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Jones v. Clinton Special Report

Discovery Requests

Jones's Second Set of Questions for Clinton

This is the complete and unedited text of the second set of interrogatories for President Clinton filed by Paula Corbin Jones's lawyers. It is dated Oct. 1, 1997.

Among the information requested: The name of any doctor who has performed a medical procedure on Clinton's genitalia and the name of any individual with whom he has had sexual relations while holding elected office. Jump to the questions.

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

PAULA CORBIN JONES,
Plaintiff,

WILLIAM JEFFERSON CLINTON
and DANNY FERGUSON,
Defendants.

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CIVIL ACTION NO. LR-C-94-290

Judge Susan Webber Wright

SECOND SET OF INTERROGATORIES
FROM PLAINTIFF TO DEFENDANT CLINTON

TO: William Jefferson Clinton

Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Plaintiff Paula Jones hereby propounds the following written interrogatories to you. You are required to serve a written response, in full compliance with the applicable rules of procedure, on or before Monday, November 3, 1997.

DEFINITIONS

For the purposes of these requests, the following definitions apply:

"Defendant Clinton" means William Jefferson Clinton.

"Document" means any tangible thing on which appears, or in which is stored or contained, any words, numbers, symbols, or images. The term "document" includes any and all writings, drawings, graphs, charts, photographs, phono records,

and other data compilations from which information can be obtained and translated, if necessary, through detection devices, into reasonably usable form.

"Person" means any identifiable entity, including but not limited to individuals, corporations, partnerships, sole proprietorships, and unincorporated associations.

"You" means William Jefferson Clinton.

INSTRUCTIONS

Please answer each of the following enumerated interrogatories separately and fully, in writing, and under oath. A request for identification of any particular document or thing includes a request for identification of the original of that document or thing, as well as identification of each and every photocopy or duplicate of that document or thing, and each and every draft of the document or thing.

In answering the following interrogatories, you are to provide not only the information within your direct personal knowledge, but also the information within the knowledge of your attorney(s), any investigator employed by you or by your attorney(s), or any consultant or expert witness employed by you or by your attorney(s).

The following interrogatories are continuing. After serving your initial response to these interrogatories, please supplement your response whenever any information responsive to them is recalled or received by you or your attorney(s).

If, in response to a particular interrogatory, an objection is interposed, and the objection applies to some but not all of the information requested, please provide in your answer all responsive information to which the objection does not apply. Any and all objections should be interposed by the deadline for your initial response, or will be considered waived.

INTERROGATORIES

INTERROGATORY NO. 7: If, based on a claim of privilege or exemption from discovery (including but not limited to the attorney-client privilege and the work-product exemption), you are withholding from production any document or thing requested in the First Set of Requests from Plaintiff to Defendant Clinton for Production of Documents and Things, then please state the following for each and every document or thing:

a. A description of the general nature of the document or thing (for examples, "letter," "memorandum," "photograph," "cassette tape");

b. The date on which the document or thing was created;

c. The name and address, and telephone number of the person(s) who created the original of the document or thing;

d. The name of each and every individual who has seen, or had possession of, the original or a copy of the document or thing.

ANSWER:

INTERROGATORY NO. 8: Please state the name, address, and telephone number of each and every medical doctor who has performed any surgery or medical procedure on your genitalia at any time after May 8, 1991.

ANSWER:

INTERROGATORY NO. 9: Please state the name, address, and telephone number of each and every medical doctor who has examined your genitalia at any time after May 8, 1991.

ANSWER:

INTERROGATORY NO. 10: Please state the name, address, and telephone number of each and every individual (other than Hillary Rodham Clinton) with whom you had sexual relations when you held any of the following positions: