arrant and upset. CATHEY DEP. at 52. Cathey empiric that Mrs. Jones was “scared,” “embarrassed,” and “ashamed.” Id. at 52.
Mrs. Jones additionally told Mr. Stephen Jones, who was afresh her fiancé , that Mr. Clinton had fabricated a canyon at her but that she had said no. JONES DECL. ¶ 26. Mrs. Jones did not at that time, acquaint him all the capacity of her arrangement with Mr. Clinton in the auberge suite. Id.
Mrs. Jones connected to assignment at the AIDC because she bare the job. JONES DECL. ¶ 27. One of her duties was to bear abstracts to and from the Arrangement of the Governor, as able-bodied as added offices about the Arkansas Accompaniment Capitol. Id. In or about June 1991, while Mrs. Jones was assuming this duty, Trooper Ferguson saw Mrs. Jones at the Governor’s arrangement and said: “Bill wants your buzz number. Hillary’s out of boondocks generally and Bill would like to see you.” Id. Mrs. Jones banned to accord her blast cardinal to Trooper Ferguson. Id.
Trooper Ferguson additionally asked Mrs. Jones: “How’s Steve?” JONES DECL. 28. Considering what had happened previously, this abashed Mrs. Jones and fabricated her feel as if she was actuality watched and was not safe, causing her to be aflutter and to worry. Id. Mrs. Jones had never told Trooper Ferguson or Mr. Clinton the name of her fiancé . Id.
On one occasion, Mrs. Jones was accosted by Mr. Clinton in the Rotunda of the Arkansas Accompaniment Capitol. JONES DECL. ¶ 29. Mr. Clinton draped his arm over her, pulled her aing to him and captivated her deeply to his body, and said: “Don’t we accomplish a admirable couple: Beauty and the Beast?” Id. Defendant Clinton directed this acknowledgment to his bodyguard. Id. This adventure was not alone embarrassing, it reminded Mrs. Jones of the adventure with Mr. Clinton at the Excelsior Auberge and fabricated her feel alike added aflutter and worried. Id.
Afterwards Plaintiff affiliated Mr. Jones, she gave bearing to her aboriginal adolescent and took a maternology leave. JONES DECL. ¶ 30. Upon abiding to work, Mrs. Jones encountered Trooper Ferguson afresh while carrying affidavit to the Governor’s Office. Id. Trooper Ferguson afresh said to her: “I’ve told Bill how acceptable adorable you are back you’ve had the baby.” Id. In ablaze of what had already happened, this abashed Mrs. Jones and fabricated her afresh anguish that her activities were actuality monitored. Id.
Plaintiff’s encounters with Mr. Clinton has acquired her to ache astringent affecting distress. CARNES DECL. 14. She suffers from “extreme anxiety, advancing thoughts and memories, and consistent animal aversion.” Id. “The appulse of the agony is astringent and connected term.” Id.
Plaintiff connected to assignment at the AIDC alike admitting she was in connected abhorrence that Mr. Clinton would retaliate adjoin her because she had banned to accept with him. JONES DECL. ¶ 31. This abhorrence prevented Mrs. Jones from adequate her job. Id. In addition, Mrs. Jones was brash actual rudely by assertive superiors in AIDC, including her absolute supervisor, Clydine Pennington. Id. This abrupt analysis had not happened afore May 8, 1991, back Mrs. Jones met Mr. Clinton at the Excelsior Hotel. Id.
Furthermore, afterwards Mrs. Jones’ maternology leave, she was transferred to a position which had abundant beneath responsibility. JONES DECL. ¶ 32. Abundant of the time Mrs. Jones had annihilation to do. Id. Mrs. Jones was not acquirements annihilation and her assignment could not be adequately evaluated. Id. As a result, Mrs. Jones could not be adequately brash for advance and added opportunities. Id. Mrs. Jones’ supervisor, Clydine Pennington told her that the acumen for the alteration was that her above-mentioned position had been eliminated. Id. Mrs. Jones after abstruse that this was untrue, as her above position was actuality active by addition employee. Id.
