Paula Jones' original lawyers withdrew from her case in September of 1997. In December, her new lawyers, led by Donovan Campbell, Jr. of Dallas, Texas, filed a revised complaint against President Bill Clinton and former Arkansas state trooper Danny Ferguson.

In August, U.S. District Judge Susan Webber Wright dismissed Jones' claims that Clinton defamed her after the alleged harassment incident between the two by denying the charges.

This amended complaint, filed on December 8, 1997, drops the defamation charge against Ferguson and reduces the damages sought to $525,000.

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

PAULA JONES,

Plaintiff,

v.

WILLIAM JEFFERSON CLINTON
and DANNY FERGUSON,

Defendants.

CIVIL ACTION NO. LR-C-94-290

Judge Susan Webber Wright

(Jury Trial Demanded)

PLAINTIFF'S FIRST AMENDED COMPLAINT

Plaintiff Paula 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 the tort of outrage or intentional infliction of emotional distress.

JURISDICTION

1. This Court has subject matter jurisdiction pursuant to (a) 28 U.S.C. Section 1331, because the case arises under the Constitution and laws of the United States; (b) 28 U.S.C. Section 1343, because this action seeks redress and damages for violation of 42 U.S.C. Section 1983 and 1985 and, in particular, the due process, free speech, right-to-petition, and equal protection provisions of the United States Constitution, including the rights protected in the First, Fifth, and Fourteenth Amendments thereof; (c) 28 U.S.C. Section 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; and (d) 28 U.S.C. Section 2201, because this action seeks a declaratory judgement of the rights and legal relations of the parties in a case of actual controversy. This Court also has jurisdiction over the cause of action alleged in Count III pursuant to federal pendent jurisdiction.

2. Venue is appropriate in this judicial district under 28 U.S.C. Section 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.

The Parties

3. Plaintiff Paula Jones (hereinafter "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 (hereinafter "Defendant Clinton") is a citizen of the State of Arkansas or alternatively of the District of Columbia.

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

FACTS

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 office 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. Defendant 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 Defendant Ferguson, Blackard and Jones about what the Governor could want. Jones, who was then a rank-and-file Arkansas state employee being paid approximately $6.35 an hour, thought it was an honor to be asked to meet the Governor. Defendant 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 Defendant Clinton answered. Plaintiff entered. Defendant 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. Defendant 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. Defendant 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, Defendant 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, and without Plaintiff's consent, Defendant Clinton put his hand on Plaintiff's leg and started sliding it toward the hem of Plaintiff's culottes, apparently attempting to reach Plaintiff's pelvic area. Defendant Clinton further bent down to attempt to kiss Jones on the neck, also without her consent.

21. Defendant Jones exclaimed, "What are you doing?" and escaped from Defendant Clinton's physical proximity by walking away from him. Jones tried to distract Defendant Clinton by chatting with him about his wife and her activities. Jones later took a seat at the end of the sofa nearest the door. Defendant Clinton asked Jones: "Are you married?" She responded that she had a regular boyfriend. Defendant 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 Defendant Clinton's genital area that were obvious to Jones.

23. Jones became horrified, jumped up from the couch, absolutely refused to engage in such conduct, 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. Defendant Clinton, while fondling his penis, said: "Well, I don't want to make you do anything you don't want to do." Defendant 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, Defendant 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 to whom Defendant Clinton had previously referred. Defendant 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 Defendant 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 Defendant Clinton to turn the meeting toward a sexual liaison. To the contrary, the unwanted sexual advances, batteries, and assaults committed by Defendant Clinton were repugnant and abhorrent to Jones, who took all reasonable steps she could think of to terminate Defendant 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. Defendant Ferguson did not escort Plaintiff back to the registration desk. Jones said nothing to Defendant 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, emotional, and nervous. Plaintiff wanted to talk about something that had 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 Defendant Clinton in the hotel suite. According to Ballentine, Jones told her that Defendant 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 to the police or to her AIDC superiors. Plaintiffs responded that it was the State Police themselves who had just jointly perpetrated, with Defendant Clinton, this heinous conduct upon her and that Defendant Clinton had sternly admonished her that her boss at the AIDC was Defendant Clinton's very good friend. Thus, Plaintiff realized that the police and the AIDC would stifle any petition of hers for redress, and she correctly feared that, if she did so report, she would lose her job.

