CIVIL ACTION :   NO. 94-290




Plaintiff Paula Corbin Jones, by counsel, brings this action to obtain
redress for the deprivation and conspiracy to deprive Plaintiff of her
federally protected rights as hereafter alleged, and for intentional
infliction of emotional distress, and for defamation.


1. This Court has subject matter jurisdiction pursuant to
(a) 28 U.S.C. 1331, because the case arises under the Constitution
and laws of the United States; (b) 28 U.S.C. 1343, because this
action seeks redress and damages for violation of 42 U.S.C. 1983 and
1985 and, in particular, the due process and equal protection
provisions of the United States Constitution, including the rights
protected in the Fifth and Fourteenth Amendments thereof; and (c) 28
U.S.C. 1232, since there is diversity of citizenship and this is a
civil action involving, exclusive of interest and costs, a sum in
excess of $50,000.00. This Court also has jurisdiction over the causes
of action alleged in Counts III and IV pursuant to federal pendant

2. Venue is appropriate in this judicial district under
28 U.S.C. 1391(b), because Defendants William Jefferson Clinton and
Danny Ferguson reside here, and a substantial part of the events
giving rise to this Complaint occurred here.


3. Plaintiff Paula Corbin Jones (hereafter “Jones”) is a
citizen of the State of California. Prior to her marriage on December
28, 1991, Plaintiff was known as Paula Rosalee Corbin.

4. Defendant William Jefferson Clinton (hereafter “Clinton”) is a citizen of
the State of Arkansas or alternatively of the District of Columbia.

5. Defendant Danny Ferguson (hereafter ”Ferguson”) is a citizen of the
State of Arkansas.


6.  On or about March 11, 1991, Jones began work as an Arkansas
State employee for the Arkansas Industrial Development Commission
(hereafter “AIDC”), an agency within the executive branch of the state
of Arkansas. The Governor of Arkansas is the chief executive officer
of the executive branch of the State of Arkansas.

7. On May 8, 1991, the AIDC sponsored the Third Annual Governor’s Quality
Management Conference (hereafter “Conference”), which was held at the Excelsior
Hotel in Little Rock, Arkansas. Clinton, then Governor of Arkansas,
delivered a speech at the Conference on that day.

8. Also on that day, Jones worked at the registration desk at the Conference
along with Pamela Blackard (hereafter “Blackard”) another AIDC employee.

9. A man approached the registration desk and informed Jones and Blackard
that he was Trooper Danny Ferguson, Bill Clinton’s bodyguard. Defendant
Ferguson was at that time a law enforcement officer within the ranks
of the Arkansas State Police and assigned to the Governor’s Security
Detail. He was in street clothes and displayed a firearm on his
person. He made small talk with Jones and Blackard and then left.

10. At approximately 2:30 p.m. on that day, Ferguson reappeared at the
registration desk, delivered a piece of paper to Jones with a four
digit number written on it and said: “The Governor would like to meet
with you” in this suite number. Plaintiff had never met Defendant
Clinton and saw him in person for the first time at the Conference.

11. A three-way conversation followed between Ferguson, Blackard and
Jones about what the Governor could want. Jones, who was then a
rank-and-file Arkansas state employee being paid approximately S6.35
an hour, thought it was an honor to be asked to meet the Governor.
Ferguson stated during the conversation: “It’s okay, we do this all
the time for the Governor.”

12. Jones agreed to meet with the Governor
because she thought it might lead to an enhanced employment
opportunity with the State. Blackard told Jones that she would assume
Plaintiff’s duties at the registration desk.

13. Trooper Ferguson then escorted Jones to the floor of the hotel
suite whose number had been
written on the slip of paper Trooper Ferguson had given to Jones. The
door was slightly ajar when she arrived at the suite.

14. Jones knocked on the door frame and Clinton answered. Plaintiff entered.
Ferguson remained outside.

15. The room was furnished as a business suite, not for an
overnight hotel guest. It contained a couch and chairs, but no bed.