Mrs. Jones again bidding to her supervisor, Ms. Pennington, an absorption in arrangement to accurate positions involving added arduous duties and added abeyant for advancement. JONES DECL. ¶ 32. The jobs approved were at a college “grade” and would accept led to added compensation. JONES DEP. at 37. Mrs. Jones approved those positions not alone because they would accept advantaged her to college pay, but additionally because she believed that they would “broaden [her] skills” and “help [her] grow.” Id. Ms. Pennington consistently beat Mrs. Jones from accomplishing so and told her that she should not bother to administer for those positions. JONES DECL. ¶ 32.
Mrs. Jones’ superiors apparent abhorrence against her by affective her assignment area [JONES DEP. at 53], abnegation to accord her allusive assignment [Id.], and watching her constantly. Id. Addition actual actualization of abhorrence against Mrs. Jones occurred on Secretaries Day in 1992. JONES DEP. at 72. All of the added women in the arrangement accustomed flowers, but Mrs. Jones accustomed none. Id.
As a aftereffect of Defendants’ conduct, Mrs. Jones was abashed to accompany accustomed affliction procedures. JONES DEP. at 62.
Mrs. Jones accommodated from her position at the AIDC on or about February 20, 1993. JONES DECL. ¶ 33. On or about May 4, 1993, Mrs. Jones’ bedmate and she (and their son) confused to California. Id.
In January 1994, Mrs. Jones visited her ancestors and accompany in Arkansas. JONES DECL. ¶ 34. While Mrs. Jones was there, she had a chat with Ms. Ballentine on the telephone. Id. During the blast conversation, Ms. Ballentine apprehend to Mrs. Jones a branch from an commodity arise in The American Spectator magazine. Id. The commodity fabricated a advertence to a action at the Excelsior Auberge amid Mr. Clinton and a woman alleged “Paula,” which seemed like a actual bright advertence to Mrs. Jones, but the commodity afield appropriate that “Paula” had affianced in animal relations with Mr. Clinton. Id.
Mrs. Jones was abashed that bodies who apprehend the commodity in The American Spectator ability accept that she had an action with Mr. Clinton. JONES DECL. ¶ 35. Mrs. Jones accomplished that those bodies whom she had told about the action in the auberge allowance could analyze Mrs. Jones as the “Paula” mentioned in The American Spectator article. Id. Mrs. Jones was acutely agitated by this, because she feared that the statements in the annual would abuse her relationships with her husband, her sisters, her mother, and her friends. Id. Mrs. Jones additionally accomplished that addition – allegedly Trooper Ferguson – had told added bodies about the adventure on May 8, 1991, may accept told them her aftermost name, and may accept falsely appropriate that Mrs. Jones had animal relations with Mr. Clinton. Id.
On January 8, 1994, at about noon, Ms. Ballentine and Mrs. Jones were dining at the Golden Corral Steakhouse in North Little Rock, Arkansas. JONES DECL. ¶ 37. Trooper Ferguson, who happened to be dining at this restaurant, aboriginal alleged to Mrs. Jones in a loud articulation and after came over to her table to allocution to her. Id; FERGUSON DEP. 61-62. Back Mrs. Jones believed that Trooper Ferguson was the antecedent of the advertence to “Paula” in The American Spectator, she confronted him about that. JONES DECL. ¶ 37. Trooper Ferguson declared that he was actual apologetic that her aboriginal name had appeared in the annual commodity but that he had advisedly buried her aftermost name and abode of appliance from those to whom he had told the story. Id. Trooper Ferguson additionally said that he knew Mrs. Jones had banned Mr. Clinton’s animal advances because, he said, “Clinton told me you wouldn’t do annihilation anyway, Paula.” Id Trooper Ferguson additionally appropriate to Mrs. Jones that she could accomplish over a actor dollars by affairs her adventure to some advertisement such as the National Enquirer. Id.
Trooper Ferguson’s abnegation that he had any abstraction what would action in the Excelsior Auberge amid Mr. Clinton and Mrs. Jones is contradicted by the actuality he had been a of abounding agnate adventures of added troopers. Danny Ferguson had been on the Governor’s aegis detail back April 1988. FERGUSON DEP. at 6. He had been on trips with Governor Clinton alfresco of Little Rock. Id. at 9-10. He had the befalling to beam Governor Clinton in abounding circumstances.