32. Later, on the same day, Plaintiff also described the substance of her encounter with Defendant 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, of the substance of her encounter with Defendant 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 Defendant Clinton in the hotel suite.

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, Defendant 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, Defendant Ferguson approached Jones and asked: "How's Steve?" This frightened Plaintiff and made her feel as if she were being watched and was not safe. She had never told Defendant Ferguson or Defendant Clinton the name of her fiance.

37. Plaintiff and Stephen Jones later married. She gave birth to her first child and returned to work, after which she encountered Defendant Ferguson at Governor Clinton's Office. Defendant 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 Defendant Clinton in the Rotunda of the Arkansas State Capitol. Defendant 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?" Defendant 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 would take retaliatory action against her because of her rejection of his abhorrent sexual advances and in order to further chill and squelch her potential reporting of these incidents to appropriate authorities. 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 Defendant 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 Defendant 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. This discriminator treatment contrasts vividly with Defendants' treatment of other women who succumbed to Defendant Clinton's predatory custom, habit, pattern, and practice of using State payroll, time, vehicles, personnel, and resources to solicit sexual favors and who provided such favors because Defendants systematically granted, directly and indirectly, governmental and employment benefits, appointments, advancements, raises, promotions, positions, and perquisites to such other women.

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

41. In January 1994, Plaintiff visited her family and friends in Arkansas. While Jones was in Arkansas, Ms. Ballantine 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 Defendant 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 Danny Ferguson), who had escorted "Paula" to Defendant 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 Defendant Clinton, as well as a willingness to continue a sexual relationship with him. These assertions were and are untrue. The article, using information apparently derived from Defendant 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 resources, 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 Defendant 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." This reported pattern of conduct by Defendant Clinton is accurate and reflects Defendants' unconstitutional actions taken under color and pretense of state law, regulation, custom, usage, habit, pattern, and practice.

44. Since Jones ("Paula") was one of the women preyed upon by the Defendant Clinton and his troopers, including Defendant Ferguson, in the manner described above, those who read this magazine account could conclude falsely that Jones ("Paula") had a consensual sexual relationship and affair with Defendant Clinton.

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 Defendant 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 then wife at this restaurant, first hailed Jones in a loud voice and later came over to Jones' 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 very 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 refused Defendant Clinton's sexual advances because: "Clinton told me you wouldn't do anything anyway, Paula." Trooper Ferguson further suggested to Jones that she could make over $1,000,000.00 by selling her story to some publication such as the National Enquirer, as to which Plaintiff conveyed no interest.

47. Because the false statements appearing in The American Spectator article that Jones was willing to have sex with Defendant 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 Defendant Clinton's sexual advances, and that she had not expressed a willingness to be his girlfriend. Jones and her lawyer asked that Defendant Clinton acknowledge the incident, state that Jones had rejected Defendant Clinton's advances, and apologize to Jones.

48. Defendant 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, Defendant Clinton publicly branded Plaintiff a liar. Moreover, as recently as the week the original Complaint was filed herein, Defendant Clinton, through his White House aides, stated that Plaintiff's account of the hotel room incident was untrue and a "cheap political trick."

49. Defendant Clinton hired an attorney, who, as Defendant 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."

50. Dee Dee Meyers, White House Spokeswoman, said of Jones' allegation: "It's just not true." Thus, the pattern of attempting to intimidate, chill, and squelch Jones continues to this date.

51. Defendant 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 Defendant Clinton's branding of Jones as a liar is aggravated in that a greater stigma is suffered by Jones from the statements of the President of the United States, in whom the general public usually reposes trust and confidence in consideration of the traditional integrity of the holder of that office.

53. Defendant Clinton, a member of the Arkansas State Bar, former law partner at the firm of Wright, Lindsey & Jennings, and former Attorney General of Arkansas, 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 Defendant Clinton's hotel suite, Jones was falsely imprisoned by Clinton's intentional restriction of her personal freedom of movement without legal right. Defendant 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 Defendant 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 Defendant Clinton under the doctrines of agency, joint conduct, master-servant, respondent superior, and conspiracy.

