1. My name is Paula Jones. I am the plaintiff in the lawsuit styled Paula Jones v. William Jefferson Clinton and Danny Ferguson.

2. I married Mr. Stephen Jones on December 28, 1991, and have been married to him ever since then. Stephen and I have two sons. We live in Long Beach, California.

3. I was born and raised in Arkansas.

4. On or about March 11, 1991, I began work as an employee of the State of Arkansas, working for the Arkansas Industrial Development Commission (the "AIDC").

5. On May 8, 1991, the AIDC sponsored the Third Annual Governor's Quality Conference (the "Conference") at the Excelsior Hotel in Little Rock, Arkansas.

6. On that day, I worked at the registration desk at the Conference. Pamela Blackard ("Ms. Blackard"), another employee of the AIDC, worked with me at the registration desk.

7. A man approached the registration desk and told Ms. Blackard and me that he was Trooper Danny Ferguson ("Trooper Ferguson"), Governor Clinton's bodyguard. He made small talk with Ms. Blackard and me, during which he showed me that he was carrying a pistol. He then returned to Governor Clinton.

8. Later that day, Trooper Ferguson came back to the registration desk and handed to me a piece of paper with a number written on it. Trooper Ferguson told me that the number was a suite number in the Hotel and he said to me that the Governor would like to meet with me. I had never met or talked to Governor Clinton. The first time I had ever seen him in person was at the Conference.

9. Ms. Blackard, Trooper Ferguson and I then talked about what the Governor could want. I thought it was an honor to be asked to meet the Governor. Among other things, Trooper Ferguson stated: "We do this all the time."

10. I decided to go meet Mr. Clinton. Ms. Blackard told me that she would take over my duties at the registration desk.

11. Trooper Ferguson then escorted me to the suite whose number had been written on the slip of paper he had handed to me earlier. When I arrived at the suite, the door was slightly ajar. I knocked on the door frame, and Mr. Clinton answered. I went into the suite, while Trooper Ferguson remained outside.

12. Mr. Clinton shook my hand, invited me in, and closed the door.

13. We talked for a few minutes. Mr. Clinton asked me about my job. He told me that Dave Harrington (who at that time was in charge of the AIDC) was his "good friend."

14. Mr. Clinton then unexpectedly reached over to me, took my hand, and pulled me toward him, so that our bodies were close to each other. I removed my hand from his and retreated several feet.

15. Mr. Clinton approached me again, saying "I love the way your hair flows down your back" and "I love your curves." While saying these things, Mr. Clinton put his hand on my leg and started sliding his hand toward my pelvic area. I did not consent to him doing this. He also bent down to kiss me on the neck, but I would not let him do so.

16. I exclaimed, "What are you doing?" and escaped from Mr. Clinton's reach by walking away from him. I was extremely upset and confused and I did not know what to do. I tried to distract Mr. Clinton by asking him about his wife and her activities, and I sat down at the end of the sofa nearest the door. Mr. Clinton then walked over to the sofa, lowered his trousers and underwear, exposed his penis (which was erect) and told me to "kiss it."

17. I was horrified by this. I jumped up from the couch and told Mr. Clinton that I had to go, saying something to the effect that I had to get back to the registration desk. Mr. Clinton, while fondling his penis, said: "Well, I don't want to make you do anything you don't want to do." Mr. Clinton then stood up, pulled up his pants and said: "If you get in trouble for leaving work, have Dave call me immediately and I'll take care of it." As I left the room, Mr. Clinton detained me momentarily, looked sternly at me and said: "You are smart. Let's keep this between ourselves."

18. When Mr. Clinton referred to Dave Harrington, I understood that he was telling me that he had control over Mr. Harrington and over my job, and that he was willing to use that power. From that point I was very fearful that my refusal to submit to Mr. Clinton's advances could damage my career and even jeopardize my employment.

19. Mr. Clinton's advances to me were unwelcome. I never said or did anything to suggest to Mr. Clinton that I was willing to have sex with him. During the time we were together in the hotel suite, I resisted his advances although I was stunned by his totally unexpected advances and intimidated by who he was.

20. When I left the hotel suite, I was upset but I tried to maintain my composure. I saw Trooper Ferguson waiting outside the suite. He did not escort me back to the registration desk. I said nothing to him and he said nothing to me.

21. When I returned to the registration desk, Ms. Blackard immediately asked me what was wrong. After attempting to collect myself, I told Blackard much of what had happened, but I was too upset to tell her everything. She attempted to comfort me.

22. I left the Conference and went to the workplace of a friend named Debra Ballentine. I was still very upset, emotionally distraught and nervous. I told her that I wanted to talk to her about something that had just happened and wanted to discuss it someplace privately. Ms. Ballentine and I went to a private area in the office and talked for awhile, and then we went outside and talked for awhile. Although I was upset, as best as I was able I told Ms. Ballentine what had happened with Mr. Clinton in the hotel suite.

23. Ms. Ballentine urged me to report the incident to the police or to my superiors at the AIDC. I was afraid to do so because it was the State Police themselves who had just helped Mr. Clinton assault me, and because Mr. Clinton had just told me that the head of the AIDC was his "good friend." What had happened to me and what Mr. Clinton had said made me afraid to file charges or a grievance.