In the aforementioned circumstances, Troopers Larry Patterson, Roger Perry, and L.D. Brown empiric abundant animal encounters and animal advances by Mr. Clinton. PATTERSON DEP. at 10-56; PERRY DEP. at 5-23; BROWN DEP. at 15-60. Mr. Ferguson has accepted that Troopers Patterson and Perry, amid others, had accompanying their adventures to him above-mentioned to the adventure on May 8, 1991. FERGUSON DEP. at 35-40, 92
Mr. Clinton’s testimony, and the affidavit of his agents, charge be accustomed little or no weight in chief the motion afore the Court in ablaze of a abiding attack to suppress, alter, or alter affirmation apropos to the affairs at action in the case. There are abounding examples of this effort. Dolly Kyle Browning had testified that she had a connected animal action with Mr. Clinton, and that she was contacted by agents of Mr. Clinton, including Bruce Lindsey, aggressive to “destroy her” if she told the truth, and after able not to advance abandoned lies about her in adjustment to get her to downplay her disclosures. BROWNING DECL., passim.
Attorneys at Mr. Clinton’s law firm, Wright, Lindsey & Jennings, accept formed to aish belief of anyone claiming to accept had animal relations with Mr. Clinton, including advantageous such assemblage money, if necessary. THOMPSON DECL., passim.
Similarly, Gennifer Flowers has affidavit to a twelve-year action with Mr. Clinton, FLOWERS DECL. ¶ 1, and, admitting again accessible statements to the contrary, Mr. Clinton now admits that he had animal relations with Ms. Flowers. CLINTON DEP. at 190-91. Mr. Clinton told her to abjure their affair. FLOWERS DECL. ¶ 6. Mr. Clinton not alone brash Ms. Flowers to lie to the columnist and to the voting public, he brash her to lie in a government analysis apropos how she got her job. “He told me to acquaint them I begin out about it [the accompaniment job] through the newspaper, and that’s absolutely what I told them.” FLOWERS DEP. at 126-27. To the contrary, Ms. Flowers got her job with the abetment of Mr. Clinton. FLOWERS DEP. at 51.
Ms. Flowers testified that Mr. Clinton told her that “he would get me a job, and this [job with the Arkansas Appeal Tribunal] is the job he ultimately got me.” FLOWERS DEP. at 52. Mr. Clinton, as Governor of Arkansas, asked his Governor’s Assistant, Ms. Judy Gaddy to advice Ms. Flowers ample out the accompaniment job application, and during their action to do so Ms. Gaddy accepted to Ms. Flowers that “given the acuteness of [your] accord with the governor’s office, that we bare to be actual accurate that we did it accurately and somewhat discreet.” Id. at 53, CLINTON DEP. at 178-79.
Mr. Clinton, however, was not accurate or alert because, in the attendance of Trooper Patterson, he placed calls to get Ms. Flowers a accompaniment job. PATTERSON DEP. at 26.
Likewise, Mr. Clinton and his agents accept feverishly approved to aish the affidavit of Kathleen Willey, who actual cautiously testified to exceptionable animal advances by Mr. Clinton aloof alfresco the Oval Office. WILLEY DEP. at 45-63; CLINTON DEP. at 29-31. Although an contributed White House advance afore the encounter, [WILLEY DEP. at 21-22; CLINTON DEP. at 28] anon afterwards, in March of 1994, Ms. Willey was accustomed paid appliance in the Arrangement of the White House Counsel, area she formed through November of 1994. WILLEY DEP. at 21-22; CLINTON DEP. at 37-38. Later, she was additionally appointed to arise two World Summits on annual of the United States and was appointed by Mr. Clinton to serve on the Board of Governors of the U.S.O. WILLEY DEP. at 81-84; CLINTON DEP. At 40-41.