56. The actions of Defendant Clinton and the Arkansas state employees, including Defendant Ferguson and other agents of Clinton were taken under color and pretense of state law, regulation, custom, usage, habit, pattern, and practice.

57. Defendant Clinton's and Defendant Ferguson's extreme and outrageous actions and omissions above stated caused Jones embarrassment, humiliation , fear, emotional distress, horror, grief, shame, and damage. Moreover, Defendants have continued and repeated such heinous conduct against other women and will, in all probability, continue to repeat this extreme and outrageous conduct against women unless severely sanctioned by this Court through the award of punitive and exemplary damages against each Defendant.

58. Plaintiff incorporates by reference paragraphs 1 through 57.

59. Plaintiff is entitles to the equal protection of the laws under the Fourteenth Amendment of the United States Constitution, to due process of law under the Fifth and Fourteenth Amendments of the United States Constitution, and to freedom of speech and the right to petition the Government for redress of her grievances under the First Amendment of the United States Constitution.

60. Defendant Clinton, individually and as Governor of Arkansas, acting under color and pretense of state law, regulation, custom, usage, habit, pattern, and practice, discriminated against Plaintiff because of her gender by sexually harassing and assaulting her on May 8, 1991, and thereafter, and this conduct deprived Jones of her right to equal protection of the law. Defendant Clinton, further so acting, also discriminated against Plaintiff because of her sex by systematically granting, directly and indirectly, governmental and employment benefits, appointments, advancements, raises, promotions, positions, and perquisites to other women who succumbed to Defendant Clinton's predatory custom, usage, habit, pattern and practice of using State payroll, time, vehicles, personnel, and resources to solicit sexual favors and who provided such favors, while continually denying, directly and indirectly, any such appointments, benefits, advancements, raises, promotions, positions, and perquisites to Plaintiff because she would not accede to Defendant Clinton's repeated solicitations of sex from her. This conduct further deprived Plaintiff of her right to equal protection of the law. Additionally and alternatively, Defendant Ferguson was a willful participant in said joint action with Defendant Clinton in committing such discriminatory conduct, and there was a mutual understanding and a meeting of the minds between them in perpetrating such heinous conduct, as evidenced by, inter alia, Defendant Ferguson's admission to Plaintiff that "we do this all the time for the Governor."

61. Further, Defendant Clinton continued, personally and through agents, directly and indirectly, 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 rudeness and hostility by her superiors, which deprived her of an opportunity for advancement, and she suffered economic depravation. In contrast, other women who succumbed to Defendant Clinton's said predatory pattern and practices and provided him sexual favors were not subjected to such a hostile work environment but were, in fact, frequently granted employment benefits, appointments, advancements, raises, promotions, positions, and perquisites, directly and indirectly, by Defendants and their subordinates in government.

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, as did numerous other women in order to obtain or keep their governmental jobs or employment positions. Further, Plaintiff 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. Defendant Clinton's actions deprived Jones of her due process liberty and property interests guaranteed to her by the Constitution of the United States of America.

63. Plaintiff also was entitled to freedom of speech and the absolute right to petition the Government for redress of her grievances under the First Amendment of the United States Constitution. By virtue of Defendant Clinton's overt and covert warnings, admonitions, intimidations, and threats to Plaintiff to "keep this to yourself" (or words to that effect) and that he would speak to Plaintiff's boss, and by virtue of Defendant Ferguson's pointed inquiries and implied threats to Plaintiff regarding "how's Steve," Defendants acting under color and pretense of state law, regulation, custom, and usage, intentionally infringed and violated Plaintiff's said First Amendment rights, privileges, and immunities and deprived her of same by chilling and squelching Plaintiff's exercise of such rights in reporting Defendant's heinous conduct to governmental authorities for proper redress.

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 she was also personally restrained and imprisoned by the seizing of her person against her will, by Defendant Clinton and his agent.

