This is the complete and unedited text of the response to Paula Corbin Jones's complaint filed by Danny Ferguson in October 1994. Highlights of Ferguson's narrative of events include:

Jones Tells Ferguson Clinton Is "Good Looking"
Jones Asserts She Will be Clinton's Girlfriend

IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF ARKANSAS
WESTERN DIVISION

PAULA CORBIN JONES, PLAINTIFF

v.

WILLIAM JEFFERSON CLINTON AND
DANNY FERGUSON, DEFENDANTS

ANSWER OF DANNY FERGUSON

Comes now Danny Ferguson, and for his Answer to the Complaint filed herein, states and alleges as follows, viz:

1. Defendant Danny Ferguson notes that the plaintiff has attempted to plead several reasons why this Court would have jurisdiction. Defendant Danny Ferguson denies that he has violated any of plaintiff's federally protected rights, but does admit that there is diversity of citizenship between the parties, and that this Court has jurisdiction based on the diversity allegations.

2. Defendant Danny Ferguson admits that venue is proper in the Little Rock Division of the Eastern District of Arkansas.

3. Defendant Danny Ferguson admits the allegations of Paragraphs 3, 4, and 5 of the Complaint as regards the parties herein.

4. Defendant Danny Ferguson is without knowledge as to when plaintiff Paula Corbin Jones began work as an Arkansas state employee, and thus denies the allegations of Paragraph 6.

5. Defendant Danny Ferguson has knowledge of a Governor's Quality Management Conference held at the Excelsior Hotel in Little Rock, at which Governor Bill Clinton delivered a speech to the conference. Defendant Danny Ferguson has no personal knowledge as to the date of said conference and thus denies the specific allegations of Paragraph 7.

6. Defendant Danny Ferguson admits that Paula Corbin Jones was at the registration desk on the day of the aforesaid conference with another female employee, but is not aware of the identity of such female employee and he thus denies the allegations of Paragraph 8.

7. Defendant Danny Ferguson denies the allegations of Paragraph 9. He does admit that at the time of the aforesaid conference that he was a law enforcement officer within the ranks of the Arkansas State Police and assigned to the Governor's Security Detail. He admits that he was wearing street clothes but specifically denies displaying a firearm on his person. As regards the allegations of small talk with plaintiff Paula Corbin Jones, after the speech given by Governor Clinton, Paula Corbin Jones did make several comments to defendant Danny Ferguson about how she found Governor Clinton to be "good looking" and about how she thought his hair was sexy, and which comments she asked defendant Danny Ferguson to relay to Governor Bill Clinton.

8. Defendant Danny Ferguson denies each and every material allegation in Paragraph 10 of the Complaint.

9. Defendant Danny Ferguson denies each and every material allegation in Paragraph 11 of the Complaint.

10. Defendant Danny Ferguson denies the allegations in Paragraph 12 of the Complaint. Plaintiff Paula Corbin Jones had made comments in the morning about Governor Clinton's good looks, and his sexy demeanor and had mentioned nothing to defendant Danny Ferguson in any of these conversations about hoping to have an enhanced employment opportunity. Defendant Danny Ferguson denies each and every other allegation of Paragraph 12.

11. Defendant Danny Ferguson admits traveling in an elevator with plaintiff Paula Jones and pointing out a particular room of the hotel. He has no information as to whether the door was opened or closed.

12. Defendant Danny Ferguson denies each of the allegations in Paragraph 14. When he pointed out the room in question, he left and returned to the second floor.

13. Defendant Danny Ferguson has no knowledge or information as to the allegations made in Paragraphs 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, and 26, and therefore denies each and every allegation in same.

14. Defendant Danny Ferguson specifically denies the allegations of Paragraph 27. Paul Corbin Jones did not come into the presence of defendant Danny Ferguson in the hallway because he was sitting on a couch on the second floor. The defendant Danny Ferguson does not have personal knowledge of what took place in the hotel room or of the amount of time spent by Paula Jones in such room. When Paula Jones returned to the second floor, some 20 to 30 minutes after having been left by defendant Danny Ferguson, she asked him if he and the Governor were going to stay at the seminar for the rest of the day. He replied that they had the option to do that, but that it was up to the Governor. She then asked if the Governor had a girlfriend and Danny Ferguson answered negatively, and she then responded that she would be the Governor's girlfriend. Plaintiff Paula Corbin Jones did not appear to be upset in any way at this time.