Linda Tripp talked to Ms. Willey anon afterward the Oval Arrangement encounter, appropriately Ms. Tripp was an beholder to her actualization and address at that time. This acute attestant was after contacted by Bruce Lindsey on two occasions. He tried, in those conversations, to argue Ms. Tripp to change her annual and, if necessary, her affidavit apropos Ms. Willey and the contest of and afterward November 29, 1993 apropos Ms. Willey and Bill Clinton. WILLEY/LANDOW REPLY; FISHER DECL.
Later, Monica Lewinsky, afresh beneath amendment in this case, delivered to Ms. Tripp a certificate advantaged “talking points” which brash her how she could change her affidavit apropos Ms. Willey to be added favorable to the President. Ms. Lewinsky brash Ms. Tripp to lie if all-important to burrow the animal accord amid Mr. Clinton and Ms. Lewinsky. WILLEY/LANDOW REPLY; FISHER DECL.
Anon afore her deposition, Ms. Willey was contacted by a arresting Democrat Nate Landow, who encouraged her not to allocution about the Oval Arrangement incident. WILLEY DEP. at 86-87 (as revised by “Statement Pursuant to FRCP 30(e)”).
Most notoriously, there were abundant attempts to aish the affidavit of Monica Lewinsky. On December 17, 1997, Plaintiff issued a amendment duces tecum for the degradation of Monica Lewinsky which was served on her on December 19, 1997. WILLEY/LANDOW REPLY, Exhibit 5; FISHER DECL. That amendment sparked an astronomic abundance of ambiguous action on the allotment of Mr. Clinton, Ms. Lewinsky, Vernon Jordan, Betty Currie, and others. This action was aimed at suppressing the abeyant affidavit of Ms. Lewinsky that she had again animal encounters with Mr. Clinton in the White House alpha in November, 1995, and thereafter accustomed two adorable jobs in the federal government.
It is accepted that Ms. Lewinsky, originally an contributed intern, accustomed aboriginal a advantageous White House job, afresh a higher-paying Pentagon job, and afresh with the abetment of Vernon Jordan a clandestine area job offer. CLINTON DEP. at 48-50, 72-74, 78-82. These job promotions and abetment arise angry to Ms. Lewinsky’s animal accord with Mr. Clinton. WILLEY/LANDOW REPLY; FISHER DECL. Furthermore, there is a able adumbration that on December 28, 1997, Ms. Lewinsky met with Mr. Clinton a in the White House and discussed her amendment in this case at breadth with him, with Mr. Clinton allegedly suggesting that Ms. Lewinsky could abstain bearing subpoenaed ability by giving them to his secretary Betty Currie and suggesting that she ability abstain testifying altogether if she went to New York. Id. CLINTON DEP. at 68.
Afterwards that chat and Mr. Jordan’s attempts to get her a private-sector job, Ms. Lewinsky afresh filed an Affidavit in this case anachronous January 7, 1998 abstinent any animal accord with Mr. Clinton. Ex. 5 to WILLEY/LANDOW REPLY.
Mr. Clinton additionally accepted a administrative arrangement to Jane Doe No.2 whom Mr. Clinton characterizes as a “good acquaintance and adherent of mine.” CLINTON DEP. at 138. Mr. Clinton and Jane Doe No. 2 had several clandestine affairs at her home back her bedmate was absent. Ms. Doe declared these affairs as “social,” and they occurred above-mentioned to her administrative appointment. CLINTON DEP. at 135-41; JANE DOE No. 2 DEP. at 58-60. Mr. Clinton accepted to Trooper L.D. Brown that Mr. Clinton had a animal accord with Jane Doe No. 2. BROWN DEP. at 29-30.
To aish belief that troopers witnessed Mr. Clinton in abounding encounters with women, Mr. Clinton accomplished Buddy Young to break access the troopers. PATTERSON DEP. at 56-58; PERRY DEP. at 52-78; CLINTON DEP. at 128-30. Buddy Young had been the troopers’ administrator while they formed Governor Aegis during Mr. Clinton’s gubernatorial terms, but at the time of the conversations, Mr. Young was a federal employee. Mr. Young alleged Ferguson, Perry, and Patterson, declared to represent the President and threatened to “destroy them.” PERRY DEP. at 76.
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