Home of the Paula Jones Centerfold
Move Down the Page To Navigate. It's a Big MagazineFiled COUNSEL: American Politics Journal en banc, per se, res ipsa loquitor, Bar No. YES, New York, New York.
OPINION: JURY TRIAL DEMANDED
COMPLAINT Plaintiff Bill Clinton, by counsel, brings this suit to obtain a redress for the deprivation and conspiracy to deprive Plaintiff of his federally protected rights as hereafter alleged and lied about, and for intentional infliction of emotional distress on good Christians everywhere who have not signed the Contract ON America, contributed to Haley Barbour's bogus charities and for defamation of character although Plaintiff herein admits he prays for defendant every day.
JURISDICTION 1. This Court has subject matter jurisdiction pursuant to (a) 28 U.S.C. @ 1331, because the case arises under, we hope, 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 $ 50,000,000.00. This Court also has jurisdiction over the causes of action alleged in Counts III and IV pursuant to federal pendant jurisdiction. This court also has jurisdiction because the Court of Public Opinion, is, after all the most important court of all.
VENUE
2. Venue is appropriate in this judicial district under 28 U.S.C. @ 1391(b), because Plaintiff William Jefferson Clinton resides here even though he really doesn't get here much, and a substantial part of the fantasy giving rise to Jones' Complaint occurred here, we think, although it depends on what pharmaceutical or non-pharmaceutical grade chemical Jones is taking or has taken when we depose her.
THE PARTIES
3. Defendant Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones (hereafter "The Five Plaintiffs of Paula") are citizens of the States of Confusion. Prior to her marriage, we think she was married, on December 28, 1991, Jones was known as Paula Rosa-lee-lyn Carter Corbin.
4. Plaintiff William Jefferson Clinton (hereafter "The Big Guy") is a citizen of the State of Arkansas or alternatively of the District of Columbia and is also the most powerful individuals in the known world and one of America's most beloved presidents -- even under the CNN/Gallup Poll.
5. Defendant Susan Carpenter McBimbo (hereafter "Suzie the Coozie") is a citizen of the State of Deprivation.
FACTS
6. On or about March 11, 1991, Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones began to show up for work sporadically as an Arkansas State employee for the Arkansas Industrial Development Commission (hereafter called "SIDEWALK"), which she couldn't pronounce, and, which is 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 SIDEWALK sponsored the Third Annual Governor's Quality Management Conference (hereafter "Conference"), which was held at the Excelsior Hotel in Little Rock, Arkansas. The Plaintiff, then Governor of Arkansas, delivered a speech at the Conference on that day.
8. Also on that day, Jones sort-of-worked at the registration desk at the Conference between going out for bottles of Yoo Hoo, and corn dogs along with Pamela Blackard (hereafter "Blackard" a better nane you could not choose) another SIDEWALK "employee."
9. A man approached the registration desk and informed Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones and Blackard that he was Trooper Danny Ferguson, Plaintiff's bodyguard. 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 had a firearm hidden on his person which Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones found while fondling him. He made small talk with Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones fondled her back and talked to Blackard who was cheering them on and then left.
10. At approximately 2:30 p.m. on that day, Ferguson reappeared as if from heaven and in a ring of fire aboard a white stallion named Simon and at the registration desk, delivered a piece of paper to Jones with a four digit number written on it -- the day of Armageddon according to Jones - and said: "The Big Guy would like to meet with you" in my suite. Ferguson then winked and Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones knew what he meant -- he wanted to make whoopee, as she puts it, right then and there, but without Blackard's hooting and hollering as had occurred prior. Jones had never met Plaintiff Clinton and saw him in person for the first time at the Conference from approximately 35 feet away in a suite to which she had snuck looking for towels and prophylactics in order to join Ferguson forthwith.
