
Excerpts from depositions of Arkansas State Troopers in the Paula Jones case
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March 16, 1998
THE WASHINGTON TIMES
Excerpts from deposition of Roger L. Perry
Q: During the time that you were with Governor's Security --I guess the years would be '89 until '92 when Bill Clinton was governor -- did you travel with him?
Mr. Perry: Yes, Sir
Q: Did there come a time when you traveled with Bill Clinton when he would point out a woman to you and ask you to get information about that woman?
Mr. Perry: Yes, Sir.
Q: Was this something that happened more than once?
Mr. Perry: To actually ask me to get a woman's name and number, one time. ...
Q: What was the specific instance, do you recall that?Mr. Perry: It was in Augusta, Arkansas, at a Christmas parade. ... The governor was in a convertible. He was riding in the convertible, and it was crowded, real cold, and he got out. We were walking, and he noticed this lady in the crowd, was talking about how beautiful she was, how pretty she was. And he said, "Find out who that is."
Q: Do you know the name (Jane Doe 1)?Mr. Perry: Yes Sir, I do.
Q: Have you ever seen her come to the Governor's Mansion while you were on Governor's Security?
Mr. Perry: Personally just to see her come in to visit the governor, no, Sir.
Q: Did you ever have a conversation with Danny Ferguson about (Jane Doe 1)?
Mr. Perry: Yes, Sir.
Q: Would you describe that conversation?
Mr. Perry: I walked in the guard shack that morning to relieve Danny, and Danny said, "You're not going to believe what that son of a bitch has done now ... The governor had me call (Jane Doe 1) and told me what --even told her to wear: a trench coat, a hat, and to use her maiden name when she pulled up to the checkpoint." ... And Danny escorted her to the basement area of the Governor's Mansion ... And delivered her to Governor Clinton."
Q: Did Danny Ferguson say whether he had to stand guard?
Mr. Perry: He told me he stood on the stair just in case Hillary or Chelsea woke up. ...
Q: What kinds of things would you do to conceal these encounters from Hillary Clinton?
Mr. Perry: Lie to her on the phone about his whereabouts late at night.
Q: Did that ever happen?
Mr. Perry: Yes. He did it on a few occasions, and nothing ever happened. One night Hillary did wake up and called downstairs and asked me, and she said, "Roger, where's Bill?" and that's the exact words she used, "Where's Bill?" And I said, "Hillary, he had insomnia. He couldn't sleep, so he went for a drive."
She started screaming and cussing and slammed the phone down. I got on the phone and called him and I said, "Governor, Hillary's up," and he said, "Oh, my God. Oh, God. Oh, God," and he came in the back gate probably five to ten minutes later. ...
Q: Did he indicate to you why he was upset that --
Mr. Perry: No. All he was saying was, "My God. My God. I'll be right there. I'll be right there." ...
Excerpts from the deposition of Larry G. Patterson
Q: You said that you were with Governor's Security from 1987 to 1993, correct?
Mr. Patterson: Yes, sir. ...
Q: Who was the governor at the time you began in Governor's Security?
Mr. Patterson: Bill Clinton. ...
Q: At the time you went on the Governor's Security, had you heard or did you have any information about whether Gov. Clinton had any extramarital sexual relationships with women?
Mr. Patterson: Rumor only.
Q: After you went on the Governor's Security, did there come a time when you acquired firsthand knowledge that this was the case?
Mr. Patterson: Yes.
Q: How long was that, and how did it come about?
Mr. Patterson: Within two to three months of being on the detail, Gov. Clinton asked me to take him places, to get women's telephone numbers, addresses for him.
Q: Did you have to go through a kind of a period of time where you earned the governor's confidence before he'd do this?
Mr. Patterson: I think there was a period, yes, that he tested each one of the troopers to --
Q: How would he do that?
Mr. Patterson: An example would be that we would be driving down the street,
and we'd see some attractive lady, and he would ask me, "Larry, what would you like to do to that lady?"
Q: During the time that you would travel with him to political events around the state, would there ever be occasions when Bill Clinton would ask you to solicit women for him?
Mr. Patterson: There has been a number of times when Bill Clinton has told me, "The lady in the red dress," the "lady in the green dress," whatever, or color of hair or distinguishing characteristic, "would you go get me her name and her phone number. She has that come-hither look."
Q: And would you go get their name and phone number?
Mr. Patterson: Yes, sir, I did.
Q: And give it to Bill Clinton?
Mr. Patterson: Yes, sir, I did.
Q: Do you have any knowledge of whether there was any follow-up to that by Bill Clinton?
Mr. Patterson: On one of the females, yes ... she appeared on numerous occasions afterward.
Q: When you say "she appeared," what do you mean?
Mr. Patterson: She came -- her first appearance was at the Governor's Mansion. She came on a Saturday, and the governor called me out at our office and told me that he was expecting a guest, that he had a friend coming for a tour of the Governor's Mansion. She showed up. I buzzed him in the house. I said, "Governor, I think your guest is here." He just said, "Just bring her to the back door." So I brought her to the kitchen door. He was waiting in the kitchen for her. I turned left, went back, got into our office.
