ORAL DEPOSITION OF PAULA CORBIN JONES

   BY MR. BENNETT:

   Q. I'm sorry. If I forgot to ask you that question. I don't have as good a
   memory as your counsel. But who was your supervisor there?

   A. I'm trying to think. I don't remember who she was.

   Q. Do you remember what year you worked there?

   A. Probably 1988.

   Q. And you were fired from that job as well, weren't you?

   A. Well, it was actually a mutual thing, but yes. On the paperwork I
   believe it was that I was fired.

   Q. And the reason they gave you for firing you?

   A. For being late.

   Q. And you were late a lot, weren't you?

   A. Yes.

   Q. All right. After you worked at Dillard's, where did you work?

   A. Hertz car rental.

   Q. And where was that?

   A. At the Little Rock airport.

   Q. And how long were you employed there? Do you remember?

   A. About four months.

   Q. And what did you do there?

   A. I rented cars.

   Q. Okay. And you were fired from that job too; is that right?

   [skips pages 25-32]

   ...

   Q. And have you had an opportunity since you answered the
   interrogatories to review your employment records at AIDC?

   A. No.

   Q. You knew I'd be asking you questions today about your employment
   history at AIDC, didn't you?

   MR. CAMPBELL: Objection. Assumes facts not in evidence and

   BY MR. BENNETT:

   Q. Did you?

   MR. CAMPBELL: asks for speculation and conjecture as to what
   might be in the mind of another.

   BY MR. BENNETT:

   Q. I'm asking you what was in your mind?

   A. No.

   Q. You didn't think I would be asking you about your employment?

   A. I didn't really think about what you would be asking me.

   Q. Okay. Who did you first talk to about getting a job at AIDC?

   A. I believe it was Pam Blackard.

   Q. And is Pam the lady whose deposition was taken in these offices a
   short while ago?

   A. Yes.

   Q. And she's one of your best friends; is that right?

   [skips page 34]

   A. I have no idea.

   Q. All right. When did you start work at AIDC?

   A. I think it was March of '90.

   Q. March of '90?

   A. I'm not sure, actually. I'm really not.

   Q. Okay. Do you know how long you worked there?

   A. Two years.

   Q. And were you fired from there?

   A. No.

   Q. Did they force you out?

   A. In a way.

   Q. How?

   A. I could tell that there was I had applied for different other jobs
   within the agency and my supervisor would always try to discourage me,
   try to keep me over on that corner saying that I could grow and make
   something of myself if I stay over there and let her train me. And I never
   went anywhere. There was a lot of hostility it seemed between Cherry
   Duckett and I. She never would speak to me. I'd try to I'd talk to
   anybody, you know, very outgoing. I would try to talk to her. There's
   several things that I'm not a hyper one of those schizophrenics that
   thinks that's something's wrong all the time. And you can tell when
   there's a lot of static in an office place when you go there every day for
   two years.

   Q. Are there any other things you haven't just testified about? Tell me
   everything that causes you to think that they wanted you to leave. Is that
   what you are saying? They wanted you to leave?

   MR. CAMPBELL: Objection. Multifarious.

   BY MR. BENNETT:

   Q. Is that what you're saying? Are you saying that they wanted you to
   leave?

   A. I feel that they wanted to keep me in that area so I wouldn't get
   outside their little wing to where they could control me and make sure
   that I stayed right there and couldn't upgrade myself at all. Absolutely.

   Q. All right. Now who do you think wanted to control you?

   A. Either Dave Herrington or Cherry Duckett.

   Q. Did you ever talk to Dave Herrington?

   A. Very seldom.

   Q. Did Dave Herrington ever say anything to you to suggest that he
   wanted to control you?

   A. We never talked at length. It was just "hi" or something like that.
   That was it. Never had any conversations.

   Q. Okay. Well now, who else do you think tried to control you.

   A. Clydine Pennington.

   Q. And was she your supervisor for the whole two years you were
   there?

   A. Yes.

   Q. Why did Clydine Pennington want to control you, do you know?

   A. I don't know.

   Q. What specific job did you apply for?

   A. I applied for document examiner, document examiner, that was my
   initial thing that I had applied for.

   Q. And you got that job?

   A. Yes.

   Q. But you have indicated in your answer previous answers to me that
   in a way they wanted you out because you couldn't get certain positions
   you wanted. Did I understand you correctly?

   A. Correct.

   Q. And I'm asking you what those other positions were that you applied
   for that you didn't get. Would you give me specifics?

   A. It was a grade higher, that I could make more pay. It was something
   that I know that maybe could broaden my skills and help me grow and I
   would try to apply for them because document examiner was at the very
   low entry level and I wanted to try to grow. And each time I would try
   to do that, I would talk to my supervisor about it and she would always
   discourage me and make me believe that I could grow within the
   administrative services, which in fact I didn't. I got degrade
   downgraded.

   Q. All right. Now what higher grade were you trying to get to?

   A. Just the next grade. You know, there's always a pay level difference
   when you go to another step and another grade and that's want I was
   wanting.

   Q. What was that grade?

   A. I really don't know. It was higher than the grade that I was at and I
   don't remember what grade level I was at when I was hired.

   Q. Do you know what grade level you were at?

   A. No.

   Q. And you don't know what the higher grade level was?

   A. No. Ten or 11 maybe. Ten or I don't recall exactly how it went
   now.

   Q. Do you know what the qualifications were for the next higher grade?

   A. Yes.

   Q. What were they?

   A. Well, it was the qualifications that I knew that I could that I was
   qualified for. It was for typing and different things. It just had a higher
   grade level. There might not have been much of a job difference or in
   your job duties, but it would have a higher grade level. According to
   which position of the building, you know, an area that it was in.

   Q. Did you ever write a letter or a request to any or your supervisors
   asking that you be permitted to apply for a higher grade?

   A. I don't know if I put it in writing to Clydine Pennington, but I know I
   did two different times orally went into her office and asked her and told
   her what I would like to do, would it be okay with her, because I felt
   that I wanted to tell her instead of just leaving out of the department
   without her knowing. I was trying to be nice to her. And she would
   always discourage me. "No, you stay over here. We want to keep you
   over here. We like you. We want you to stay over here. You will grow
   with us. You stay over here and we'll teach you everything." That's how
   she would get me to stay. But then when I stayed, nothing ever
   happened.

   Q. All right. Now when was the first conversation you had with Ms.
   Pennington, do you remember?

   A. No.

   Q. Do you remember when the second one was?

   A. No.

   Q. Do you remember exactly what you said to Ms. Pennington on either
   of those occasions?

   A. What I repeated just a minute ago.

   Q. Do you remember exactly what she said to you?

   A. Yeah. She would tell me, "We like you over here. We want to keep
   you over here. We want to if you stay over here, Paula, we can train
   you and help you grow with the company and we want to keep you over
   here." She would put it that way.

   Q. Now on July 1st, 1991, you received a cost-of-living increase, didn't
   you?

   A. Probably. I don't know what date it was. But I know I received what
   everybody else got each year.

   Q. Now also on July 1st, 1991, you were upgraded from a Grade 9 to a
   Grade 11, the very grade you mentioned, weren't you?

   A. I don't recall.

   Q. Well, do you dispute that that's what the record show?

   MR CAMPBELL: Objection. No foundation. No evidence in the record.

   BY MR. BENNETT:

   Q. Do you dispute you can answer.

   A. No.

   Q. So you did get a Grade 11, didn't you?

   A. That's what I'm saying. I don't really know how the grades went. I
   don't know how the grades went. I don't know what I came in as and I
   don't know what I left as. So I don't know.

   Q. Well, you went from, on July 1, 1991, according to the records, you
   went from a Grade 9 to a Grade 11. Did you ever apply for a grade 12
   or 13 or 14?

   MR CAMPBELL: Objection. No foundation. No evidence in the record.

   BY MR. BENNETT:

   Q. Did you ever apply for a grade higher than 11?

   A. Yes. I believe I did.

   Q. When?

   A. I don't know. I just those few times when I would talk to Clydine
   and she would say that, I would go ahead and fill out an application
   maybe or something.

   Q. All right. And on March 11th, 1992, you received a merit increase?

   A. Um-huh.

   Q. Didn't you?

   A. Probably. That's what everybody else received too.

   Q. And on

   A. Cost-of-living-raise.

   Q. And on July no. I said merit increase.

   A. Oh, I don't what that is.

   Q. You know there's a difference between a merit increase and a
   cost-of-living increase, you know that?

   A. No.

   Q. You don't know that you got both cost-of-living increases and merit
   increases when you worked at AIDC?

   A. I don't know if I did or not.

   Q. You resigned on February 2nd, 1993; is that correct?

   A. Yes.

   Q. You weren't fired, were you?

   A. No.

   Q. You weren't terminated, were you?

   A. No.

   Q. At no time that you worked for AIDC did you ever get demoted in
   pay, did you?

   A. I'm not sure actually. I don't think so.

   Q. Did they ever decrease your grade at any time at AIDC?

   A. I think they did.

   Q. When?

   A. When I came back from maternity leave.

   Q. All right. You think you went down in grade?

   A. I was thinking I did, yes.

   Q. What grade did you go down to?

   A. To like a 9 or 10 or something like that, it seemed like.

   Q. If I were to tell you that the records show that you didn't go down a
   grade, would you dispute that?

   MR. CAMPBELL: Objection. Assumes facts not in evidence. No
   foundation.

   THE WITNESS: Yeah.

   BY MR BENNETT:

   Q. You would dispute that?

   A. Yes, I would.

   Q. Do you know how much money you made before you went on
   maternity leave?

   A. No, I don't.

   Q. Do you know how much money you made after you came back from
   maternity leave?

   A. No, I don't.

   Q. At any time during the period you worked at AIDC, did anybody at
   AIDC ever mention to you the alleged incident with Governor Clinton?

   MR. CAMPBELL: Objection. Ambiguous, vague, global. There's a
   number of alleged incidents with Governor Clinton.

   BY MR. BENNETT:

   Q. On the incident the incident which allegedly occurred at the
   Excelsior Hotel on May 8th, 1991, did anybody at AIDC ever mention
   to you at any point in time while you worked there?