11. A three-way followed between Ferguson, Jones and an unidentified chambermaid who asked about how they could get the Plaintiff into the sack with them and what he would want. Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones, who was then a rank-and-file Arkansas state employee and prior-welfare recipient was being paid approximately $ 3.35 an hour, and thought it was a good idea to meet and "greet" the Governor. Ferguson stated during the conversation: "It's okay, we do this all the time-- attempting to convince Plaintiff that Greek Style sex with Ferguson was okay."
12. Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones begged to meet with the Plaintiff because she thought it might lead to an "enhanced employment opportunity" with him and asked whether he had "a stable" of women.
13. Trooper Ferguson then got dressed and escorted Jones to the floor of the hotel suite where the Governor was entertaining friends and supporters . The door was slightly ajar when she arrived at the suite.
14. Jones knocked on the door frame and a butler answered. Plaintiff entered. Ferguson remained outside conveniently.
15. The room was furnished like a palace, not for an overnight hotel guest. It contained a couch and chairs, but no bed.
16. The butler shook Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones' hand, invited her in, and closed the door. There were, at Plaintiff's best guess, at least 40 people in the suite.
17. A few minutes of small talk ensued, which included Dick Morris asking Jones about her "job." The Plaintiff told Morris that Dave Harrington, Jones boss, 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 Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones' ultimate superior within the AIDC. Plaintiff heard this and made a mental note of it like a fox notes the position of the chicken coop.
18. The Governor then took a phone call with Morris listening in, so that their bodies were in close proximity.
19. Morris removed his head from near the Governor's and retreated several feet toward Jones.
20. However, The Governor approached Morris again. He said: "I love the way you duck when reporters ask me a tough question" and "I just love your nerves." While saying these things, The Governor put his hand on Morris' collar and started pulling it toward his own face in a threatening manner. Clinton also bent down to attempt to kick Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones on out of the way. She was already "at work" on Morris.
21. Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones mumbled almost incoherently because her mouth was full, "What are you doing?" and escaped from Plaintiff's physical proximity by crawling away from him. Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones tried to distract the Governor guy by chatting with him about his wife, asking if he could get rid of her for the subsequent weekend. When Plaintiff said no, Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones took a seat at the end of the sofa nearest the door and refused to leave. The Governor asked Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones: "Aren't you married? Aren't you ashamed?" She responded that she had a regular boyfriend but owed him nothing. The Governor then approached the sofa and as he sat down he hiked up his trousers exposing his ankles and asked Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones to "leave nicely or I'll call security."
22. There were distinguishing characteristics in Clinton's ankle area that were obvious to Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones, and no one else.
23. Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones became insulted, 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. The Governor , scratched his upper leg and said: "Well, it's about time." The Plaintiff then stood up and smoothed out 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 Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones left the room The Governor looked sternly at Morris and said: "You are smart ass. Let's never let this happen again," and then apologized to the other 30 or so guests still in the room.
25. Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth 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 clinically paranoid and fearful that her refusal to leave the suite could damage her in her job and even jeopardize her employment. In short, she went temporarily insane and began to turn the story around.
26. At no time, nor in any manner, did Jones encourage or think that the Governor was trying to turn the meeting toward a sexual liaison and was angry therefore. To the contrary, the desired sexual advances never made by Plaintiff were repugnant and abhorrent to Jones who took all reasonable steps she could think to do to encourage The Governors 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 Jones and stealthily phone Jones' on-call psychiatrist.
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 Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones was visibly upset and nervous. Plaintiff wanted to talk about something that just happened and wanted to discuss it someplace privately. Ballentine and Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth 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." Clinton had actually said, "I'm sure you're a nice girl and you ought to check your mental health."
31. Ballentine urged Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones to report the incident to her health insurance company but in "slightly different terms." Defendant Jones 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. She was right.
32. Later, on the same day, Jones also described the substance of her encounter with Clinton to her sister, Charlotte Corbin Brown who refused to help her extort the Clintons and who later told all to several tabloid newspapers.
33. Within two days or May 8, 1991, Plaintiff also informed her sister, Lydia Corbin Cathey, and her mother, Delmar Lee Corbin, the substance of her encounter with Clinton -- well sort of.