16. Clinton shook Jones’ hand, invited her in, and closed the door.

17. A few minutes of small talk ensued, which
included asking Jones about her job. Clinton told Jones that Dave
Harrington is “my good friend.” On May 8, 1991, David Harrington was
Director of the AIDC, having been appointed to that post by Governor
Clinton. Harrington was Jones’ ultimate superior within the AIDC.

18. Clinton then took Jones’ hand and pulled her toward him, so that their
bodies were in close proximity.

19. Jones removed her hand from his and retreated several feet.

20. However, Clinton approached Jones again. He said: “I love the way your
hair flows down your back” and “I
love your curves.” While saying these things, Clinton put his hand on
Plaintiff’s leg and started sliding it toward the hem of Plaintiff’s
culottes. Clinton also bent down to attempt to kiss Jones on the neck.

21. Jones exclaimed, “What are you doing?” and escaped from Clinton’s
physical proximity by walking away from him. Jones tried to distract
Clinton by chatting with him about his wife. Jones later took a seat
at the end of the sofa nearest the door. Clinton asked Jones: “Are you
married?” She responded that she had a regular boyfriend. Clinton then
approached the sofa and as he sat down he lowered his trousers and
underwear exposing his erect penis and asked Jones to “kiss it.”

22. There were distinguishing characteristics in Clinton’s genital area
that were obvious to Jones.

23. Jones became horrified, jumped up from the couch, stated that she was
“not that kind of girl” and said:
“Look, I’ve got to go.” She attempted to explain that she would get in
trouble for being away from the registration desk.

24. Clinton, while fondling his penis said: “Well, I don’t want to make
you do anything you don’t want to do.” Clinton then stood up and 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 Jones and said: “You are smart. Let’s keep this
between ourselves.”

25. Jones believed “Dave” to be the same David Harrington, of whom
Clinton previously referred. Clinton, by his
comments about Harrington to Jones, affirmed that he had control over
Jones’ employment, and that he was willing to use that power. Jones
became fearful that her refusal to succumb to Clinton’s advances could
damage her in her job and even jeopardize her employment.

26. At no time, nor in any manner, did Jones encourage Clinton to turn the
meeting toward a sexual liaison. To the contrary, the unwanted sexual
advances made by Clinton were repugnant and abhorrent to Jones who
took all reasonable steps she could think to do to terminate Clinton’s
perverse attention and actions toward her.

27. Jones left the hotel suite and came into the presence
of Trooper Ferguson in the hallway.
Ferguson did not escort Plaintiff back to the registration desk. Jones
said nothing to Ferguson and he said nothing to her during her
departure from the suite.

28. Jones was visibly shaken and upset 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.
Blackard attempted to comfort Plaintiff.

29. Jones thereafter left the Conference and went to the work
place of her friend, Debra Ballentine.

30. When Ballentine met Plaintiff at the reception area, she
immediately asked Jones what was wrong because Jones was visibly upset
and nervous. Plaintiff wanted to talk about something that just
happened and wanted to discuss it someplace privately. Ballentine and
Jones went to a private area in the office, and later outside. Jones
then told Ballentine what had happened with Clinton in the hotel
suite. According to Ballentine, Jones told her that Clinton said as
she left the room, “I know you’re a smart girl and I’m sure you’ll
keep this to yourself.”

31. Ballentine urged Jones to report the
incident. Plaintiff refused, fearing that, if she did so, no one would
believe her account, that she would lose her job, and that the
incident would endanger her relationship with her then-fiance (now
husband), Stephen Jones.

32. Later, on the same day, Plaintiff also
described the substance of her encounter with Clinton to her sister,
Charlotte Corbin Brown.

33. Within two days of May 8, 1991, Plaintiff
also informed her sister, Lydia Corbin Cathey, and her mother, Delmar
Lee Corbin, the substance of her encounter with Clinton.