   A. Pam Blackard.

   Q. How did Pam Blackard know about it?

   A. Because she was there.

   Q. She wasn't in the room, was she?

   A. No. But she was at the conference and knew what had took place
   that day.

   Q. But you told Pam Blackard, didn't you?

   A. What went on in the room?

   Q. Yes.

   A. Yes.

   Q. You didn't tell her everything that went on in the room, though, did
   you?

   A. Yes. Eventually. Yes, I did.

   Q. At the time?

   A. Oh, no, not at the time.

   Q. All right. Now you were here for Pam Blackard's deposition, weren't
   you?

   A. Yes.

   Q. And did you hear Pam Blackard testify that she never told anybody
   at AIDC, that to swore her to secrecy, or words to that effect?

   A. Yes.

   Q. Do you believe Pam Blackard wouldn't have told anybody?

   A. Yes. I believe that.

   Q. Other than Pam Blackard, did you tell anybody at AIDC?

   A. No, I did not.

   Q. All right. Now my question to you is, during the period of time that
   you worked at AIDC, did any of your supervisors or anyone else
   mention to you that they were aware of the incident which allegedly
   occurred in the room at the Excelsior Hotel?

   A. No.

   Q. Did anybody say to you that you weren't getting a promotion because
   you wouldn't give sex to Governor Clinton?

   A. No.

   Q. Did anyone ever say to you that if you gave sex to Governor Clinton
   that you would get promoted or get a raise or get a better job?

   A. No. But I'm sure they would never say that if they did know about it.

   MR. BRISTOW: Objection. It's not responsive.

   BY MR. BENNETT:

   Q. Do you know of anybody at AIDC who knew about this incident
   other let me finish other than Pam Blackard?

   A. Not to my knowledge. Personally, nobody mentioned it to me. That
   doesn't mean they didn't know.

   Q. You don't know of anybody, though, do you?

   A. Un-uh.

   Q. How did you and Ms. Pennington get along during the two years?

   A. At first we were I really liked her at first. She was really nice and
   everything. But it seemed like after a few months, it started changing.
   She was more not as friendly as she used to have been. She liked to
   talk too, you know. She had to go around to everybody's desk and chat
   and talk and stuff.

   Q. Did Ms. Pennington interview you for your job?

   A. Yes.

   Q. Did you tell Ms. Pennington at the time of your interview that you
   had been fired from these several jobs?

   A. If she asked me, yes, I did.

   Q. On the application there is a line asking you the reasons for leaving,
   wasn't there?

   MR. CAMPBELL: Objection. Objection. No foundation. Assumes facts
   not in evidence.

   BY MR. BENNETT:

   Q. Do you know if the application had a line where you were supposed
   to say why you left your prior employment?

   A. No, I don't know.

   Q. You didn't fill that out, did you?

   A. I don't know if I did or not.

   Q. Is it your testimony that if that you if Clydine Pennington asked
   you why you left those other jobs, you would have told her you were
   fired from some of them; is that correct?

   A. I would have told her, yes, if she asked me.

   Q. Did you tell Ms. Pennington that your experience in your other jobs
   was such that older women didn't like you?

   A. What are you referring to?

   Q. When you were interviewed by Ms. Pennington

   A. What older women?

   Q. Well, I don't know. I'm asking you. Did you ever tell Ms. Pennington
   that in your other jobs you had difficulty with other older women?

   A. In one job.

   Q. Which job was that?

   A. Hertz.

   Q. And what did you tell Ms. Pennington?

   A. I don't recall telling her anything actually.

   Q. Now when you left, do you remember AIDC do you remember
   the month and the year you left?

   A. AIDC?

   Q. Um-huh.

   A. I left in '93, probably February of '93.

   Q. You left right before your second anniversary; is that right?

   A. No.

   MR. CAMPBELL: Objection. Misstates the evidence in the record.

   BY MR. BENNETT:

   Q. You may answer the question.

   A. What anniversary are you talking about?

   Q. When did you start at AIDC?

   A. In March, I believe.

   Q. Of what year?

   A. Of '90?

   Q. '91.

   A. '91, something like that.

   Q. And you left when? In February of '93; is that right?

   A. I believe that's correct.

   Q. So had you stayed another month, it would have been two years
   there. That's what I meant by anniversary. Is that right?

   A. Yes. Yes. You're right.

   Q. And you indicated to people at AIDC that you were looking for
   federal employment; is that correct, when you left?

   A. No.

   Q. You never told anybody that?

   A. I never said that.

   Q. Did you tell people that you were moving because your husband's job
   had changed?

   A. Yes.

   Q. And who did you tell that to?

   A. I don't know. Just my friends and stuff probably and probably told
   my supervisor that I was going to quit.

   Q. And what reasons did you give them for quitting?

   A. Because my husband got transferred and we were moving to
   California.

   Q. Was that true?

   A. Absolutely.

   Q. Now in the last few days at AIDC, you got in a big argument with
   Ms. Pennington about taking leave without pay; is that correct?

   A. No. I don't recall that.

   Q. Do you remember having an argument with anybody about your
   taking leave without pay?

   A. No. I don't recall that.

   Q. Do you remember calling Ms. Pennington a bitch?

   A. I've never called her that.

   Q. Do you remember yelling at her and telling her that she and AIDC,
   you'd get even with them?

   A. No. Are you talking about this while I was still working with her?

   Q. Right at the end, yeah.

   A. No. This is after I quit.

   Q. Oh. tell me about that.

   A. This incident took place after I quit.

   Q. Okay. Tell me what happened.

   A. This is when I went back to clean out my desk after I had done quit
   AIDC. I had a confrontation with Dave Herrington and Clydine
   Pennington. I brought them both together so I could express the feelings
   that I had encountered while I was working there of how I felt that I was
   being treated, mistreated. And that's where that incident took place.

   Q. Tell me, where did this take place?

   A. Out in the kind of like a hall area. There was a whole bunch of like
   dividers and stuff. It wasn't like office rooms. And I just did it right out
   there.

   Q. And what did you say to Mr. Herrington and Ms. Pennington?

   A. I explained to Mr. Herrington, whether he was aware of it or not,
   how Ms. Pennington treated me and that she was I always tried to get
   jobs. I brought that up. And nobody would let me try to get another job
   and better myself. And I just spewed on them really. Because I was just
   very upset from how I had been treated up there by trying to better
   myself.

   Q. What do you mean you "spewed on them"?

   A. Well, just I was upset and I was telling them and I wanted Mr.
   Herrington to know how Ms. Pennington was and I didn't feel that Ms.
   Pennington was a very good supervisor and I was just telling I don't
   recall everything that was said. I just know that I wanted Mr. Herrington
   to know what Clydine Pennington, how I felt about the way I had been
   treated over in that section, whether he was aware of it or not, I wanted
   him to know that before I left the building.

   Q. And did you yell in Ms. Pennington's presence?

   A. Oh, I'm sure I did raise my voice probably.

   Q. Did you use profanity?

   A. I don't recall if I ever used any curse words.

   Q. What did Ms. Pennington say when you spewed on her?

   A. She I think she tried to talk right back and defend herself and she
   got loud too as well. I think Mr. Herrington just kind of was shocked and
   surprised and was listening to both sides of it and everything.

   Q. What did Mr. Herrington say?

   A. I don't recall. I just know that he wished me well and that he was
   sorry that it turned out the way it did. That's what he had said.
   Something to that effect.

   Q. You had quit some days before; is that right?

   A. Yes.

   Q. Do you remember how long before?

   A. Maybe a few days or so before.

   Q. Had you given them notice that you were going to quit because of
   you husband's transfer to California?

   A. If I recall, it seems like they gave me a going away party thing. Yeah.
   They have it in a conference room and people in the thing, they had
   cake or whatever to wish me well or whatever.

   Q. So you had told somebody that you were quitting and leaving?

   A. Oh, yes. Yes. I told Clydine about the possible move.

   Q. And what did she say to you?

   A. I don't recall what she said to me.

   Q. Tell me a little bit about this going-away party.

   A. They would just have like snacks and different people from each
   section would bring snacks or dip or something and they would say
   good-bye and that would be about it.

   Q. Was Ms. Pennington there?

   A. I'm sure. I don't know. I don't recall. I'm sure she was.

   Q. A lot of people were there?

   A. I think so.

   Q. Have a good time?

   A. In and out. In and out. I mean, there wasn't a whole bunch of people
   there at one time.

   Q. Have a good time at the party?

   A. I don't recall. It wasn't a party. It was just, you know, to say bye and
   everybody to eat, you know.

   Q. But it was a friendly gathering?

   A. Yes.

   Q. Was Pam Blackard there?

   A. I don't recall.

   Q. During this incident that you described where you spewed on Ms.
   Pennington, do you recall yelling at Mr. Herrington?

   A. No. I don't think so. He was just listening. I was voicing to him how
   she how I felt the way I had been treated by Ms. Pennington and he
   was very nice to listen.

   Q. You didn't mention anything at that time, did you, about this alleged
   incident which occurred at the Excelsior Hotel with Governor Clinton?

   A. Oh, no.

   Q. Now tell me about your maternity leave. Just how many maternity
   leaves had you taken?

   A. One.

   Q. For just one child?

   A. Right.

   Q. The second child was born after you left; is that right?

   A. Yeah. A long time after.

   Q. And when you returned to work after maternity leave, did your duties
   change?

   A. Yes, they did.

   Q. Tell me how your duties changed.

   A. I know I read the Arkansas handbook, state employee Arkansas
   handbook, before I left on maternity leave and I know I had six weeks.
   Well, in the Arkansas handbook under maternity leave, it stated that you
   are to return back to your same position after six weeks' leave and unless
   there was a reduce in staff or something like that. I don't remember the
   exact words. And when I came back, none of them called or nothing like
   that. I don't think I ever received a call from Clydine Pennington or
   anybody to tell me they were making changes while I was no longer
   while I wasn't there. And when I came back, I no longer was at my
   desk. They had moved me completely to sit right outside Clydine's
   office, so she could watch me at all times. I was sitting right out front.
   And I didn't have any work to do. My work had been gone. I was sitting
   there doing nothing.