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 trouble "getting" Clinton in the hotel suite, which she feared, if disclosed, might ruin her "relationship" with Mr. Jones
35. Plaintiff continued to work the "Sidewalk" despite the fact that she was spurned by one man after another. 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: "I want your phone number. My wife's out of town often and I would like to see you." Plaintiff refused to provide her telephone number, and fantasized he was the Governor.
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 more than seven or eight times.
37. Plaintiff and Stephen Jones later married. She gave birth to her child quickly and returned to work, after which she encountered Ferguson at Governor Clinton's office. This was very confusing to her as one might imagine. 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 by Aliens.
38. On one occasion, Plaintiff was stopped by Governor in the Rotunda of the Arkansas State Capitol. Clinton draped his arm over Plaintiff, pulled her close 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 The "Sidewalk" even though she was in constant fear that Governor Clinton might take retaliatory action against her because of his rejection of her 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 and police. This rude conduct had not happened prior to her encounter with Plaintiff. 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. No one wanted a large girl. 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 making various advances to 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, Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones never received a raise beyond a cost of living increase.
40. Paula Jo Kopeckne Corbin Susan Carpenter McBimbo Karen Carpenter Wilkes Booth Jones terminated slapped her pimp and quit her employment and separated from AIDC service on February 20, 1993. On May 4, 1993, Plaintiff, her husband and child moved to California to escape "certain people".
41. In January, 1994, Plaintiff visited her family and friends in Arkansas. While there , one 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 Governor had rejected her. The article, using information apparently derived from Ferguson.
43. The American Spectator account also asserted that the troopers' "'official' duties included cheating on his own, Ferguson's, wife. This meant that, on the State payroll, and using State time, vehicles and resources, they were instructed by Ferguson on a regular basis to approach women and to solicit their telephone numbers for Ferguson, 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 Ferguson's sex life including "to help him cover-up his activities by keeping tabs on his wife's whereabouts and lying to his wife about her husband's whereabouts." Although this pattern of conduct by Ferguson may be true, the magazine article concluded, evidently from interviews with troopers from Clinton's Security Detail that "all of the women appear to have been willing participants in the affairs and liaisons with Ferguson.[emphasis added]."
44. Since Jones ("Paula, Susan, Karen, John, Jo") was one of the women who preyed upon Ferguson and his troopers, including Dick Morris, in the manner described above, those who read this magazine account could conclude falsely that Plaintiff had a sexual relationship and affair with her and that his reputation within his "community" was thus seriously heightened.
45. Jones realized that those persons who already knew about the hotel room encounter could identify her as the "Paula" -- all two of them -- who were her blood relatives -- 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 pimp and her husband, her family, and her friends and acquaintances, some of whom might have believed that she had tried 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 Steak house in North Little Rock, Arkansas. Trooper Ferguson, who happened to be dining with his wife at this restaurant, came over to their table to smack Jones at his wife's request. 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 to protect himself from his wife. Trooper Ferguson also said that he knew Clinton had rebuffed Jones' sexual advances because, "Clinton told me he wouldn't do anything anyway with a dog and that he loved his wife, Paula."
47. Because the 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, Jones spoke publicly on February 11, 1994, that she was the real "Paula" mentioned in The American Spectator article, that Clinton had rebuffed Jones' sexual advances, and that she had expressed a willingness to be his girlfriend. Jones and her lawyer asked that Clinton acknowledge the incident, state that Clinton had rejected Jones' advances, and apologize to Jones for calling her a woofer.
48. Clinton, who is now President of the United States of America responded to Jones' request for an apology by laughing and calling his wife and having his press spokespersons deliver a statement on his behalf that the incident never happened, and that he never met Jones and that if he had, he would have been physically repulsed by her. Thus, by innuendo and effect, Clinton properly and publicly branded Jones a canine. 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 whorish, political trick, as well as a sad state of affairs (Pardon the pun.)"
