The Court Should Not Limit Discovery into Plaintiffs Sexual Conduct.
At the same time she is seeking unfettered discovery against the President, plaintiff makes another attempt to limit the scope of discovery with her respect to her own conduct. (Mot. at 8-10). Plaintiff omits to mention that she has claimed damages based solely on emotional suffering and that she has also asserted a claim for intentional infliction of emotional distress. Moreover, as the court has stated, such discovery is necessary to locate and preserve evidence that the defendants may need for rebuttal.
Paula Jones was known for her reputation for giving blowjobs in parking lots
Plaintiff also complains that the court is over solicitous of the President, but appears to lack "any concern for potentially embarrassing Plaintiff, with respect to equally damaging and irrelevant information." (Mot. at 11) (emphasis in original). This court has already given the plaintiff an extremely wide berth, allowing her to pursue "other conduct" discovery far broader than that allowed in any other case of which we are aware.
The court in fact has essentially not limited discovery in this regard; it simply has imposed a sequence in which questions must be posed to Jane Doe deponents.
Additionally, the court has taken every step to minimize the disclosure of this kind of information with respect to both parties, by placing all discovery under seal, and by repeatedly stating that only a limited amount of "other acts" conduct will be admitted at trial against either party. Accordingly, there are no grounds for limiting discovery regarding plaintiff at this point.
By: _________________ Robert S. Bennett, Esq. Carl S. Rauh, Esq. Mitchell S. Ettinger, Esq. Amy Sabrin, Esq. Kathrine S. Sexton , Esq. SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 1440 New York Avenue., N. W. Washington, DC 20005 (202) 371-7000
Kathlyn Graves, Esq. WRIGHT, LINDSEY & JENNINGS 200 West Capitol Avenue Suite 2200 Little Rock, Arkansas 72201 (501) 371-0808
Stephen Engstrom, Esq. WILSON, ENGSTROM, CORUM, DUDLEY & COULTER 809 West Third Street Little Rock Arkansas 7202 Counsel to President William J. Clinton
Dated: January 7, 1998
* Deposition of Michael King, Dec. 29, 1997, at 4-60. We will provide the court with a transcript of Mr. King's deposition if the court desired.
The entire brief, in Adobe Acrobat format, may be downloaded from the Washington Post website, at the following address:
or viewed directly at: http://184.108.40.206/1019jones/19980107-216.pdf
Background information is at http://www.shamema.com/parking.htm