34. Plaintiff also told her fiance, Stephen Jones, that “Bill Clinton
made a pass at me but I said ‘no’.” She, however, did not at that time tell
him the lurid details of her horrific encounter with Clinton in the hotel
suite, which she feared, if disclosed, might ruin her relationship
with Mr. Jones.

35. Plaintiff continued to work at AIDC. One of her
duties was to deliver documents to and from the Office of the
Governor, as well as other offices within the Arkansas State Capitol
complex. In or about June, 1991, while Jones was performing this duty,
Ferguson saw her at the Governor’s office and said: “Bill wants your
phone number. Hillary’s out of town often and Bill would like to see
you.” Plaintiff refused to provide her telephone number.

36. On another occasion, Ferguson approached Jones and asked: “How’s Steve?”
This frightened Plaintiff and made her feel as if she was being
watched and was not safe. She had never told Ferguson or Clinton the
name of her fiance.

37. Plaintiff and Stephen Jones later married. She gave
birth to her child and returned to work, after which she
encountered Ferguson at Governor Clinton’s office. Ferguson told her:
“I’ve told Bill how good looking you are since you’ve had the baby.”
This, too, frightened Plaintiff and made her feel that her activities
were being monitored.

38. On one occasion, Plaintiff was accosted by
Clinton in the Rotunda of the Arkansas State Capitol. Clinton draped
his arm over Plaintiff, pulled her close and tightly to his body and
said: “Don’t we make a beautiful couple — beauty and the beast?”
Clinton directed this remark to his bodyguard, Trooper Larry
Patterson, an officer of the Arkansas State Police and also a member
of the Governor’s Security Detail.

39. Jones continued to work at AIDC
even though she was in constant fear that Governor Clinton might take
retaliatory action against her because of her rejection of his
abhorrent sexual advances. Her enjoyment of her work was severely
diminished. In fact, she was treated in a hostile and rude manner by
certain superiors in AIDC. This rude conduct had not happened prior to
her encounter with Clinton. Further, after her maternity leave she was
transferred to a position which had no responsible duties for which
she could be adequately evaluated to earn advancement. The reason
given to her by her superiors for the transfer was that her previous
position had been eliminated. This reason was untrue since her former
position was not abolished. It was a pretext for the real reason which
was that she was being punished for her rejection of the various
advances made by Clinton described above. In addition, the job in
which she was placed called for a higher grade and pay, yet she was
not paid more money than she received in her previous position.
Although other employees received merit increases, Jones never
received a raise beyond a cost of living increase.

40. Jones terminated her employment and separated from AIDC service on February
20, 1993.  On May 4, 1993, Plaintiff, her husband and child moved to

41. In January, 1994, Plaintiff visited her family and
friends in Arkansas. While Jones was in Arkansas, Ms. Ballentine
telephoned Jones to arrange a meeting for lunch. During the telephone
conversation, Ballentine read to Plaintiff a paragraph from an article
published in the January, 1994 issue of The American Spectator
magazine regarding Plaintiff’s hotel suite encounter with Clinton.
Attached hereto, and incorporated herein, as Exhibit “A” is a copy of
The American Spectator article.

42. The American Spectator account asserts that a woman by
the name of “Paula” told an unnamed trooper
(obviously Defendant Ferguson), who had escorted “Paula” to Clinton’s
hotel room, that “she was available to be Clinton’s regular girlfriend
if he so desired,” thus implying a consummated and satisfying sexual
encounter with Clinton, as well as a willingness to continue a sexual
relationship with him. These assertions are untrue. The article, using
information apparently derived from Ferguson, also incorrectly asserts
that the encounter took place in the evening.

43. The American Spectator account also asserted that the troopers’
“‘official’ duties included facilitating Clinton’s cheating on his wife.
This meant that, on the State payroll, and using State time, vehicles and
they were instructed by Clinton on a regular basis to approach women
and to solicit their telephone numbers for the Governor, to drive him
in State vehicles to rendezvous points and guard him during sexual
encounters; to secure hotel rooms and other meeting places for sex;
…” and various other things to facilitate Clinton’s sex life
including “to help Clinton cover-up his activities by keeping tabs on
Hillary’s whereabouts and lying to Hillary about her husband’s
whereabouts.” Although this pattern of conduct by Clinton may be true,
the magazine article concluded, evidently from interviews with
troopers from Clinton’s Security Detail, including Ferguson, that “all
of the women appear to have been willing participants in the affairs
and liaisons [emphasis added].”