   Q. All right. Now you learned when you went back that there had been
   some structural changes at AIDC, didn't you?

   A. Like structural, what changes, what do you mean? As far as

   Q. That they had made some changes in functions in departments.

   A. No, not that I know of. Just maybe just mine. Just mine.

   Q. Well, did you learn that they consolidated purchasing department
   responsibilities?

   A. That's what they did, yes. Because that's what I was doing.

   Q. And now, Mrs. Jones, isn't it a fact that when you came back, there
   was no change in your salary, was there?

   A. No, there was not.

   Q. There was no change in you supervisor, was there?

   A. No. But I would just wonder why they would

   Q. There was no change in your title, was there?

   A. move me.

   MR. CAMPBELL: Objection, counsel. Let the witness finish her
   answer.

   BY MR. BENNETT:

   Q. I'm sorry. I apologize.

   A. Yeah, there was. I don't know what I was called. Probably a nobody
   sitting out in front of Clydine's office. Because Pam Hood got my job.
   And what is amazing to me is why it took place while I was on six
   months maternity leave when they could have done it before or after
   when I could have been there. They did it while I was away and
   unaware of what was going on.

   Q. What was your title before you went on maternity leave?

   A. Purchasing assistant.

   Q. What was your title when you came back?

   A. I don't know. I was not the purchasing agent anymore.

   Q. Well, you still worked on purchasing things, didn't you?

   A. No. I don't believe I did. That was all given to Pam Hood.

   Q. Didn't you work on data both before and after you the input of
   data?

   A. No. Actually I worked for personnel at that point. I input applications
   that were brought in to AIDC for employment and that's what I did all
   day long. I sat there and input applications into the database. That's all I
   did.

   Q. That's when you came back?

   A. Right. I did no longer do purchasing at all.

   Q. But when you were working in purchasing before you left, you were
   putting purchasing order, that's data input

   A. Right.

   Q. involving purchasing orders, right?

   A. Um-huh.

   Q. Is that correct?

   A. Um-huh.

   Q. You have to answer it

   A. That was my job. Oh, I'm sorry. Yes.

   Q. So in both instances, you were doing data input; is that right?

   A. Yes. But that was not my job title before I left. I had I was a
   purchasing assistant. When I came back, I was no longer dealing with
   purchasing department, period. Without me transferring or asking to be
   moved, I was moved without anybody asking me if that's what I wanted
   to do.

   Q. Now did you know what Pam Hood's title was?

   A. She was the purchasing I'm not really sure. Something with
   purchasing. She did all the major orders for the office supplies and stuff.

   Q. And are you aware that she applied for that job?

   A. That she did?

   Q. Um-huh.

   A. No.

   Q. How did you get along with your co-workers at AIDC?

   MR. CAMPBELL: Objection. Overbroad and global.

   THE WITNESS: In general just, you know, the ones that I liked, I
   mean, we got along pretty good. I talked to everybody around.

   BY MR. BENNETT:

   Q. Were there any there that you didn't get along with particularly?

   MR. CAMPBELL: Objection. Overbroad as to time.

   BY MR. BENNETT:

   Q. During the two-year period that you worked there.

   A. Not really. Just, you know, working in a place for a while, there's
   always going to be talk or, you know, something, but, no, I can't think of
   anything specific.

   Q. Did Ms. Pennington during the two-year period ever criticize you or
   reprimand you for any of you activities?

   A. I don't recall at this moment. I don't recall right at this moment if she
   did or not.

   Q. Did she ever reprimand you about your tardiness?

   A. No.

   Q. In two years, she never reprimanded you about your tardiness?

   MR. CAMPBELL: Objection. Asked and answered.

   MR. BENNETT:

   Q. You can answer.

   A. She may have talked to me about it, but I never got anything, I don't
   think any paperwork, or anything written up as far as I remember.

   Q. I'm not asking you about paperwork. I'm asking you

   A. Okay. Yeah. She talked to me about it. She was late herself and she
   would bring me in there, "I know. I'm late too. I live out there by you
   and we have that long traffic," she said, "and I'm guilty of it too," she
   said, "but we've got to get us here, you know, sooner," or whatever and
   that's what the conversations, how they were.

   Q. And she reprimanded you several times about your being late; isn't
   that right?

   MR. CAMPBELL: Objection. Misstates the prior testimony.

   MR. BENNETT: I'm not trying to state prior testimony.

   BY MR. BENNETT:

   Q. Didn't she reprimand you several times?

   MR. CAMPBELL: Same objection.

       BY MR. BENNETT:

   Q. You may answer.

   A. I don't recall.

   Q. Did Ms. Pennington ever criticize you or reprimand you about the
   way you dressed?

   A. No.

   Q. Did anybody ever reprimand you about the way you dressed?

   MR. CAMPBELL: Objection. Overbroad as to time and place.

   BY MR. BENNETT:

   Q. You know the place I'm talking about, don't you?

   A. What are you talking about?

   Q. AIDC.

   A. Oh, yes.

   Q. And you know the time I'm talking about, don't you? The two years
   you worked there?

   A. Um-huh.

   Q. Okay. Now, did anybody in those two years ever complain about
   how you dressed or criticized how you dressed?

   A. No. As a matter of fact, even Dave Herrington I remember him one
   time saying how really nice I always tried to dress and everything when I
   was up there. And after I had the baby, I remember him commenting on
   how I had gotten back down my weight back down and how nice I
   was looking.

   Q. Did anybody ever criticize you while you were at AIDC during that
   two-year period about talking too much, gabbing too much?

   A. Oh, I'm sure I got a lot of trouble I'm sure I got in trouble for
   talking. But I never got like paperwork, I mean, like stuff like that. Just
   they would she would talk to me.

   Q. Right. They gave you a break on these occasions. They never
   formally punished you, did they?

   A. Well, they would I don't think. I don't know if there was a formal
   procedure to formally punish you if you were talking, but I know that
   they would talk to me about it.

   Q. Who's "they," other than Ms. Pennington?

   A. Clydine Pennington. That would be who I was talking about.

   Q. And during the period of time you worked for AIDC for that two
   years, one of you primary functions was to deliver as a courier to
   deliver things; isn't that right?

   A. That's correct.

   Q. And where would you deliver things to?

   A. All over the state Capitol grounds.

   Q. And that included the governor's office?

   A. Yes.

   Q. And did anybody during those two year period ever criticize you or
   complain to you about how long you took to do the runs?

   A. I believe I heard it before. But it was they were just speculating
   because they didn't know what my job duties were and my job duties
   were to stay in the spot I was going until I had to carry paper back. And
   if people didn't know exactly what my job duties was, they might have
   thought I was sitting there not doing nothing.

   Q. But you would go and you would make the runs, you would very
   often deliver things and chitchat with the people that you delivered them
   to?

   A. Yes.

   Q. And then didn't people criticize you for taking too long in you
   deliveries?

   MR. CAMPBELL: Objection. That's overbroad and vague as to
   "people."

   THE WITNESS: No. Not to me personally, no.

   BY MR. BENNETT:

   Q. Nobody ever

   A. No.

   Q. Let me finish. Nobody ever complained to you that you were taking
   too long in making your deliveries?

   MR. CAMPBELL: Same objection.

   BY MR. BENNETT:

   Q. Go ahead.

   A. My supervisor might have said something to me. Clydine Pennington
   may have. But I don't recall. She may have though.

   Q. Did Ms. Pennington ever warn you that if you took additional leave
   without pay that you might have disciplinary action imposed on you?

   A. I don't recall. Un-uh.

   Q. Do you remember an incident when on February 22nd, 1993, you
   told your supervisor that you needed to have leave without pay because
   you didn't have any running water in your house?

   MR. CAMPBELL: Objection. Assumes facts not in evidence. No
   foundation.

   THE WITNESS: I think that incident you're talking about was the gas
   was out. There was no hot water. It was when we moved from our
   home in Vilonia to a rental house in Jacksonville just for like a month, to
   move to make the move because we sold our home and we had to get
   out. And I didn't have any when I woke up to go to work to take a
   shower or whatever, there was no hot water so I couldn't go to work if I
   couldn't take a shower. It was real cold too. And that might have been
   the incident you're talking about. That's the only one I can think of.

   BY MR. BENNETT:

   Q. What did you do? Did you call Ms. Pennington?

   A. I don't recall. I may have. Or I may have talked to Sherry Enderle,
   who was her personal secretary.

   Q. And did you get in an argument about whether you should be given
   leave without pay for that reason?

   A. No, I don't think. You're allowed to have, I think, leave without pay.
   But you know leave without pay. But if you do it enough times, I think
   you can get in trouble for it. But I don't think I had done it at all or very
   often.

   Q. Now you were aware, weren't you, that AIDC had various complaint
   procedures which were available to employees if they had grievances.

   A. Yes. As a matter of fact, I thought about doing that before, but I was
   just kind of scared to do that.

   Q. You never filed any kind of grievance procedure during your two
   years at AIDC, did you?

   A. No.

   Q. Now since you have left AIDC, since you quit and went to California
   with your husband, have you applied for any other jobs?

   A. Yes. I was with a temporary agency when I first moved out there.

   Q. And what was the name of that agency?

   A. Oh, I don't even know. It's been like four years ago. I could not even
   tell you.

   Q. And did you get a job?

   A. Yes. I worked at the Sheraton. I think it was the Sheraton. I worked
   in the executive offices. I was the reception the main secretary out
   front, the receptionist.

   Q. Was that the Sheraton Hotel?

   A. Yeah. I was in the offices, though. I wasn't in the hotel part.

   Q. And where exactly that was?

   A. It was in Long Beach.

   Q. Excuse me?

   A. It was in Long Beach.

   Q. How long did you work there?

   A. Maybe a week or two. But it was because they were I was just a
   temp until they found a permanent replacement. Because I wasn't
   qualified for the job and I wasn't trying to get the job. They just needed
   a temp until they hired somebody qualified for the job.