Q: Do you know that woman's name?
Mr. Patterson: Yes, sir, I do.
Q: What is that woman's name.
Mr. Patterson: (Jane Doe 1). ...
Q: When she showed up at the Governor's Mansion on a Saturday, was Hillary Clinton there at the time.
Mr. Patterson: She was out of town. ...
Q: Now, we started talking about (Jane Doe 1) when we were talking about how you would --how Gov. Clinton would ask you to approach a woman and --
Mr. Patterson: Yes, sir.
Q: -- get her name and phone number and so forth. How many times would you estimate that he asked you to do this and you did it?
Mr. Patterson: 15, 20 occasions.
Q: Did you ever travel with him out-of-state?
Mr. Patterson: Yes. ... We went to a fund-raiser in Washington, D.C. There was a lady in the audience there ... and later that night he called me and asked me to bring him some money, that he did not have any money -- I had already gone to my room -- and met him in the bar area of the hotel and gave him some money that evening.
Q: Was he by himself when you met him in the bar area?
Mr. Patterson: He was in the presence of a young lady. ...
Q: When you would approach a woman where Gov. Clinton had asked you to approach a woman and find out her name and phone number and so forth, would you tell her that you were with the Governor's Security staff?
Mr. Patterson: The procedure -- I don't know what anyone else done. The procedure I used, I walked up and said, "Ma'am, I'm Larry Patterson. I'm a state policeman. I'm assigned to the governor. The governor is interested in you. He would like your name and your phone number.
Q: Did you know the name, Gennifer Flowers?
Mr. Patterson: Yes, sir.
Q: Do you know where she lived?
Mr. Patterson: At the Quapaw Towers. ...
Q: Did you ever take Gov. Clinton to the Quapaw Towers?
Mr. Patterson: Yes, sir, on many occasions.
Q: When you say "many occasions," how many do you mean? Can you give us a ballpark number?
Mr. Patterson: 15, 20, 25. ...
Q: Do you have any knowledge whether Bill Clinton ever said anything to anyone or made any effort to help Gennifer Flowers get a job with the Arkansas State government?
Mr. Patterson: I was in the car with the governor when he called Bill Gaddy on the phone and told Bill. ... "The lady that we talked about the other day, I would really like to see her have that job. She's a personal friend of mine, Bill. I want it done."
Q: Who is Bill Gaddy?
A. Bill Gaddy was director of the employment security division at that time. ...
Q: Do you know the name of... (Jane Doe 3)?
Mr. Patterson: Yes, sir, I do.
Q: Who is ... (Jane Doe 3)?
Mr. Patterson: She's an attorney that was here in Little Rock. ...
Q: Did she ever come to visit Bill Clinton at the Governor's Mansion?
Mr. Patterson: She was there on one occasion.
Q: When she came to the Governor's Mansion, was that a time when Hillary was gone?
Mr. Patterson: Yes, sir.
Q: Now, have you given interviews to a publication called The American Spectator?
Mr. Patterson: Yes, sir, I did.
Q: And in reading some publications by The American Spectator, they report that you described an incident where Gov. Clinton met a woman in a school yard.
Mr. Patterson: Yes, sir. ... he said, "I've got someone I need to see." I said, Okay. "Where are we going?" He said, "To Booker Elementary School."
So we went to Booker Elementary School, and he said, "I've got a friend waiting down here, Larry, and I'd like to spend some time alone with her." ...
This particular lady was driving a small red compact car. It was parked beside the school underneath a streetlight. ... I was out of the car smoking, could see the activities going on. Two Little Rock city policemen pulled up. Said, "What are you doing here?"
I I.D.'d myself. I said, "I've got a friend that's meeting a married lady down here, and they'd like some privacy."
The Little Rock city policeman on the passenger side said, "If the school gets burglarized, I hope you can cover this.
I said, "Yeah, I can cover this. No problem." ...
Q: You said that the woman's car was under a streetlight and you could see what's going on?
Mr. Patterson: Yes, sir.
Q: What was going on? What did you see?
Mr. Patterson: I saw Bill Clinton on the passenger side of the front seat. I saw the woman get into the driver's side. I saw her head disappear into what looked like his lap.
Q: Did that woman ever come to the Governor's Mansion?
Mr. Patterson: Yes, sir.
Q: What was the incident? Can you describe that? ...
Mr. Patterson: A small Datsun Toyota pickup truck came in, drove right up into the parking lot where normally Hillary's car was parked or just on the other side of it, buzzed him in the house. He walked out. He had got in the car with this lady. I remember it being extremely cold that night. The engine was running on the vehicle, could see smoke coming out. ... In the back of the mansion, there's a security camera. It's a pan-tilt-zoom camera that would go almost completely around 360 degrees, just like a short distance right at one edge of the back of the mansion going completely 360 degrees. ...
While this act was going on in the truck, I put the camera in that area, zoomed in, and saw this lady performing oral sex on the governor. ...
Q: Was Hillary out of town at that time?
Mr. Patterson: She was out of town. ...
Excerpts from the deposition of Danny Ferguson:
Q: What years were you on the Governor's Security Detail, Mr. Ferguson?