24. Later that same day, I told my sister, Charlotte Corbin Brown, about Mr. Clinton's sexual advances to me.

25. Within the next two days, I told my other sister, Lydia Corbin Cathey, and my mother, Delmar Lee Corbin, about what Mr. Clinton had done to me. When I retold what had happened, I became very upset as I relived the experience.

26. I also told Mr. Stephen Jones, who was then my fiancé, that Bill Clinton had made a pass at me but that I had said no. I did not, at that time, tell him all the details of my encounter with Mr. Clinton in the hotel suite.

27. I continued to work at the AIDC because I needed the job. One of my duties was to deliver documents to and from the Office of the Governor, as well as other offices around the Arkansas State Capitol. In or around June 1991, while I was performing this duty, Trooper Ferguson saw me at the Governor's office and said: "Bill wants your phone number. Hillary's out of town often and Bill would like to see you." I refused to give my telephone number to Trooper Ferguson.

28. Trooper Ferguson also asked me: "How's Steve?" Considering what had happened previously, this frightened me and made me feel as if I was being watched and was not safe, causing me to worry. I had never told Trooper Ferguson or Mr. Clinton the name of my fiancé.

29. On one occasion, I was accosted by Mr. Clinton in the Rotunda of the Arkansas State Capitol. Mr. Clinton draped his arm over me, pulled me close to him and held me tightly to his body, and said: "Don't we make a beautiful couple: Beauty and the Beast?" Defendant Clinton directed this remark to his bodyguard. This incident was not only embarrassing, it reminded me of the incident with Mr. Clinton at the Excelsior Hotel and made me feel even more fearful and worried. On another occasion when I was delivering something to the Governor's office, I saw Mr. Clinton outside the office. He patted me and said "how are you doing, Paula?"

30. After I married Mr. Jones, I gave birth to my first child and took a maternity leave. Upon returning to work, I encountered Trooper Ferguson again while delivering papers to the Governor's Office. Trooper Ferguson then said to me: "I've told Bill how good looking you are since you've had the baby." (During my deposition, I forgot about this conversation.) In light of what had already happened, this frightened me and made me worry that my activities were being monitored.

31. I continued to work at the AIDC even though I was in constant fear that Mr. Clinton would retaliate against me because I had refused to have sex with him. This fear prevented me from enjoying my job. In addition, I was treated very rudely by certain superiors in AIDC, including my direct supervisor, Clydine Pennington, and an indirect supervisor, Cherry Duckett. This rude treatment had not happened before May 8, 1991, when I met Mr. Clinton at the Excelsior Hotel.

32. Furthermore, after my maternity leave, I was transferred to a position which had much less responsibility. Much of the time I had nothing to do. When I was given work, it was more mundane and tedious than what I had been doing before. I was not learning anything and my work could not be fairly evaluated. As a result, I could not be fairly considered for advancement and other opportunities. Clydine Pennington told me that the reason for the transfer was that my prior position had been eliminated. I later learned that this was untrue, as my former position was being occupied by another employee. In addition, my workstation was moved to a position where I was under constant observation by Ms. Pennington.

33. I resigned from my position at the AIDC on or about February 20, 1993. On or about May 4, 1993, my husband and I (and our son) moved to California.

34. In January 1994, I visited my family and friends in Arkansas. While I was there, I had a conversation with Ms. Ballentine on the telephone. During the telephone conversation, Ms. Ballentine read to me a paragraph from an article published in The American Spectator magazine. The article made a reference to a meeting at the Excelsior Hotel between Mr. Clinton and woman named "Paula," which seemed like a very clear reference to me, but the article incorrectly suggested that "Paula" had engaged in sexual relations with Mr. Clinton.

35. I was afraid that people who read the article in The American Spectator might believe that I had an affair with Mr. Clinton. I realized that those people whom I had told about the meeting in the hotel room could identify me as the "Paula" mentioned in The American Spectator article. I was extremely upset by this, because I feared that the statements in the magazine would harm my relationships with my husband, my sisters, my mother, and my friends. I also realized that someone ­ probably Trooper Ferguson ­ had told other people about the incident on May 8, 1991, may have told them my last name, and may have falsely suggested that I had sexual relations with Mr. Clinton.

36. On January 8, 1994, at about noon, Ms. Ballentine and I were dining at the Golden Corral Steakhouse in North Little Rock, Arkansas. Trooper Ferguson, who happened to be dining at this restaurant with a woman he identified as his wife, first called to me in a loud voice and later came over to our table to talk to me. Since I believed that he was the source of the reference to "Paula" in The American Spectator, I confronted him on this matter. Trooper Ferguson stated that he was very sorry that my first name had appeared in the magazine article but that he had purposely concealed my last name and place of employment from those to whom he told the story. Trooper Ferguson also said that he knew I had refused Mr. Clinton's sexual advances because, he said, "Clinton told me you wouldn't do anything anyway, Paula." Trooper Ferguson also suggested to me that I could make over a million dollars by selling my story to some publication such as the National Enquirer.

37. What Bill Clinton did to me on May 8, 1991, and thereafter has caused me severe embarrassment, humiliation, grief, shame, anxiety, and fear. When I saw him after the incident, even on television, I recalled my experience in the hotel room on May 8, 1991, and became fearful and worried about losing my job. Even today I experience the same emotions when I see him on television or read an article about this case.

Court documents

Scandal in the Oval Office