   Q. All right. Did you ever apply for any other jobs after that?

   A. I don't believe so. Because after I got my paycheck for that one
   week, it was not feasible to work and pay day care when day care took
   up that whole week's pay.

   Q. How much pay did you get from them at the Sheraton?

   A. I don't recall. But I remember day care for that one week was like
   $124 for a week and I don't think I made a whole lot over that. And it
   just wasn't feasible for me to drive and take my son to day care and me
   work. It would eat up the money.

   Q. You made a lot less there than you did at AIDC, didn't you?

   A. No. I was making $9 an hour at the Sheraton for just a week.

   Q. So you were making more money

   A. For just a week, though.

   Q. I see. All right. Did you apply for any other jobs?

   A. I don't know if I did or not. I didn't apply. It's just that they would
   send me out, you know. Because they had my application at the
   temporary agency and they would send my application if they thought
   there was a job that I was interested in or something I

   Q. When is the last time you worked at a job other than

   A. The Sheraton.

   Q. other than being a mother of two children, which is a big job. I
   understand that.

   A. Right. The Sheraton.

   Q. Sheraton. So after you worked at the Sheraton, did you try to get any
   other employment?

   A. I went to another interview and I know they liked me the first time I
   went in. And they didn't call me back and then about a week later, they
   did call me back, and then they interviewed me again and they didn't hire
   me for some reason. I don't know.

   Q. And do you remember what year that was?

   A. It was the same year. Probably in '94, '93, early '94, before it was
   right after this the lawsuit, I remember. Because they were talking
   about it up there and stuff.

   Q. All right. Since you filed the law suit, have you applied for any other
   jobs?

   A. No.

   Q. Have you worked in any other jobs?

   A. No.

   Q. Do you have any intention of applying for any other jobs as you sit
   here today?

   A. Oh, not until my kids go to school.

   Q. And when will that be?

   A. Well, neither one are in school yet. My oldest starts next year
   kindergarten and my youngest won't start for five more years, I want to
   stay home with my children.

   [skips pages 66-67]

   Q. Mr. Campbell doesn't know. I guess he never bounces.

   MR. CAMPBELL: Objection to the sidebar.

   BY MR. BENNETT:

   Q. Did you ever bounce a check?

   MR. CAMPBELL: Same objection.

   MR. BENNETT: She knows what I mean, Mr. Campbell.

   MR. CAMPBELL: I don't need that either, counsel.

   MR. BENNETT: I mean, your silly objections, they're you're just
   trying to harass me.

   MR. CAMPBELL: I don't understand what you mean by bounce a
   check.

   BY MR. BENNETT:

   Q. Did you ever write a bad check at AIDC? A check where there were
   insufficient funds?

   A. I don't recall.

   Q. Do you recall an instance where you were asked to reimburse them
   for personal phone calls that you had made?

   A. Yes. As well as everyone else had to do that.

   Q. And did you give them a check for that, do you remember?

   A. Yes.

   Q. Do you remember if that check didn't go through for insufficient
   funds?

   A. It could have at one time or something, but I don't recall.

   Q. Do you remember asking for a picture of Governor Clinton from his
   office during one of your courier runs?

   A. No.

   Q. Do you deny that occurred?

   A. It occurred the way you said it, yeah. I deny that. Yes.

   Q. The way I said it?

   A. Yeah. They way you said it.

   Q. Well, do you have any recollection of asking anybody for a picture?

   A. No.

   Q. Did you get a picture?

   A. Carole Phillips.

   Q. Tell me about it.

   A. Had a picture signed for me and just gave it to me. Of course, she did
   not know about the incident because I never talked to her about this. But
   she had, I guess on her own doings, had a picture sitting there waiting on
   me, signed from the governor, thinking that I would be very excited to
   get that picture. She did that on her own freewill. But I don't even know
   if I took the picture. I think I may have because she did not know about
   what had happened.

   Q. And that was after the incident?

   A. Yes.

   Q. And do you remember signing a birthday card for Governor Clinton?

   A. I believe I did.

   Q. It's a big card?

   A. Yes. I believe I did.

   Q. And that was after the incident as well?

   A. Yes.

   Q. Wasn't it?

   A. Um-huh. The reason was Carole Phillips was so excited. "You've got
   to sign this. You've got to sign this." She was a very jovial person and I
   didn't want her to lead on that there was something wrong. So I said,
   "Well, okay. I'll sign it." And I just signed my name or whatever to it. I
   don't remember or whatever.

   Q. Did you write a note on it?

   A. I don't think so.

   Q. Now other than what you've already testified to this morning, can
   you identify for me any specific detriment or adverse action which you
   say you suffered at work because you refused to have sex with
   Governor Clinton?

   MR. CAMPBELL: Objection. Overbroad. Vague as to which work.

   BY MR. BENNETT:

   Q. You can answer.

   A. Just every day when I went there, it just seemed like there was a lot
   of smoke in the air, just cloudy, you know, the way my supervisor
   treated me. It was just a day-to-day thing. I know when I came back
   from maternity leave, I know they downgraded my job duties. Maybe
   not my pay but they did it knowingly, that I was coming back in six
   weeks. They could have done it before then or after I came back. They
   did that intentionally. Just the way, Cherry Duckett would walk right in
   front of me and I would look right at her and say, "Hi, how are you
   doing today," and she would hold her head down, "hi," and keep
   walking. That's not very professional. And that's not very nice, you
   know, if you've got employees working underneath you, it's good to be
   nice to them every day to make them feel comfortable about working in
   that area. And she made me feel so uncomfortable and I couldn't think
   of any other reason except for maybe that she knew about the incident.
   She was told to act like that.

   Q. Now do you have any reason to believe that any of these people
   knew about this incident?

   A. Well, Governor Clinton told me that Dave Herrington was a good
   friend of his and he appointed him to that job. So, yeah, I have every
   reason in the world to believe that they could have found known about
   it.

   Q. Well, we'll get to that. But when

   A. Well, I'm answering the question that you asked.

   Q. No, you didn't answer the question.

   MR. CAMPBELL: Yes, she did.

   THE WITNESS: Yeah, I did.

   BY MR. BENNETT:

   Q. The question is, you have described to me, Mrs. Jones, what you
   perceived as the attitude of people towards you.

   A. Right.

   Q. You were uncomfortable; is that right?

   A. Right.

   Q. Did any of those people ever mention the incident with Governor
   Clinton?

   A. No. But they wouldn't.

   Q. Did any of these people say anything to suggest to you that they
   knew about the incident?

       A. No. But like, for instance, one time on Secretary's Day, I'm a
   secretary and had been there nearly two years, and after the incident
   happened and everything, everybody in my section got flowers on
   Secretary's Day. I'm the only one out there did not get any flowers. And
   everybody noticed it and was coming around and saying, "That is so
   cruel of them. I cannot believe they did that to you." Now what other
   reason would they do that? Just to leave me out intentionally knowing
   that I'm a secretary. I'm sitting there. Things like that they would do.
   There had to be a reason for it. I know I wasn't doing anything wrong.
   So that's why I feel that there was things somebody knew something.
   And it's very, you know, I don't know for a fact that they knew about it.
   But there had to be something for me to be treated that way. And I
   know that he was good friends with Bill Clinton because it came out his
   mouth hisself.

   Q. Now what year was it you didn't get flowers on Secretary's Day?

   A. Probably '93. Or no, no, no, '92. I'm sorry.

   Q. Now you weren't a secretary, were you?

   A. Yeah. I was considered a secretary in none of the other people
   were considered secretaries except for Clydine's personal secretary. And
   even the accountant, even the insurance lady, everybody got flowers but
   me. I was the only one. My husband sent me flowers because it hurt me,
   so he sent me flowers and surprised me because nobody else bothered to
   send me flowers.

   Q. Did you ask anybody why you didn't get flowers?

   A. No. But people would come around and ask me, you know, "I can't
   believe," you know, they knew how Clydine was very kind of devious
   sometimes. They'd say, "I can't believe she did that. That was really
   mean." And I remember people around the office would come by and
   say, "I cannot believe you did not get flowers. That is so cruel and so
   cold."

   Q. Who is responsible for giving flowers out?

   A. Clydine Pennington.

   Q. Do you believe as you sit here today under oath that the reason you
   did not get flowers on Secretary's Day is because you would not engage
   in sex with Governor Clinton in May of 1991?

   A. I believe that has something to do with it, yes.

   Q. And what is the basis for what are the facts on which you base that
   belief?

   A. Because Bill Clinton said that him and Dave Herrington were really
   good friends and Dave Herrington, he said that he had appointed him to
   that position. And Clydine and Dave Herrington was Clydine's ultimate
   boss.

   Q. Other than Secretary's Day, did any of the employees ever get
   flowers or little gifts on other occasions?

   A. I think it was just Secretary's Day or maybe a birthday or something.

   Q. Did you ever get any birthday presents or gifts of any kind while you
   worked at AIDC?

   A. No. I don't recall at this moment.

   Q. You did have that going-away party, though, didn't you?

   A. I think it was a going-away party. I may be thinking about my
   maternity leave party.

   Q. But you had a party?

   A. Yes. It wasn't a party. It was a get-together.

   Q. Did anybody did Governor Clinton or anyone else at AIDC ever tell
   you that you had to submit to sexual advances of the governor in order
   to receive a job benefit?

   A. No.

   Q. Did anybody did the governor or anyone else tell you that the
   governor would use his relationship with David Herrington to penalize
   you? Did anybody ever say that to you?

   A. No. But nobody would say that.

   Q. Did the governor or anyone else tell you that your refusal to submit to
   sexual advances would cause you to lose your job or have a negative
   effect on your job?

   A. No.

   Q. Did anybody tell you the governor did the governor tell you or
   anybody tell you that he would use his relationship with Herrington to
   have you demoted or reduced in salary in any way?

   A. Yeah, he kind of made that statement. Clinton did.

   Q. What exactly was the statement he made?

   A. Well, when the incident happened in the hotel room, he reminded me
   that Dave Herrington was his good friend. If I had any trouble, have
   Dave Herrington call me immediately. I mean, how else would I take
   that? Why would he even mention it if he wasn't trying to make a point?