65. The above-described actions of Defendant Clinton were undertaken when he was acting under the color and pretense of state law, as described above, as Governor of Arkansas, and said actions of Defendant Ferguson were undertaken when he was acting under the color and pretense of state law as an Arkansas State Trooper and Police Officer. Said actions deprived Jones of federal equal protection, due process, and free speech and petition rights guaranteed by the First, Fifth, and Fourteenth Amendments of the United States Constitutions and caused Plaintiff actual damage and injury, for which she hereby sues Defendants, jointly and severally. Said conduct is made actionable by 42 U.S.C. § 1983 (the Civil Rights Act).

66. Plaintiff incorporates by reference paragraphs 1 through 65.

67. Defendant Clinton conspired with his Security Detail, including with Defendant Ferguson, and perhaps with others currently unknown to Plaintiff, for the purpose of depriving, directly or indirectly, Jones of equal protection of the laws and of equal privileges and immunities under the laws, and for the purpose of hindering the constituted authorities of Arkansas from securing to Plaintiff the equal protection of the laws, as further set forth in Count I above.

68. The conspirators, including Defendants, committed some overt acts in furtherance of the conspiracy, which include: contacting Jones and bringing her to Defendant Clinton on May 8, 1991 to permit him to entice her on to have a sexual liaison with him; systematically granting, directly and indirectly, governmental and employment benefits, appointments, advances, raises, promotions, positions, and perquisites to other women who succumbed to Defendant Clinton's predatory custom, usage, habit, pattern, and practice of using State payroll, time, vehicles, personnel, and resources to solicit sexual favors and who provided such favors, while continually denying, directly and indirectly, any such appointments, benefits, advancements, raises, promotions, positions, and perquisites to Plaintiff because she would not accede to Defendant Clinton's repeated solicitations of sex from her; and chilling and squelching Plaintiff's free-speech and right-to-petition privileges by overtly and covertly warning, admonishing, intimidating, and threatening Plaintiff to keep quiet about said heinous conduct.

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. Defendants thereby caused Plaintiff actual injury and damages, for which she hereby sues Defendants, jointly and severally.

70. Plaintiff incorporates by reference paragraphs 1 through 69.

71. The conduct of Defendant Clinton and Defendant Ferguson herein set forth was odious, perverse and outrageous. Not only were the acts of sexual perversity, misconduct, and assault unwelcome by Jones, but they were willful, wanton, reckless, intentional, persistent and continuous in the hotel room and thereafter. Thus, Defendants intended to inflict emotional distress or knew or should have known that emotional distress was the likely result of such heinous conduct.

72. Defendant Clinton's sexual misconduct and advanced, sexual assaults upon imprisonment of Jones' person, and his exposure of his erect penis and his requests of acts to be performed thereupon was extreme, outrageous, and intentional and wilfully or wantonly caused Jones emotional distress so severe in nature that no reasonable person could be expected to endure it.

73. Not content with the events in the hotel on May 8, 1991, Defendant 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 society, and said actions caused Plaintiff's emotional distress to be so severe that no reasonable person could be expected to endure it. Accordingly, Defendants' said actions caused Plaintiff actual injury and damages, for which she hereby sues Defendants, jointly and severally.

75. Plaintiff incorporates by reference paragraphs 1 through 74.

76. In accordance with 28 U.S.C. § 2201 and Federal Rule of Civil Procedure 57, Plaintiff hereby sues for a declaratory judgment of the rights and legal relations of the parties hereto, as this action presents a case of actual controversy.

