Civil Action No. Lr-C-94-290

Paula Jones says her lawsuit is about the president's abuse of power an slurs against her character. Jones's version of events and her specific charges against Clinton, taken from her complaint:

1991: March 11: Jones began working for the Arkansas Industrial Development Commission (AIDC), an agency within the state government's executive branch. May 8: The AIDC sponsored the third annual Governor's Quality Management Conference at the Excelsior Hotel in Little Rock. Bill Clinton, then governor, appeared at the conference to deliver a speech. Jones was working at he registration desk along with Pamela Blackard when state trooper Danny Ferguson, who was serving as Clinton's bodyguard, approached the two, made small talk and then left. At about 2:30 p.m. Ferguson returned to the registration desk and delivered a piece of paper to Jones with a number written on it and said, "The governor would like to meet with you ( in this suite )." Jones, who had never met Clinton before, agreed to meet with him, thinking it might lead to a better job with the state. Trooper Ferguson escorted Jones to the hotel suite and remained outside as she entered. Clinton shook Jones's hand and closed the door. In small talk Clinton asked Jones about her job and told her that Dave Harrington, the AIDC's director, was "his good friend." Clinton then took Jones's hand and pulled her toward him. Jones retreated. Clinton approached Jones again and said, "I love the way your hair flows down your back" and "I love your curves." Clinton put his hand on Jones's leg and attempted to kiss her on the neck. Jones exclaimed, "What are you doing?" and walked away, taking a seat at the end of the sofa nearest the door. Clinton approached and, as he sat down, lowered his trousers and underwear, exposing his erect penis. He asked Jones to "kiss it." There were distinguishing characteristics in Clinton's genital area that were obvious to Jones. She said that she was "not that kind of girl" and said, "Look, I've got to go." Clinton, fondling his penis, said, "Well, I don't want to make you do anything you don't want to do." He 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 Jones left the room Clinton looked sternly at her and said: "You are smart. Let's keep this between ourselves." Jones left the suite and was visibly shaken when she returned to the registration desk. Pamela Blackard immediately asked her what was wrong. After a moment, during which Jones attempted to collect herself, she told Blackard much of what had happened.

1992: Jones, who had since married, gave birth to a child. When she returned to work, she ran into Ferguson at Clinton's office. He said, "I've told Bill how good-looking you are since you've had the baby." This frightened Jones and made her feel her activities were being monitored.

1993: Feb. 20: Jones quit the AIDC. May 4: Jones and her family moved to California.

1994: In January Jones visited a friend, who read her a paragraph from the 1994 American Spectator magazine about Jones's encounter with Clinton. The article asserts that a woman named Paula told an unnamed trooper (obviously Ferguson) that "she was available to be Clinton's regular girlfriend if he so desired." Feb. 11: Jones publicly acknowledged that she was the "Paula" in the article but said she rebuffed Clinton's advances and never expressed interest in being his girlfriend. Jones asked Clinton to apologize for the incident. Clinton, through spokespeople, said the incident never happened, and through White House aides he called the plaintiff's account a "cheap political trick."

CHARGES I & II DEPRIVATION OF CONSTITUTIONAL RIGHTS AND PRIVILEGES: Jones alleges that Clinton, by calling her to the suite and asking for sex, could have been implying that she, as a state employee, had to comply or face retribution. Furthermore, she says he imposed on her a hostile work environment in which she feared the loss of her job and the monitoring of her personal life. Jones claims she was deprived of chances to advance her career. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS: Jones maintains that Clinton's alleged actions in the hotel suite were extreme, intentional and unwelcome. She says actions that day and on other days by Clinton and his agents created severe emotional distress.

CHARGE III CONSPIRACY TO DEPRIVE PERSONS OF EQUAL PROTECTION OF THE LAWS: Jones claims that by sending Ferguson down to the reception desk, Clinton conspired with his security detail to bring Jones to the suite, where he could proposition her.

CHARGE IV DEFAMATION OF CHARACTER: Jones says Ferguson's statements in the January 1994 American Spectator about her actions at the Excelsior were knowingly false and damaged her good name. In addition, Jones says, statements by president's lawyer that denied Jone's account branded her a liar.

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