   Q. All right. Well, my question to you, though, was whether Governor
   Clinton or anyone else ever said that he would use the relationship with
   David Herrington to have you fired or demoted or

   A. Not in those words. Not in those words. But you can read between
   the lines, you know.

   Q. And that's what you're doing, you're reading between the lines?

   A. Well, because I know what he meant.

   Q. The fact of the matter is, Mrs. Jones, is following May 8th, 1991,
   you were not demoted or reduced in salary, were you?

   MR. CAMPBELL: Objection. Asked and answered.

   BY MR. BENNETT:

   Q. What's your answer?

   A. Yeah. After I come back from maternity leave, yes.

   Q. You didn't lose salary, did you?

   A. But I was demoted. I might have kept the salary, but I was demoted.

   Q. You believe your employment records, which you have not looked
   at, show you were demoted; is that correct?

   A. I don't know how they did it. I just know I was demoted. Everybody
   in the building probably knows I was demoted.

   Q. All right. Now do you know of any women at AIDC who benefited in
   their jobs because they were having sex with Governor Clinton?

   A. No, not to my knowledge.

   Q. Do you know any woman who got a raise or a job or a benefit of any
   kind because they were having sex with Governor Clinton?

   A. Are you

   MR. CAMPBELL: Objection. Overbroad and global as to "any women."

   BY MR. BENNETT:

   Q. Any of the women that you worked with.

   A. Are you talking about just within AIDC? Or other

   Q. Within AIDC, yes.

   A. Oh, not within AIDC, no, I don't know of any.

   Q. All right. Now let's go outside of AIDC. Do you know anybody who
   got a job because they were having sex with President Clinton
   then-Governor Clinton?

   A. Yes. From what I have been told.

   [ten lines are redacted]

   Q. Where did you get that information?

   MR. CAMPBELL: Objection to the extent that if you have to answer
   that question in a fashion that would reveal confidential communications
   with your counsel, I instruct you not to answer that.

   BY MR. BENNETT:

   Q. Other than learning that from your lawyers, you never heard that
   before, did you?

   A. Correct.

   Q. What's your answer?

   A. Correct.

   Q. Anybody else? Any other women?

   MR. CAMPBELL: Objection. Overbroad and global.

   MR. BENNETT: Do you want to take a break?

   MR. CAMPBELL: That would be great.

   (Off the record.)

   BY MR. BENNETT:

   Q. Mrs. Jones, on May 8th, 1991, you went to a room in the Excelsior
   Hotel where you met Governor Clinton; is that correct?

   A. That's correct.

   Q. And how long were you in the room total?

   A. Between 10 and probably 15 minutes.

   Q. And did you voluntarily go up to the room?

   A. With the guidance of a state trooper, yes.

   Q. And why did you go up to the room?

   A. Because I wanted to meet the governor and he wanted he asked to
   meet me.

   Q. And why did you want to meet the governor?

   A. Because it was exciting. I had never met the governor before. It's
   exciting. So I was going to go up there.

   Q. And I believe you've stated publicly that you thought maybe it would
   help you get a better job; is that right?

   A. That's correct.

   Q. How long were you in the room before you first saw the governor's
   exposed penis?

   A. Probably about five between five and six or seven minutes.

   Q. And how far were you away from the governor?

   A. He sat down right beside me.

   Q. So you were just a couple of feet away?

   A. Not even that far, I don't think. He sat right down nearly on top of
   me.

   Q. So he exposed himself while he was down on the seat with you; is
   that right?

   A. As he was sitting down, he pulled his pants down.

   Q. Oh, so you saw him pull his pants down?

   A. As he sitting down, I mean, it was real quick.

   Q. And he pulled his pants all the way down to his ankles?

   A. I know I saw his legs, so I think either to his knees or his ankles. I
   don't know.

   Q. Well, was his penis coming through his shorts or did he take his
   shorts off?

   A. He took his whole pants off. He was naked from here to

   (Pages 80 to 82 are missing)

   ... the governor's penis went into his body? Did you look at the whole
   penis?

   A. I just no. I didn't get down there and examine it, but you could see
   what I saw from across the room. Standing completely across the room.

   Q. How long would you say you looked at the penis?

   A. Five seconds.

   Q. Did he have his hands on it?

   A. Yes.

   Q. Did you ever see him without his hands on it?

   MR. CAMPBELL: Objection. Overbroad and global as to time.

   BY MR. BENNETT:

   Q. Did you ever see him

   A. No. I believe he had his hands on it most of the time.

   Q. And one hand or two hands?

   A. I think it seems like maybe, he put his hand over there to me to try
   to pull me to touch it or something, but I jumped up, so he didn't have
   time to even get me. So but he had his hands on it most of the time,
   either one or two.

   Q. Do you remember ever seeing his penis without his hands on it?

   A. Yeah. I saw it. Because when he pulled his pants down, I saw it
   without his hands on it and I saw what it looked like.

   Q. And then his one or two hands were on it?

   A. Yeah. Because he pulled his pants down with both hands and when
   he sat back, I mean, it's there and then he starts putting his hands all
   over it.

   Q. All right. And what was he doing?

   A. He was fondling himself.

   Q. Did he have an erection?

   A. Yes, he did.

   [17 lines missing, then skips pages 85-92 and 9 lines on page 93]

   Q. Now how long was it that you said you were in the room before you
   saw the exposed penis of the president of the governor?

   A. Five or six minutes. Five to seven minutes.

   Q. What did you do as soon as you saw that?

   A. I jumped up and I said, "I'm not that kind of girl," after I looked at it
   and he was trying to grab me. But, I mean, I went on ahead and jumped
   up and I turned around and that's when I that's the thing I drew there
   from this perspective of standing up, looking down on the couch at him.

   Q. So you didn't see it before you stood up?

   A. Yes. I looked at it. It was pointing my direction. But when I stood up,
   it was pointed to the left.

   Q. So then

   A. So.

   Q. You stayed in the room for another five or 10 minutes?

   A. Oh, no. I started to leave. And he pulled up and I was fixing to go out
   and I said, "I've got to be going. I've got to go back to the registration
   desk. I'm going to get in trouble." He pulled up, you know, stood up.
   And he was just red as he could be. You could tell I had embarrassed
   him so bad, because he probably expected me to do something. And he
   pulled up his pants, trying to situate himself. And I don't think he tucked
   in his pants. He just pulled them up and zipped his pants up, still with an
   erect penis.

   And he said, "Well, you know, if you have any trouble, I want you to
   have Dave Herrington call me immediately." And that was the second
   time he had mentioned Dave Herrington. And then I proceeded to go on
   to the door and he rushed up behind me. I started to open up the door,
   he put his hand on the door to where I could not open it up any further,
   and he stopped me and he says, "You're a smart girl, let's keep this
   between ourselves." And when I went out the door, the state trooper
   was there, which is Trooper Ferguson. And he was standing out there.

   Q. Are you saying that the governor did not let you go out the door?

   A. Not for a split second, yeah. He confined me for a moment to let me
   know that I'm a smart girl and let's just keep this between ourselves.

   Q. And the governor had his hand on

   A. On the door. When I opened the door, he stopped it, the back of the
   door, long enough to let me know what he wanted to tell me.

   Q. Now have you ever said that before?

   A. Yes, I have.

   MR. CAMPBELL: Whoa, whoa, objection.

   THE WITNESS: I'm sorry.

   MR. BENNETT: Could I finish the question?

   MR. CAMPBELL: Surely.

   BY MR. BENNETT:

   Q. In any of the many press conferences you gave, did you say that
   before?

   A. I don't recall if I have or not.

   Q. Did he let you go out the door?

   A. Yes. After he told me what he told me.

   Q. And what did you understand him to have meant by that?

   A. Well, he was threatening me. He said, "You're a smart girl. Let's keep
   this between ourselves." Apparently he didn't want this to get out.

   Q. Did you stay how long did you stay in the room after you saw the
   exposed penis?

   A. Minute and a half or something like that maybe. Because it took
   about two or three minutes to even just get back down to where my
   registration desk was because it's a big hotel.

   Q. No. I mean, outside the door of the room.

   A. How long did I stay

   MR. CAMPBELL: Objection. Vague.

   BY MR. BENNETT:

   Q. How long after you saw the exposed penis, how much longer did you
   stay in the room before leaving the room after you saw the exposed
   penis? Did you leave right away? Did you hang around for a couple of
   minutes?

   A. No, I did not hang around. He told me I was there long enough
   where he pulled his pants up. This couldn't have been 30 or 40 seconds
   or maybe a minute and he told me about Dave Herrington, if I have any
   trouble have him call, and then when I got to the door, he stopped the
   door long enough I don't know how long it took to do that but he
   stopped the door to tell me, "You're a smart girl. Let's keep this between
   ourselves." And then I left the room.

   Q. And Ferguson was right outside the door?

   A. Yes, he was.

   Q. Was he blocking the door?

   A. No.

   Q. Was the door locked when you went out?

   A. No. I don't believe it was.

   Q. Was the door locked when you went in?

   A. No. The door was ajar when I went in. It was cracked open.

   Q. And how did you get out the door? Did you just turn the handle and
   walk out the door?

   A. Yeah. After he tried to hold me in there for a few minutes.

   Q. Now you say he tried to hold you in there for

   A. Well, he held the door

   Q. Let me finish.

   A. for a few seconds.

   Q. Are you saying that he tried to hold you in that room for a few
   minutes? Is that what you're saying?

   A. I'll redo that. A few seconds. Long enough to tell me what he wanted
   to say to me.

   Q. Did you express to him in the room that you were concerned about
   being away from your desk?

   A. Yes.

   Q. What did you say?

   MR. CAMPBELL: Objection. Asked and answered.

   BY MR. BENNETT:

   Q. Go ahead.

   A. After, you know, when I said I had to be leaving, I said, "I'm going to
   get in trouble. I need to go back down to my registration desk." I had to
   find something to try to get away from him.