44. Since Jones (“Paula”) was one of
the women preyed upon by Clinton and his troopers, including by
Defendant Ferguson, in the manner described above, those who read this
magazine account could conclude falsely that Jones (“Paula”) had a
sexual relationship and affair with Clinton. Jones reputation within
her community was thus seriously damaged.

45. Jones realized that those persons who already knew about
the hotel room encounter could
identify her as the “Paula” mentioned in The American Spectator
article. She became extremely upset because, inter alia, she feared
that the statements in the magazine would damage her relationship with
her husband, her family, and her friends and acquaintances, some of
whom might have believed that she had agreed to be Clinton’s
“girlfriend” at a time when she was engaged to Mr. Jones.

46. On January 8, 1994, at approximately 12:00 noon, Jones and Ballentine
were dining at the Golden Corral Steakhouse in North Little Rock,
Arkansas. Trooper Ferguson, who happened to be dining with his wife at
this restaurant, came over to their table to talk to Jones. Since
Jones believed that the ultimate source of the report in The American
Spectator of the hotel suite encounter was Trooper Ferguson, she
confronted him on this matter. Trooper Ferguson stated that he was
sorry that Jones’ first name had appeared in the magazine article but
that he had purposely concealed her last name and place of employment
from those to whom he recounted the incident. Trooper Ferguson also
said that he knew Jones had rebuffed Mr. Clinton’s sexual advances
because, “Clinton told me you wouldn’t do anything anyway, Paula.”

47. Because the false statements appearing in The American Spectator
article that Jones was willing to have sex with Clinton (and the
innuendo that she had already done so when she left the hotel suite)
threatened her marriage, her friendships, and her family
relationships, Plaintiff spoke publicly on February 11, 1994, that she
was the “Paula” mentioned in The American Spectator article, that she
had rebuffed Clinton’s sexual advances, and that she had not expressed
a willingness to be his girlfriend. Jones and her lawyer asked that
Clinton acknowledge the incident, state that Jones had rejected
Clinton’s advances, and apologize to Jones.

48. Clinton, who is now President of the United States

of America responded to Jones’ request
for an apology by having his press spokespersons deliver a statement
on his behalf that the incident never happened, and that he never met
Plaintiff. Thus, by innuendo and effect, Clinton publicly branded
Plaintiff a liar. Moreover, as recently as the week this Complaint was
filed, Clinton, through his White House aides, stated that Plaintiff’s
account of the hotel room incident was untrue and a “cheap political

49. Clinton hired an attorney, who, as Clinton’s agent, said
that Jones’ account “is really just another effort to rewrite the
results of the election [i.e. for President of the United States] and
… distract the President from his agenda.” The attorney further
asked the question: “Why are these claims being brought now, three
years after the fact? The attorney also asked how Jones allegations
could be taken “seriously.” These comments by Clinton’s counsel, on
behalf of Clinton, imply that Jones is a liar.

50. Dee Dee Meyers, White House Spokeswoman, said of Jones’ allegations:
“It’s just not true.” Thus, the pattern of defaming Jones continues
to this date.

51. Clinton knows that Jones’ allegations are true and that his, and his
attorney’s, spokespersons’, and agents’ denials are false.

52. The outrageous nature of Clinton’s branding of Jones as a liar is
aggravated in that a greater stigma and reputation loss is suffered by
Jones by the statements of the President of the United States in whom
the general public reposes trust and confidence in the integrity of
the holder of that office.