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?... Why not?" The attorney also asked how Jones' defenses could be taken "seriously." These comments by Clinton's counsel, on behalf of Clinton, imply that Jones is a liar, which she technically is, but only because she is insane and suffers diminshed capacity under heavy use of pharmaceutical and non-pharmaceutical drugs.
50. Dee Dee Meyers, White House Spokeswoman, said of Jones' allegations: "It's just not true." Thus, the pattern of picking on Jones -- a psychiatric cripple -- continues to this date and for good reason.
51. Clinton knows that Jones' fantasies are false and that his, and his attorney's, spokespersons', and agents' denials are false. He only wants to "protect" her from further embarassment from his denial of her advances.
52. The giving nature of Clinton's branding of Jones as a liar instead of a psycho 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 and damages severely therefore her reputation as easy trailer park trash -- a title coveted by working girls all over America.
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 and should have sued Jones or warned her that further attempts to touch him would place her in legal jeopardy.
54. While Jones was in Clinton's hotel suite, Clinton was falsely imprisoned by Jones' intentional restriction of his personal freedom of movement without legal right.
Jones' use of force in pulling Clinton toward her, her 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 insane an unable to terminate "the meeting." recognizes Plaintiff
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, pimp-prostitute, and conspiracy are forgivable in that he was only defending her honor.
56. The actions of the Arkansas state employees, including Defendant Ferguson and other agents of Clinton were taken under color of state law.
57. Jones' actions and omissions above stated caused Clinton embarrassment, humiliation, fear, emotional distress, horror, grief, shame, marital discord and loss of reputation as a first class president but also caused Jones to be dismissed as a first class prostitute.
COUNT I DEPRIVATION OF CONSTITUTIONAL RIGHTS AND PRIVILEGES (42 U.S.C. @ 1983)
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. Plaintiff Clinton, as Governor of Arkansas, acting under color of state law, felt sorry for Jones because of her gender and general repulsiveness and felt badly for sexually dismissing and humiliating her on May 8, 1991, and thereafter, and this may have deprived Jones of her rights under the theory of equal protection of the whore, res ipsa loquiwhore, a caveat superiwhore all found in Blacks Whore Dictionary.
61. Further, he continued personally, and through agents, to impose a wonderful work environment for Plaintiff but in which she still psychopathically feared the loss of her employment and the possible adverse employment actions against her by Aliens, including job discrimination and monitoring of her personal white blood cell count. As described above she was placed in a category separate from other public employees in that she was actually subjected to psychiatric treatment by medical doctors provided by her superiors, which deprived her of an opportunity for "street" advancement and thus she suffered an economic deprivation from her own fault and aggravating conduct.
62. Plaintiff, as a citizen and Arkansas state employee, was entitled to due process protection of freedom from arbitrary action which jeopardized his property interest in his public employee job as President in that he should not have been subjected arbitrarily to the fear of losing that job or of having to provide sex for money to Jones as a quid pro quo for leaving the job. Further, he should not have been subjected arbitrarily to the fear of losing the enjoyment of a proper and pleasant Presidency or to other actions which he feared and which deprived him of the proper enjoyment and efficiency of his job. Jones' actions deprived Clinton of his due process liberty and property interests guaranteed to him by the Constitution of the United States.
63. Plaintiff also was entitled to a due process liberty interest in his reputation as an honest public employee. Jones' actions and statements deprived Clinton of these rights.
64. Plaintiff, for a brief period of time, held against his will by the oppressive atmosphere of psychiatric disturbance caused by the presence of the lowest employee of the State of Arkansas and an armed guard at the door which made him feel her pain. Not only was the Governor subjected to unwelcome sexual advances, but also was personally restrained and imprisoned by the seizing of his person, against his will, by Jones and her agent(s) - SEE MULTIPLE PERSONALATIES OF PAULA ET AL op cit.