   Q. Is that when he said, "If you have any trouble"

   A. Have Dave Herrington, he would take care of it for me.

   Q. And you interpreted that as a threat?

   A. I interpreted that as that he's the governor and he can do what he
   wants to and he's got the power to do and if I got in trouble to have
   Dave Herrington, his good friend, call him and he'll just take care of it, if
   I got in trouble by my immediate supervisors where I was working at the
   hotel that day.

   Q. So in other words, you interpreted it as a threat rather than as his
   saying, "If you get in trouble with your bosses, I'll help you out?"

   A. Right.

   Q. And what did you say, if anything, to Mr. Ferguson, Trooper
   Ferguson, when you left?

   A. I didn't say anything to Mr. Ferguson. He was sitting down, as I
   recall, on a bench or a chair that had been put out there, waiting for, I
   guess, Bill to do his thing and when I walked past him, he looked up and
   give me a smirk.

   Q. Was he right outside the door?

   A. Oh, just a few feet away maybe. He was there guarding. Absolutely.

   Q. Well, was he sitting down?

   A. I think he was sitting down, yes. He was sitting down.

   Q. And how far away from the door was he?

   A. I don't know. A few feet maybe.

   Q. And you had no conversation with him at all?

   A. No. He looked at he looked at me, looked up at me

   [skips pages 99-100]

   A. Okay. He come over to the first time he come over to say anything
   to me and Pam Blackard was when Clinton was in the ballroom speaking
   and he come over just to chat or something and he said that he was the
   governor's bodyguard and I think he said what his name was. And we
   said, "Oh, do you have a gun?" Because he was in plain clothes and we
   wanted to know. He said yeah. So I think Pam said, "Well, let's see your
   gun" or whatever. And he pulled back his coat and he showed us his gun
   that he was carrying. And then I think he kind of walked away and it just
   some small chat or whatever. Because he was standing out there by
   himself. And we were out there.

   And then the second time was when he come to hand me a note and tell
   me that the governor wanted to meet with me and on the note was a
   four-digit number. I remember looking at it. He said, "The governor" I
   don't know if he used the word Bill or the governor "wants to meet
   with you in this room number."

   I said, "What for? What does he want to meet with me for?" And I was
   excited, though. You know, but I thought why would he want to meet
   with me? And I asked him that question as well as I voiced it to Pam.

   And he said, "It's okay. We do this all the time."

   And so then when he left I said, "Well, I'll think about it for a while."

       Discussed it with Pam. She said, "Good, maybe we can find a job.
   You know, maybe we can get a better job." And I'm not stupid, yeah, I
   was going to go up there and see if I could maybe get another job or find
   a way to put applications to better myself and to get another job, a
   higher-paying job. And I thought maybe I could help my friend out and
   stuff. And I was excited to meet the governor. So Pam said, "Now you
   go up there, I'm going to watch the desk and everything, but don't stay
   too long." That's why I know I was not up there longer than maybe, you
   know, 10 minutes at the most, up in the room itself, because Pam didn't
   want me to be gone very long either because she didn't want to get in
   trouble and have to explain to somebody where I was.

   That was the conversation that me and Ferguson had had. And then
   when he come back to see if I was going to go up there and then me and
   Pam had decided, yeah, I'll go up there and then me and Pam had
   decided, yeah, I'll go up there. So then he escorted me up and around
   the corner and up the elevator.

   Q. Now did you tell anybody downstairs why you were leaving the
   desk? Did you give any excuses to anyone

   A. I didn't.

   Q. as to why you were leaving the desk?

   A. Un-uh. I didn't talk to anybody about where I was going or what,
   except for Pam.

   Q. Do you know whether Pam did?

   [skips page 103]

   A. Yeah, He seemed like he was unloosening his tie as soon as I you
   know, he come to the door and opened it because it was already ajar and
   I knocked on the door facing and he opened up the door and it seemed
   like he was loosening his tie with one hand and he acted like he had
   known me for years. You know. Right off the bat. And I had never met
   the guy in my life. And he shook my hand. And he introduced hisself or
   whatever.

   Q. How did he introduce himself?

   A. "I'm Bill Clinton." I think it was that. I don't think he said, "I'm the
   Governor." "I'm Bill Clinton."

   Q. And then what happened?

   A. "Nice to meet you" or whatever. And then we proceeded to I
   proceeded to go on in. And went

   Q. Did you say something to him when he said, "Hi. I'm Bill Clinton"?

   A. I said, "I'm Paula Corbin" or whatever.

   Q. Okay.

   A. And I think he had said something about he asked me where I was
   worked and I told him I was over at AIDC and he said that he knew
   Dave Herrington was a good friend of his and he had appointed him to
   that job. And then when we went in, oh, a couple of minutes, we went
   over by the window and I remember looking out the window because
   there's a pretty view up there, because it was really high up. And that's
   when he ... made his first pass at me at the window.

   Q. Okay. Tell me exactly what he did.

   A. He sat down on the windowsill, leaned up against it with his bottom.
   And I was standing in front of him just talking because I was the one
   looking out the window. And he proceeded to he just reached right
   over while we were talking and we were just talking in general and I
   don't know what exactly everything we were talking about but nothing
   sexual. And

   Q. Do you remember anything you were talking about?

   A. I think we were talking about the job or whatever and about working
   with the state or something. I really don't know exactly, but it wasn't
   nothing bad that we were talking about. Because what was so shocking
   to me I'm sitting here talking to this man but nothing related to what's on
   his mind and he's over here while he's answering my questions pulling
   me over like he has done this a million times and grabs me and pulls me
   over to him to the windowsill and tries to kiss me and just didn't ask me
   or nothing. And I was just really shocked. And I pulled away. That was
   the first time I pulled away. I said, "No." I said, "What are you doing?"

   Q. Now he was still

   A. I was so scared and nervous.

   Q. Was his back to the window?

   A. Yes.

   Q. So why didn't you just go right out the door?

   A. You know what? This is the governor we're talking about. I had just
   met the man. A state trooper sitting outside the door with a gun. I know
   that. I'm terrified. And so what I'm thinking next is what was happening
   here and what am I going to do next to get out of the room? Is he going
   to stop here? I didn't know but that would be it. But the man kept on
   and on until he dropped his pants. That's why I didn't run out the door. I
   was scared.

   Q. After he made a pass at you, you didn't go right out the door, did
   you?

   A. No. Because the state trooper was out there and I knew he was out
   there. And I did not know but what they were taping and had him out
   there to all kinds of stuff was going through my mind. Because I'm
   thinking, this is not happening to me. This cannot be happening to me.
   And I thought if I run out that door, he's going to catch me, because Bill
   will know I'm fixing to run tell somebody. I'm not that stupid. I was not
   going to run out the door. I was scared to death.

   Q. So instead of running out the door, what did you do?

   A. I just moved away from him and got completely away from him. He
   was still sitting on the windowsill.

   Q. All right. Then what happened?

   A. And I went way over like to the middle of the living area. And I was
   talking to him about Hillary. I mean, I was just kind of trying to ignore
   what he had just done. And I was talking to him about Hillary and she
   was working with children's things or something, children's schools at the
   time, and I remember I was complimenting her on how she was really
   good with children. And the next, you know

   Q. Then what happened?

   A. I was he come over by the wingback chair close to where I was at.
   Then it's like he wasn't even paying attention to what I was saying to
   him. Then he goes, "Oh, I love the way your hair flows down your
   back. And I was watching you," and stuff like that. Downstairs. And
   then he did it again. Then he started he pulled me over to him while he
   was leaning up against the wingback chair and he took his hands and was
   running them up my culottes. And they were long. They were down to
   my knees. They were long, dressy culottes. And he had his hand up,
   going up to my middle pelvic area, and he was kissing me on the neck,
   you know, and trying to kiss me on the lips and I wouldn't let him. And
   then I backed back. I said, "Stop it. You know. I'm not this kind of girl."
   I mean. And it still and then I ran right over to where the couch was. I
   thought what am I going to do? I was trying to collect my thoughts. I did
   not know what to do. After the second time after the first time, I had
   rebuffed him. And then when I got over there and I kind of sat right
   there by the end of the couch on the seemed like on the armchair part.
   And the next thing you know it, I turn around because he was kind of
   back over here, and he come over there, pulled his pants down, sat
   down and asked me to perform oral sex.

   Q. What did he say exactly?

   A. He asked me would I kiss it. He goes you know, I can see the look
   on his face right now. He asked me, "Would you kiss it for me?" I mean
   it was disgusting.

   Q. Were those the actual words he used?

   A. Yes.

   Q. He didn't use other words?

   A. I think that was it.

   Q. Okay. What did you say?

   A. I said, "No. I'm not that kind of girl." And that's when I said, "I'm
   going to get in trouble. I've got to be going. I've got to get back to my
   registration desk." And then he said then he was you know, you
   could tell he was embarrassed and everything. And he was pulling up his
   pants. And he said, "Well, if you have any trouble, you have Dave
   Herrington call me immediately." And you could tell he was so
   embarrassed because of what he had just done, because I had rejected
   him.

   Q. All right. Now then you went downstairs and you told Pam part of
   this story; is that right?

   [skips pages 109-119]

   A. He wanted me to do something against my will.

   Q. That's not my question. Did he require you to do something against
   your will?

   A. Well, he tried to kiss me against my will. Is that what you're saying?
   I'm not quite sure.

   Q. You said when he

   A. Absolutely, but he still wanted me to do it. Three times he tried to
   make me do it against my will. I would say so after the first time of
   rejection, yes, he did.

   Q. Did he make you kiss his penis?

   A. No.

   Q. Did you kiss his penis?

   A. No.

   Q. All right. What other damages or injuries did you sustain?

   A. He threatened me about when I opened the door, he held his hand
   up there and said, "You're a smart girl. Let's keep this between
   ourselves." That's a threat. He don't want me to tell anybody.

   Q. Okay. What else?

   A. He told me about his boss my boss, ultimate boss was his dear
   friend and to me it seemed to me that if anything if I was going to get
   in trouble for anything whatsoever for being up there, his boss could
   have took care of it one way or the other, either got me fired or helped
   helped me not get in trouble for being away from the registration desk.
   That was a threat.