77. Specifically, Plaintiff hereby sues for an order of this Court declaring that:

(a) Plaintiff has and is entitled to the rights privileges, and immunities under the First, Fifth, and Fourteenth Amendments of the United States Constitution to equal protection, due process, and free speech and petition as claimed above in paragraphs 1, 59, 62, 63, 65, and 67 and as applied to the facts plead above in paragraphs 1, 6-57, 60-65, and 67-68;
(b) Defendants have, jointly and severally, violated said rights, privileges, and immunities of Plaintiff as set out above under color and pretense of state law, regulation, custom, usage, habit, pattern, and practice, thereby deprived Plaintiff of such rights, privileges, and immunities, and caused her actual damage and injury;
(c) Defendants are thus jointly and severally liable to Plaintiff for such damages under 28 U.S.C. § 1983;
(d) Defendants conspired together to deprive Plaintiff, directly or indirectly, of equal protection of the laws and of equal privileges and immunities under the laws and to hinder the constituted authorities from securing to Plaintiff the equal protection of the laws;
(e) Defendants committed some overt acts in furtherance of said conspiracy, as set out in paragraph 68 above;
(f) as a result thereof, Plaintiff was injured by Defendants in her person and property and deprived of exercising her rights and privileges as a U.S. citizen;
(g) Defendants thus are jointly and severally liable to Plaintiff for such damages under 28 U.S.C. § 1985(3);
(h) Defendants' actions against Plaintiff were extreme, outrageous, and intentional and wilfully or wantonly caused Plaintiff emotional distress so severe that no reasonable person could be expected to endure it;
(i) Defendants intended to inflict such emotional distress or knew or should have known that such distress was the likely result of such conduct;
(j) Defendants' actions caused Plaintiff actual injury and damages, and Defendants thus are jointly and severally liable to Plaintiff for such damages;
(k) Defendants are liable to Plaintiff for punitive damages because of their wilful, outrageous, and malicious conduct committed with evil motive or intent and reckless or callous indifference to the rights of Plaintiff;
(l) Defendants should be required to pay significant punitive damages in order to punish them and to deter them and others from continuing to commit such heinous conduct against other women, as they have done; and
(m) Defendants are liable, jointly and severally, to Plaintiff for at least nominal damages and for Plaintiffs' attorneys' fees and expenses and costs of suit, under 28 U.S.C. § 1988, since Plaintiff is the prevailing party herein.

Wherefore, Plaintiff prays for and requests the following relief:

a. With respect to Count I, judgement against Defendants Clinton and Ferguson, jointly and severally, for compensatory damages in an amount within the jurisdictional limits of this Court and to be determined by the jury, but not less than $75,000.00; punitive damages for Defendants' willful, outrageous and malicious conduct committed with evil motive or intent and reckless or callous indifference to the rights and welfare of Plaintiff and others in an amount within the jurisdictional limits of this Court and to be determined by the jury, but not less than $100,000.00, in order to punish Defendants and to deter them and others like them from continuing to commit the heinous conduct complained of herein against other women, which conduct they have repeated as against other women and will continue to repeat unless severely sanctioned by this Court; the costs of her suit and attorneys' fees and expenses under 28 U.S.C. § 1988; nominal damages; and such other and further relief, special or general, at law or in equity, as the Court may deem proper.

b. With respect to Count II, judgment against Defendants Clinton and Ferguson, jointly and severally, for compensatory damages in an amount within the jurisdictional limits of this Court and to be determined by the jury, but not less than $75,000.00; punitive damages for Defendants' willful, outrageous and malicious conduct committed with evil motive or intent and reckless or callous indifference to the rights and welfare of Plaintiff and others in an amount within the jurisdictional limits of this Court and to be determined by the jury, but not less than $100,000.00 in order to punish Defendants and to deter them and others like them from continuing to commit the heinous conduct complained of herein against other women, which conduct Defendants have repeated as against other women and will continue to repeat unless severely sanctioned by this Court; the costs of her suit and attorney's fees and expenses under 28 U.S.C. § 1988; nominal damages; and such and further relief, special or general, at law or in equity, as the Court may deem proper.

c. With respect to Count III, judgment against Defendant Clinton for compensatory damages in an amount within the jurisdictional limits of this Court and to be determined by the jury, but not less than $75,000.00; punitive damages for Defendant's willful, outrageous and malicious statements and conduct in an amount within the jurisdictional limits of this Court and to be determined by the jury, but not less than $100,000.00; the costs of her suit and attorney's fees and expenses; nominal damages; and such other and further relief, special or general, at law or in equity, as the Court may deem proper.

d. With respect to Count IV, declaratory judgment against Defendant Clinton and Defendant Ferguson, jointly and severally, for those declarations and orders set forth in Count IV above; the costs of her suit and attorneys' fees and expenses; and such other further relief, special or general, at law or in equity, as the Court may deem proper.