53. Clinton, a member of the Arkansas State Bar, knew or should
have known on May 8, 1991, and thereafter, that
Arkansas law provides that harassment, including the touching or
attempt or threat to do so which subjects the victim to offensive or
potentially offensive physical contact, is a criminal violation of
Arkansas Code Annotated 5-71-208.

54. While Jones was in Clinton’s hotel suite, Jones was falsely imprisoned
by Clinton’s intentional restriction of her personal
freedom of movement without legal right.
Clinton’s use of force in pulling Jones toward him, his words and
acts, and the armed police guard outside the door, in conjunction with
the impressive atmosphere of her being alone with the Governor of the
State who was also her superior’s boss, caused her to be initially and
temporarily afraid to terminate the meeting.

55. The statements, acts, and omissions of Clinton’s
agents, servants, and employees who acted
under his explicit and implicit instructions and supervision, during
the pertinent periods herein when he was Governor of Arkansas, and
after he became President, bind Clinton under the doctrines of agency,
joint conduct, master servant, respondeat superior, and conspiracy.

56. The actions of the Arkansas state employees, including Defendant
Ferguson and other agents of Clinton were taken under color of state

57. Clinton’s actions and omissions above stated caused Jones
embarrassment, humiliation, fear, emotional distress, horror, grief,
shame, marital discord and loss of reputation.



58. Plaintiff incorporates by reference paragraphs 1 through 57.

59. Plaintiff is entitled to the equal protection of the laws under the
Fourteenth Amendment of the United States Constitution, and due
process of law under the Fifth and Fourteenth Amendments of the United
States Constitution.

60. Defendant Clinton, as Governor of Arkansas,
acting under color of state law, discriminated against Plaintiff
because of her gender by sexually harassing and assaulting her on May
8, 1991, and thereafter, and this deprived Jones of her right to equal
protection of the law.

61. Further, he continued personally, and
through agents, to impose a hostile work environment on Plaintiff in
which she feared the loss of her employment and the possible adverse
employment actions against her, including job discrimination and
monitoring of her personal life. As described above she was placed in
a category separate from other public employees in that she was
actually subjected to hostility by her superiors, which deprived her
of an opportunity for advancement and she suffered an economic

62. Plaintiff, as a citizen and Arkansas state employee,
was entitled to due process protection of freedom from arbitrary
action which jeopardized her property interest in her public employee
job in that she should not have been subjected arbitrarily to the fear
of losing that job or of having to provide sex to the Governor as a
quid pro quo for keeping the job. Further, she should not have been
subjected arbitrarily to the fear of losing the enjoyment of a proper
and pleasant work environment, or to other adverse actions which she
feared and which deprived her of the proper enjoyment and efficiency
of her work. Clinton’s actions deprived Jones of her due process
liberty and property interests guaranteed to her by the Constitution
of the United States.

63. Plaintiff also was entitled to a due process
liberty interest in her reputation as an honest public employee.
Clinton’s actions and statements deprived Jones of these rights.

64. Plaintiff, for a brief period of time, was held against her will by
the oppressive atmosphere of intimidation caused by the presence of
the highest official of the State of Arkansas and an armed guard at
the door. Not only was she subjected to unwelcome sexual advances, but
also Was personally restrained and imprisoned by the seizing of her
person, against her will, by Clinton and his agent.

65. The above-described actions of Clinton were
undertaken when he was acting
under the color of state law, as Governor of Arkansas, and said
actions deprived Jones of federal equal protection and due process
rights guaranteed by the Fifth and Fourteenth Amendments of the United
States Constitution, and made actionable by 42 U.S.C.  1983 (The

66. Plaintiff incorporates by reference paragraphs 1 through 65.

67. Clinton conspired with his Security Detail, including with Defendant
Ferguson, and perhaps with others currently unknown to this Plaintiff,
to deprive Jones of equal protection of the laws and of equal
privileges and immunities under the laws, as further set forth in
Count I above.

68. The conspirators committed some acts in furtherance
of the conspiracy which included contacting Jones and bringing her to
Clinton on May 8, 1991 to permit him to attempt to entice her on to
have a sexual liaison with him.