   Q. Okay.

   A. That was intimidation.

   Q. What other injuries?

   A. Just psychological of him dropping his pants and doing what he did. I
   mean there was a few minutes of conversation and the man dropping his
   pants. That's mentally abusive and I felt shame. I felt like I was the bad
   person after I left that room. I thought I was the bad person here and I
   was the one that was at fault for going up there and I would have never
   thought that I would have never expected that. I didn't expect to go up
   there with sex on my mind, but intentionally, he had that on his mind
   apparently or he would have never wanted to see me.

   Q. What psychological damage did you sustain? Could you be more
   specific?

   A. Absolutely. I mean I was horrified. I was I was scared to death. I
   would have to think about that. Every time I look at this man on TV I
   don't even look. I just turn it off because it brings back that terrible day
   of when I had to look at his private parts, a strange man without me
   asking for it.

   Q. All right. Now, have you ever consulted a psychiatrist for this?

   A. No.

   Q. Have you ever consulted a psychologist about this?

   A. No.

   Q. Have you ever had any medical bills as a result of this?

   A. No.

   Q. Has this affected your marriage?

   MR. CAMPBELL: Well, I will object to the extent that that would cause
   you to violate the husband/wife privilege. I will instruct you not to
   answer as to any private communications, verbal or non-verbal, between
   you and your husband.

   BY MR. BENNETT:

   Q. Are you making any claims in this case that either Danny Ferguson or
   Governor Clinton are responsible for any damages as it may relate to
   your marriage?

   A. No

   Q. Do you take medication?

   A. No.

   Q. Have you ever taken any medication because of this?

   A. No.

   Q. Have you ever had any psychiatric treatment

   A. No.

   Q. for any reason?

   A. I'm sorry. No.

   Q. Have you ever had any prior incidences in your life which have
   caused you emotional distress such as molestation or incest or date rape?

   A. No.

   Q. After the alleged incident, you never took any time off work because
   of it, did you?

   A. No.

   Q. Never had any physical ailments because of it, did you?

   A. Mentally, yes, thinking about it and when I would see the man on TV
   and then when he got reelected for President and I just couldn't
   understand how America could vote a man in for president, but they did
   not know what he did to me and I thought if they only knew what I
   know he's done and he's the President of the United States.

   Yeah, it caused emotional pain and stress, but I didn't want to go tell
   anybody about it because I just wanted to let it go away. I wanted to
   keep it a secret and not let anybody know about it.

   Q. Do you still have this emotional distress?

   A. Absolutely. Every time I see that man on TV.

   Q. Every time you talk about this incident or think about this incident, it
   causes you stress

   A. Emotional.

   Q. is that correct?

   [skips pages 124-225]

   [...]he's an actual police officer and whether he has a gun and that Pam
   wanted to see the gun; is that right?

   A. That's correct.

   Q. Was it Pam who asked to see his gun or was that you?

   A. I think it was her that asked, but I'm not for sure.

   Q. And he did open his coat in response to that banter and show that he
   had a gun; is that correct?

   A. Yeah. Well, I don't know if we asked I don't know if she asked him
   to show it or he said yeah and he just pulled back his coat and showed it
   to us.

   Q. Did you in any way take this to be intimidating or threatening or
   coercive in any fashion?

   A. Not at that point, no.

   Q. So this is just light banter between all the convention delegates are
   in the hall listening to the Governor speak and you and Pam are outside
   and I guess the only other person outside is Danny Ferguson. Is that
   your recollection?

   A. Yes.

   Q. Okay. So he's being friendly with you and you and Pam are being
   friendly with him?

   A. Right.

   Q. Okay. Now, how many minutes do you recall this conversation taking
   place?

   A. Five minutes or something because he wouldn't stay there the whole
   time.

   Q. In the in the context of this conversation with a man that you know
   to be Governor Clinton's bodyguard, did you make any statements about
   you would like to meet the Governor or had you hoped to see that
   Governor? Did you say something to that effect?

   A. No.

   Q. Did Mr. Ferguson say anything to you in this five-minute
   conversation about whether or not you would like to meet the Governor?

   A. Not at that conversation, he didn't.

   Q. Okay. All right. So in that five-minute conversation, nothing has
   nothing is said about you meeting him or him him wanting to meet
   you, talking about Governor Clinton; is that correct?

   A. Oh, I don't think so, not in that portion of it.

   Q. All right. Then how much time went by from this five-minute
   conversation until you saw State Trooper Ferguson again?

   A. I don't know. It could have been an hour. It was awhile.

   Q. Could it have been as little as 30 minutes?

   A. Yes. I really don't know. It was awhile though. I mean he didn't just
   hang around the whole time.

   Q. Okay. It could have been as little as 30 minutes.

   [skips pages 228-235]

   Q. Now, you say that he reached and pulled you to him. What part of
   your body did he place his hands on?

   A. He pulled my hands up to to pull me up to him.

   Q. All right. Now, did he in any way hurt your hands when he did that?

   MR. CAMPBELL: Objection, asked and answered.

   THE WITNESS: No.

   BY MR. BRISTOW:

   Q. Now, did he try when he pulled your hands toward him, did he try
   to kiss you at that time?

   A. He was just trying to hug up to me at that point and I said, "What are
   you doing?"

   Q. Okay. And what did he say?

   MR. CAMPBELL: Objection, asked and answered.

   THE WITNESS: I don't think he even answered me.

   BY MR. BRISTOW:

   Q. Then what did you do?

   MR. CAMPBELL: Objection, asked and answered.

   THE WITNESS: I proceeded to walk over to where oh, between the
   chairs and the couch, you know, closer to the end of the door, over in
   the middle of the living room and he walked over there towards me and
   he leaned up against the back of a wingback chair and then he started
   proceeding to tell me how he liked the way my curves and my hair was
   down my back and then that's when he pulled me up again. He was
   trying to run his hand up to the middle of my, you know, my pelvic area
   and he was trying he was kissing me on the neck and started to kiss
   me on the lips and I just I said, now, "what are you doing? Stop it. I'm
   not that kind of girl" or whatever. I said

   BY MR. BRISTOW:

   Q. How many times did you tell him that you were not that kind of girl?

   A. I think I said that twice.

   Q. And what provoked your saying that twice?

   A. Well, I wasn't that kind of girl to do that with a strange man that I just
   met within five minutes.

   Q. Well, what did you what did he do that caused you to say you were
   not that kind of girl? You say that you say that he put his hands up
   your culottes?

   A. Uh-huh.

   Q. What did he touch when he

   A. He was trying to touch my private area.

   Q. Well, did he do that?

   A. Well, he was on his way to trying. If I hadn't have stopped him, he
   would have.

   Q. And that's when you said that you were not that kind of girl?

   A. Absolutely.

   Q. Now, what else did he do when you said the second time that you
   were not that kind of girl?

   MR. CAMPBELL: Objection, asked and answered.

   BY MR. BRISTOW:

   Q. Go ahead.

   A. When he exposed himself to me and I got up off the couch, off the
   end of the couch and I said, "I'm not that kind of girl. I've got to be
   going."

   Q. Okay. And you said that at that point in time that you were only able
   to be away a short time, is that right; you might get in trouble at work

   A. Right.

   Q. if you didn't go?

   A. Right.

   Q. And at that point in response to that, what did he say?

   MR. CAMPBELL: Objection, asked and answered.

   THE WITNESS: Well, he said he said, "Dave Herrington is a good
   friend of mine" or whatever he said. "If you have any trouble, have your
   boss, Dave Herrington, call me immediately."

   BY MR. BRISTOW:

   Q. Okay. Now, at any point while you were in the room, did he say
   did Mr. Clinton say anything about Danny Ferguson?

   A. I don't recall, no.

   Q. Did you say anything about Danny Ferguson while you were in the
   room?

   A. No.

   Q. Now, you say that when you left the room that you saw Mr.
   Ferguson and did not have any conversation with him?

   A. That's correct.

   Q. And then you came back downstairs and you finished finished up
   your shift?

   A. That's right.

   Q. If the personnel records at AIDC indicate that you worked on
   Thursday and Friday and all the following week, you would not dispute
   that, would you?

   A. No.

   MR. CAMPBELL: Objection. No foundation, misstates the evidence in
   the record, no evidence in the record.

   By MR. BRISTOW:

   Q. And go ahead.

   A. That's correct.

   Q. You would not dispute that if that's what the record showed?

   A. No.

   MR. CAMPBELL: Same objections.

   THE WITNESS: No.

   BY MR. BRISTOW:

   Q. Now, in addition, when you went back to work, you continued to run
   the rounds as a courier which took you to the Governor's office; is that
   correct?

   A. That's correct.

   Q. Okay, And in fact, continued on a daily basis to go to the Governor's
   office; is that correct?

   A. Yes.

   Q. Now, when is the next time after the incident at the Excelsior that you
   spoke with Governor Clinton?

   A. After the incident at the hotel?

   Q. Yes.

   A. Let me get which one come first. I think it was it was when I was
   walking through the state capitol. I was on my way to the treasurer's
   office and to deliver or pick up some checks, payroll checks because that
   was my job too and they were Trooper Patterson and Clinton were
   walking up to the front of the state capitol and I was walking the
   rotunda is round, so I was walking this direction. They were coming up
   on the opposite side and he would have came, you know, back this way
   to go to the Governor's office. Instead, he hollered my name out and
   diverted and come back around this way and hugged me, put me in a full
   brace hug. And I don't think I hugged him back and then

   Q. Now, at that point in time, did you know who Trooper Patterson
   was?

   A. No.

   Q. So what you remember about this incident is that the Governor was
   accompanied by a trooper, correct?

   A. I knew his name was Roger.

   Q. Well, the trooper's name was Roger; is that right?

   A. Yes.

   Q. All right.

   A. I mean I'm sorry Larry. I get them confused.

   Q. Well

   A. I'm sorry.

   Q. Okay.

   A. Larry.

   Q. So all you really know is that the Governor had a trooper with him
   and you did not know the name of the trooper?

   A. Well

   MR. CAMPBELL: Objection, misstates prior testimony.