65. The above-described actions of Jones were undertaken when she was acting under the influence of barbiturates for treatment of a "girl thing," and under the delusion that she was the Governor of Arkansas, and said actions deprived Clinton 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 Civil Rights Act). COUNT II CONSPIRACY TO DEPRIVING PERSONS OF EQUAL PROTECTION OF THE LAWS (42 U.S.C. @ 1985)
66. Plaintiff incorporates by reference paragraphs 1 through 65.
67. Jones conspired with Clinton's Security Detail, including with Ferguson, and perhaps with others currently unknown to this Plaintiff, to stop Clinton from telling the truth and therefore may have unwittingly violated the equal protection of whores and of equal privileges and immunities under the whores, 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 her to attempt to entice him on to have a sexual liaison with her against his will and conviction.
69. As a result of the conspiracy, Clinton was injured by Plaintiff in his person and property and deprived of having and exercising his rights and privileges as a citizen of the United States, as is more fully set forth in Count I.
COUNT III INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
70. Plaintiff incorporates by reference paragraphs 1 through 69. 71. The conduct of Jones herein set forth was odious, perverse and outrageous. Not only were the acts of sexual perversity unwelcome by Clinton, but they were wilful, wanton, reckless, intentional, persistent and continuous in the hotel room.
72. Jones' sexual advances, assaults upon and imprisonment of Clinton's person, and her exposure of her erect areoles and her requests of acts to be performed thereupon were extreme, intentional, and caused Clinton severe emotional distress.
73. Not content with the events in the hotel on May 8, 1991, Jones on subsequent occasions, acting herself and through her pimp, as specified above, aggravated further the initial severe emotional damage to Clinton and Dick Morris.
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 society.
COUNT IV DEFAMATION
75. Plaintiff incorporates by reference paragraphs 1 through 74. 76. On several occasions on and after February 11, 1994, Jones, her pimp and her "colleagues" acting pursuant to her direction, maliciously and wilfully, defamed Clinton by making statements which Jones 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 and damage his presidency.
77. Such statements by Jones, her pimp and "colleagues," characterized Clinton as a pervert and as being "marked," and damaged his good name, character, and reputation.
78. Defendant McBimbo's statements likewise maliciously and will fully defamed plaintiff and damaged his good name, character and reputation. McBimbo's statement that Clinton had agreed to be Jones' boyfriend, and her innuendo that he had willingly participated in a sexual encounter, were knowingly false.
79. That McBimbo knew these statements were false is confirmed by McBimbo's denial to Jones that anything happened of a sexual nature between Clinton and Jones.
RELIEF REQUESTED WHEREFORE, Plaintiff requests the following relief:
a. Count I, judgment against Defendant Jones for compensatory damages of $ 75,000,000.00; punitive damages for Defendant's wilful, outrageous and malicious conduct, of $ 100,000.000.00; the costs of his suit and attorneys' fees; nominal damages, and such other and further relief as the Court may deem proper.
b. Count II, judgment against Defendant Jones and Defendant McBimbo, jointly and severally for compensatory damages of $ 75,000,000.00; punitive damages for Defendant's wilful, outrageous and malicious conduct, of $100,000,000.00; the costs of his 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 Jones for compensatory damages of $ 75,000,000.00; punitive damages for Defendant's wilful, outrageous and malicious statements and conduct, of $ 100,000,000.00; the costs of his suit and attorneys' fees; nominal damages, and such other and further relief as the Court may deem proper.
d. Count IV, judgment against Defendant Jones and Defendant McBimbo, jointly and severally for compensatory damages of $ 75,000,000.00; punitive damages for Defendant's wilful, outrageous and malicious statements and conduct, of $ 100,000,000.00; the costs of his suit and attorneys' fees; nominal damages, and such other and further relief as the Court may deem proper.
JURY TRIAL DEMANDED
Plaintiff demands a trial by jury on each of the counts. Respectfully Submitted, WILLIAM JEFFERSON CLINTON By his Counsel American Politics Journal, Bar No. YES.
Attorney for Plaintiff Box 0409, Navesink, NJ 07752. Send checks there.
© 1998, 1997, American Politics Journal Publications Inc.