69. As a result of the conspiracy, Jones was injured by Defendants in her
person and property and deprived of having and exercising her rights and
privileges as a citizen of the United States, as is
more fully set forth in Count I.


70. Plaintiff incorporates by reference paragraphs 1 through 69.

The conduct of Clinton herein set forth was odious, perverse and
outrageous. Not only were the acts of sexual perversity unwelcome by
Jones, but they were wilful, wanton, reckless, intentional, persistent
and continuous in the hotel room.

72. Clinton’s sexual advances, assaults upon and imprisonment of
Jones’ person, and his exposure of
his erect penis and his requests of acts to be performed thereupon
were extreme, intentional, and caused Jones severe emotional distress.

73. Not content with the events in the hotel on May 8, 1991, Clinton
on subsequent occasions, acting himself and through his agents, as
specified above, aggravated further the initial severe emotional
damage to Jones.

74. These actions were so outrageous in character,
and extreme in degree, as to go beyond all possible bounds of decency,
and to be regarded as atrocious and utterly intolerable in a civilized


75. Plaintiff incorporates by reference paragraphs 1 through 74.

76. On several occasions on and after February 11, 1994, Clinton, and his
agents and employees acting pursuant to his direction, maliciously and
wilfully, defamed Jones by making statements which Clinton knew to be
false. These statements were made with the intent and certain
knowledge that they would be reprinted in the print and other media.

77. Such statements by Clinton, his agents and employees,
characterized Jones as a liar and as being “pathetic,” and damaged her
good name, character, and reputation.

78. Defendant Ferguson’s statements likewise maliciously and
willfully defamed plaintiff and
damaged her good name, character and reputation. Ferguson’s statement
that Jones had agreed to be Clinton’s girlfriend, and his innuendo
that she had willingly participated in a sexual encounter, were
knowingly false.

79. That Ferguson knew these statements were false is
confirmed by Clinton’s denial to Ferguson that anything happened of a
sexual nature between Clinton and Jones.


WHEREFORE, Plaintiff requests the following relief:

a. Count I, judgment against Defendant Clinton for compensatory
damages of $ 75,000.00; punitive damages for Defendant’s wilful,
outrageous and malicious conduct, of $100,000.00; the costs of her
suit and attorneys fees; nominal damages, and such other and further
relief as the Court may deem proper.

b. Count II, judgment against Defendant Clinton and Defendant Ferguson,
jointly and severally for compensatory damages of
$75,000.00; punitive damages for Defendant’s
wilful, outrageous and malicious conduct, of $100,000.00; the costs of
her suit and attorney’s fees; nominal damages, and such other and
further relief as the Court may deem proper.

c. Count III, judgment against Defendant Clinton for
compensatory damages of $ 75,000.00; punitive damages for
Defendant’s wilful, outrageous and malicious
statements and conduct, of $ 100,000.00; the costs of her suit and
attorneys’ fees; nominal damages, and such other and further relief as
the Court may deem proper.

d. Count IV, judgment against Defendant Clinton and Defendant
Ferguson, jointIy and severally for compensatory
damages of $75,000.00; punitive damages for Defendant’s wilful,
outrageous and malicious statements and conduct, of $ 100,000.00; the
costs of her suit and attorneys’ fees; nominal damages, and such other
and further relief as the Court may deem proper.


Plaintiff demands a trial by jury on each of the counts.

Respectfully Submitted,


Gilbert K. Davis, VA Bar No. 4683 Attorney for Plaintiff 9516-C Lee
Highway Fairfax, Virginia 22031 (703) 352-3850


Joseph Cammarata, VA Bar No. 35118 Attorney for Plaintiff 9516-C Lee
Highway Fairfax, Virginia 22031 (703) 352-3850


I hereby certify under penalty of perjury that I am the Plaintiff in
the above-captioned case; that I have read the foregoing Complaint;
and, that the facts related therein are true and correct to the best
of my knowledge, information, and belief.

Paula Corbin Jones