   BY MR. BRISTOW:

   Q. And you can go ahead. Isn't that at the time it occurred, going back
   to the time the incident in the rotunda occurred, at that point in time, you
   did not know who the trooper was, did you?

   Mr. CAMPBELL: Objection, Misstates prior testimony.

   BY MR. BRISTOW:

   Q. Go ahead.

   A. I knew who he was because Clinton looked at him and said, "Hey,
   Larry, don't we make a good looking couple?" So I knew what his first
   name was. I didn't know what his last name was though.

   Q. And you had never met that trooper before that occurrence?

   A. That's right.

   Q. All right. Now, what else did Governor Clinton say other than "hey,
   Larry, don't we make a good couple?"

   A. He said, "Hey, Larry, don't we make a good looking couple?" And he
   was hugging me side to side then and then he said, "We look like beauty
   and the beast." And I didn't know what to say. I looked up at him and I
   said, "You just don't you don't look like the beast." That was the only
   comment I made I made and I think Larry, he smiled or something.

   Q. Okay. And you said you don't know you remember him hugging
   you, but you don't know whether that you may have hugged him back?

   A. I don't think I did.

   Q. But you don't know one way or the other?

   A. No, I don't believe I did.

   Q. Okay, And everybody is smiling about this. Larry is smiling, the
   Governor is smiling and you were smiling; is that correct?

   A. I don't know if everybody was smiling or not.

   Q. Well, when you made the statement "you don't look like the beast,"
   you were smiling about that. It was all in a light vein; isn't that right?

   A. Yeah, probably, but I wasn't, you know, smiling real big or laughing
   or anything.

   Q. Okay. And then the Governor and Patterson walked off and you
   went on about your rounds; is that correct?

   A. Oh, well, Clinton made a point to tell me how he thought I looked
   that day.

   Q. What did he say?

   A. He said I looked really nice and he liked what I had on.

   Q. Okay. Anything else was said that day?

   A. And I think that was it.

   Q. Okay. All right. And what did you say when he told you that he
   thought you looked very nice and he liked what you had on? Did you
   say thank you?

   A. I don't know if I did or not. I could have said thank you, but I don't
   recall saying anything to him back.

   Q. But you may have thanked him and been polite?

   A. I may have.

   Q. Okay. Now, what is the next incident when you personally saw the
   Governor?

   A. Now, I don't know what time point in time this was, but one
   instance, I was in the Governor's office like I did every day. I would go
   there twice a day and sometimes I would have to wait. That was my job
   to wait, have documents signed by whoever was in the Governor's office
   and I was sitting in there one day right in a chair like this right at the door
   and there was windows right here, right at the door and I was probably
   chatting with Carole Phillips. We talked a lot and there was some bright
   lights coming and we looked behind and that was he was coming up
   there, Clinton was, and when he as soon as he walked in the door
   and this is probably on film somewhere. As soon as he walked in that
   door, he patted me on the thing. He said, "How are you doing, Paula?"
   He remembered my name again and that's on film somewhere.

   Q. Okay. Now, what did you say?

   A. I don't think I said anything or I may have said hi, but that's it.

   Q. All right.

   A. He acknowledged me and everything.

   Q. And anything else that was said?

   A. No.

   Q. Okay. And did he do anything unfriendly or intimidating when he
   acknowledged you? I mean you say he was being filmed.

   A. Not in the front of the cameras, I doubt if he would do that.

   Q. So when he patted you on the shoulder and said "How are you doing,
   Paula "

   A. Uh-huh.

   Q. he did that in a friendly fashion, correct?

   A. Yeah.

   Q. And you responded in a friendly fashion. Correct?

   A. I guess.

   Mr. Campbell: Objection, misstates prior testimony.

   BY MR. BRISTOW:

   Q. Go ahead.

   A. I don't know how I responded. I don't know if I said anything. I may
   have just looked at him.

   Q. Okay. You don't recall how you may have responded?

   A. Huh-uh, no, I don't.

   Q. By the way, what was the outfit you were wearing when he said you
   looked nice when you were in the presence of Roger Patterson Larry
   Patterson, do you remember?

   A. Yeah. I think it was an Easter outfit I had. It was a white, like a long
   cullote thing. Those were in style then and it was made out of like a silk
   type material. It was a dressy outfit. It was long, about down to my
   knees.

   Q. Okay.

   A. Had a big wide belt around it.

   Q. When you wore that outfit, was it unusual for you to receive
   compliments that you looked good in that outfit?

   A. I don't remember anybody really said anything.

   Q. You don't remember one way or the other?

   A. Huh-uh.

   Q. Okay. All right. Tell me about any other incidences in which you met
   Governor Clinton.

   A. That was it.

   Q. All right. Now, let's go back from the day at the Excelsior Hotel. Tell
   me about the next time that you saw Danny Ferguson.

   A. After I left the hotel room, he was sitting out there and he looked up
   with a smirk on his face. I went down to the elevator. I did not see him
   any more that day at all whatsoever. I left and the next time I saw him
   was it seemed like it was quite awhile, a few months or something.

   I was over at the Governor's office and he was not sitting in the
   Governor's office and usually he doesn't sit out there. I think they sit in
   the back. And I was sitting there and I left when I went to leave, I
   heard somebody holler my name and he rushed out and it was Ferguson
   and he said, "The Governor wanted me to ask you if he could get your
   phone number because Hillary is out of town a lot and he would maybe
   like to meet with you." And I told him no, that I was living with my
   boyfriend and I did not mention his name and he responded by saying,
   "well, how is Steve doing" and I did not tell him who he was.

   Q. Okay. Anything else that was said in that conversation?

   A. No. I think that was it.

   Q. Okay. When is the next time that you saw Danny Ferguson?

   [skips pages 248-260]

   [...] and Clinton makes him do it and

   Q. But you said the case

   MR. CAMPBELL: Counsel, it's after 5:00 now

   MR. BRISTOW: Just about two or three minutes will be a good
   breaking point.

   BY MR. BRISTOW:

   Q. You said that the reason that you sued Mr. Ferguson was because he
   had lied about you, but and that that had hurt your reputation; is that
   right?

   A. Right.

   Q. Were you not aware that there has been a motion filed in this case to
   take your reputation out of it, to take away anything about your
   defamation or reputation? Are you aware of that?

   MR. CAMPBELL: Objection, misstates the motion at issue, misstates
   the evidence in the record and no foundation.

   BY MR. BRISTOW:

   Q. Isn't it true that a motion has been filed to take away the reputation
   issue and to drop the defamation claim against Mr. Ferguson?

   MR. CAMPBELL: Same objections.

   THE WITNESS: Yes.

   BY MR. BRISTOW: Was that filed with your permission and your
   consent?

   A. It was filed, but I didn't really care if it was dropped or not
   personally.

   Q. Well, if you don't care about whether you are suing Mr. Ferguson for
   defamation or not, why are you suing Mr. Ferguson? Why do I have to
   be here? Why does Mr. Ferguson have to be in this lawsuit? What is it
   you're wanting from Mr. Ferguson?

   MR. CAMPBELL: Objection, multifarious. That's about four questions.
   Also, objection, asked and answered. She already told you, counsel, she
   was suing him for his conspiracy.

   BY MR. BRISTOW:

   Q. If you are willing to drop the defamation count as your lawyers have
   represented to the federal judge, why are you suing my client, Danny
   Ferguson, at this point in time?

   MR. CAMPBELL: Same objections, asked and answered.

   BY MR. BRISTOW:

   Q. Go ahead.

   A. Because he did escort me up there knowing full well why. He said he
   did it all the time. So he knew exactly what was going to take place. Him
   and Bill Clinton apparently conspired together to get me up there and tell

   [skips pages 263-299]

   A. I think so. I don't recall.

   Q. Now I want to ask you about some facts and I want to I want you
   to tell me every fact that you have that you think supports these
   allegations. And generally it is my understanding that you believe that
   Governor Clinton and Danny Ferguson or Danny Ferguson that you
   were, I think I think that you believe that you were stalked, that you
   were under surveillance, that you were investigated, that you were
   harassed. Am I correct that you are making those allegations against Mr.
   Clinton and Mr. Ferguson?

   A. That's the way I felt personally.

   Q. Okay. Now what I want you to do is tell me the facts that you are
   aware of to indicate that you were under some sort of surveillance.

   A. Okay. Well, first of all, Ferguson said he asked me how Steve was
   doing. I never told him Steve's name. That was the incident in the state
   Capitol. And apparently he knew who he was. And I didn't tell him. And
   we weren't married at that point. So I don't know how he found out who
   my boyfriend was. So apparently somebody had looked into something
   to

   Q. All right. Now that is an assumption you are making; is that correct?

   A. Yes. But you're asking me what assumptions do I have that would
   make me think that. Now that is an assumption that I have that would
   make me believe that somebody knew something because nobody knew
   who Steve's name was and surely he wouldn't

   Q. Okay. Well now, a fact is something you have seen or something you
   have heard. And so you have told me a fact, and it's your testimony that
   Mr. Ferguson asked you how was Steve doing. And I accept that as a
   fact that you have. Now what other facts do you have that you either
   saw or heard or someone reported to you to indicate that you were
   under some fort of surveillance?

   A. I don't have any substantial facts, because I really don't. But that's
   just the way I felt. I know I've been followed in Long Beach, California,
   by unmarked-looking cars.

   Q. Unmarked cars followed you in Long Beach and when did that take
   place?

   A. Well, it was a little bit, oh, probably a year or so ago.

   Q. Now are you in any way accusing my client, Mr. Ferguson, of having
   something to do with that?

   A. No. I'm just yeah. I'm answering your question. If I felt like I was
   followed or anything.

   Q. Okay. Or are you accusing the President of having something to do
   with unmarked cars following you in Long Beach?

   A. Possibly. Well, somebody was following me probably.
 

SOURCE: http://www.courttv.com/legaldocs/government/jones/jonesdepo.html