Mr. Ferguson: I went there in April of '88, and I left in July of '95.
Q: Do you know a woman named (Jane Doe 1)?
Mr. Ferguson: ... I had taken her -- she had come up to the mansion after the governor had been elected president before he was sworn in and went in and saw the governor early in the mornings.
Q: Describe how that happened.
Mr. Ferguson: usually it happened -- all except one time it happened when I was working midnights. He would call out about five o'clock in the morning saying that (Jane Doe 1) was coming by. ... So the president-elect would let me know she was coming to the gate, to let her -- you know, let him know it was okay to come in.
She would come in, park over by the security shack. I would go out and meet her and then take her downstairs to -- used to be the game room. ... I would go upstairs. ... I'd tell him that she was there. ...
Q: Well, what's your recollection at this point in time about what happened when you met Paula Jones?
Mr. Ferguson: ... Ms. Jones was sitting at the table with another female. I recognized her just by the face. I didn't know her name at that point.
I went over and started small-talking with her, and they were kind of giggling about the governor's pants being too short. And they -- she said that she thought he was good-looking, had sexy hair, wanted me to tell him that. Also wanted me to -- that's when she said she'd like to meet him, so I told him that. And he had come back that she had that come-hither look, and there's a few things said back and forth.
He stayed out there -- I really don't know how much longer --talking to people, and he motioned for me to come over to him. He asked me to see if I could get him a room, that he was expecting a call from the White House and that he had several phone calls that he needed to make, for me to go to the car, get his briefcase because his phone messages were in there. So I got the briefcase. I went to the front desk. I told them what the governor needed. They gave me to, I guess, the manager, assistant manager, who gave me the key to a room. I went back and got him, took him upstairs to the room. I believe it was then that he told me that if Paula wanted to meet him, that she can come up. So I wrote the number down on a piece of paper, went down to her, gave it to her thinking if she wanted to go up, she'd go up. She said that she didn't know whether she could get away from the desk there. I told her, "It's no big deal. I'll just tell the governor. " I said, "I'm going around the comer to sit on a couch."
It wasn't, oh, three or four minutes she came around the comer. I was sitting on the couch. I asked her, "How did you get away?" She said she told them that she wasn't feeling well, that she needed to go to the bathroom. I thought she'd go on up, but she kept staying. I said, "Do you want me to walk up with you?" and she said, "Yeah."
So I walked up to the -- we rode up the elevator. I believe it was the eighth floor, I believe it was. We got off the elevator. I pointed in the direction of the room. I immediately turned and went back downstairs to the second floor where the governor told me to wait. ...
About 15, 20 minutes later, maybe a bit longer -- I'm not sure -- she came back down. She was smiling. She walked up to me and asked me if the governor and I were going to be at the conference the remainder of the day, and I said that his schedule had that on there, except for we'd go back to the mansion around lunchtime for a -- I believe it was a photo op. And then she asked me if the governor had any girlfriends. I said, "no." She said that she would be his girlfriend.
Q: When is the next time you saw Paula Jones?
Mr. Ferguson: About a week or two later at the governor's office.
Q: And did you-all have any discussion the next time you saw her?
Mr. Ferguson: Yes, sir. She called me out of the -- I was in the reception area. She called me out the door into the hallway. ...
Q: What did you say, and what did she say?
Mr. Ferguson: She asked me if the governor had asked about her. I said, "No." She asked me for a piece of paper. She wrote her phone number down and said, "If he wants to talk to me, he can call me at this number. If my boyfriend answers, either hang up or tell him you've got the wrong number." ...
Q: When she gave you that information, did you convey it to the governor?
Mr. Ferguson: No, sir, I threw it away as soon as I walked back in the door.
Excerpts from the deposition of L.D. Brown:
Q: What was the process that you would go through in soliciting women for Bill Clinton?
Mr. Brown: I would talk to them personally, sometimes give them my business card. If they were from out of town, I would find out where they were staying. If we were out of town and/or in town anywhere in Arkansas, I would try to get their telephone number and introduce them subsequently to the governor. ...
Q: Well, what would happen from there? I mean, do you have knowledge of Governor Clinton then actually meeting with these women, some of them?
Mr. Brown: Just from him, not any of those kind of solicitations, whatever you want to call it. I don't -- one happened in ... Boca Raton [Fla.]. That was an out-of-town thing.
Q: What was that incident? ...
Mr. Brown: A couple of the girls came over, and when it was time to go and pay the bill, the governor got in the car with the girl that I had given the card to, and we followed them to an area that was under development. It was kind of a remote area from this club and pulled over, Ralph and I did. And around in front of them -- she stopped, and then we pulled on around in front of them, and they stayed back there in the car for a few minutes. I can't remember how long, but -- and then the governor came back and jumped in the back seat, and we left and went back to the hotel. ...
Q: When Bill Clinton got back in the car with you after he left the car where he had been with the woman, what did he say to you about what they had done in there.
Mr. Brown: Well, he indicated in so many words that she had performed oral sex on him. I cleaned it up a little bit. ...
Reposted with permissionNational Weekly Edition, The Washington Times