15. Defendant Danny Ferguson specifically denies the allegations of Paragraph 28, 29, 30, 31, 32, 33, and Paragraph 34 of the Complaint.

16. Defendant Danny Ferguson denies the specific allegations of Paragraph 35 of the Complaint. Approximately a week or two after the aforesaid conference, plaintiff Paula Jones came into the Governor's office to deliver mail when Danny Ferguson was present. She motioned for Danny Ferguson to follow her into the hall as she left and he did so. Once in the hall, she asked if the Governor had said anything about her and Danny Ferguson replied in the negative. Plaintiff Paula Corbin Jones then asked for a piece of paper and a pen and wrote down her home phone number and told defendant Danny Ferguson to give it to Governor Clinton. She said to tell him that she was living with her boyfriend and that if the boyfriend answered, Governor Clinton should either hang up or say that he had a wrong number.

17. Defendant Danny Ferguson specifically denies each and every allegation of Paragraph 36 stating that he did not even know plaintiff's husband's first name until she went public in February of 1994, and he saw this name in the newspaper.

18. Defendant Danny Ferguson specifically denies the allegations of Paragraph 37 and denies in the most specific terms having made any such comment as alleged herein.

19. Defendant Danny Ferguson has no information as to the allegations in Paragraph 38, 39, 40, and 41 of the Complaint and therefore denies same.

20. Defendant Danny Ferguson never spoke to anyone who said they were associated with The American Spectator. He did have a conversation with David Brock who indicated that he was writing a book. He denies that he said that the incident happened in the evening and said nothing whatsoever about a consummated and satisfying sexual encounter with Clinton nor did he say anything about any future sexual relationship as regards plaintiff Paula Corbin Jones.

21. Defendant Danny Ferguson denies the allegations in Paragraphs 43, 44, and 45 of the Complaint.

22. Trooper Danny Ferguson specifically denies the allegations in Paragraph 46 of the Complaint. He does admit that the parties had a conversation at the Golden Corral Steak House in which Paula Corbin Jones inquired as to how much money Danny Ferguson thought that she could make for herself by coming forward with her allegations. Danny Ferguson responded by talking about his painful experiences with the media after The American Spectator article and about the effect on Paul Corbin Jones' family if she came forward and talked about the matter. The specific allegations in Paragraph 46 are denied.

23. Defendant Danny Ferguson denies each and every material allegation of Paragraphs 47, 48, 49, 50, 51, 52, and 53 of the Complaint.

24. Defendant Danny Ferguson specifically denies the allegations of Paragraph 54 of the Complaint and affirmatively avers that he was not outside the door to the hotel room.

25. Defendant Danny Ferguson specifically denies the allegations of Paragraphs 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, and 65 of the Complaint.

26. Defendant Danny Ferguson specifically denies having engaged in any conspiracy and thus specifically denies Paragraphs 66, 67, 68, and 69 of the Complaint.

27. Defendant Danny Ferguson denies Paragraph 70, 71, 72, 73, and 74 of the Complaint.

28. Defendant Danny Ferguson specifically denies Paragraph 75, 76, 77, 78, and 79 of the Complaint. Defendant Danny Ferguson states that any actual statements made by him as outlined in this Answer were in fact true and that he pleads the defense of truth as regards the allegations set forth in the Answer. The other allegations made by plaintiff herein are specifically denied.

29. Defendant Danny Ferguson denies each and every material allegation of the Complaint not specifically admitted herein.

30. Defendant Danny Ferguson prays that the Complaint filed herein against him be dismissed.

31. Defendant Danny Ferguson would request a trial by jury on each and every allegation of disputed fact herein.

WHEREFORE, premises considered, defendant Danny Ferguson prays that the Complaint filed herein against him be dismissed; prays for trial by jury; prays for his cost herein paid, laid out, and expended, including attorney's fees, and prays for all other further and proper relief in the premises.

DANNY FERGUSON

By Bill Bristow, P. A.
State Bar No. 75009
216 E. Washington
Jonesboro, Arkansas 72401

Robert Batten
State Bar No. 71004
1412 West Main
Jacksonville, Arkansas 71004




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