| |
| |
Preface | |
| |
| |
Acknowledgments | |
| |
| |
| |
The Complaint | |
| |
| |
Introduction | |
| |
| |
Case Planning | |
| |
| |
| |
Interviewing | |
| |
| |
[Jones's] Complaint | |
| |
| |
Notes and Comments | |
| |
| |
| |
Ramifications of Pleading Decisions | |
| |
| |
| |
Motions Testing the Complaint | |
| |
| |
Introduction | |
| |
| |
Memorandum in Support of President Clinton's Motion for Judgment on the Pleadings and Dismissal of the Complaint | |
| |
| |
Plaintiff's Memorandum in Opposition to the Motion of Defendant William Jefferson Clinton for Judgment on the Pleadings | |
| |
| |
Judge Wright's Decision | |
| |
| |
Jones v. Clinton, 974 F. Supp. 712 (E.D. Ark. 1997) | |
| |
| |
Notes and Comments | |
| |
| |
Analysis Chart | |
| |
| |
| |
Pre-Answer Motions | |
| |
| |
Introduction | |
| |
| |
President Clinton's Motion to Set Briefing Schedule | |
| |
| |
Memorandum in Support of President Clinton's Motion to Set Briefing Schedule | |
| |
| |
Plaintiff's Memorandum in Opposition to the Motion of Defendant Clinton to Set Briefing Schedule | |
| |
| |
Resolution of the Issue | |
| |
| |
Oral Argument of Robert S. Bennett on Behalf of the Petitioner [before the U.S. Supreme Court] | |
| |
| |
Oral Argument of Gilbert K. Davis on Behalf of the Respondent | |
| |
| |
Notes and Comments | |
| |
| |
Other Pre-Answer Motions | |
| |
| |
| |
Motion to Recuse Judge | |
| |
| |
| |
The Answer | |
| |
| |
Answer of President William Jefferson Clinton | |
| |
| |
Notes and Comments | |
| |
| |
| |
Affirmative Defenses | |
| |
| |
Complaint and Answer Comparison | |
| |
| |
| |
Amendments | |
| |
| |
Introduction | |
| |
| |
Plaintiff's Motion for Leave to File First Amended Complaint and Brief Thereon | |
| |
| |
Excerpts of First Amended Complaint | |
| |
| |
Opposition to Plaintiff's Motion to Amend the Complaint | |
| |
| |
Order Granting Motion for Leave to Amend | |
| |
| |
Notes and Comments | |
| |
| |
| |
Revising the Theory of the Case | |
| |
| |
| |
Analyzing an Opposition to Amendment | |
| |
| |
| |
Discovery: Devices and Defenses | |
| |
| |
Introduction | |
| |
| |
| |
Formulating a Discovery Plan | |
| |
| |
Devices | |
| |
| |
Interrogatories | |
| |
| |
Plaintiff's Responses and Objections to the First Set of Interrogatories of Defendant William Jefferson Clinton | |
| |
| |
Notes and Comments | |
| |
| |
Second Set of Interrogatories from Plaintiff to Defendant Clinton | |
| |
| |
Notes and Comments | |
| |
| |
| |
Drafting Interrogatories | |
| |
| |
Requests for Production of Documents and Things | |
| |
| |
First Set of Requests from Plaintiff to Defendant Clinton for Production of Documents and Things | |
| |
| |
Notes and Comments | |
| |
| |
Requests for Admissions | |
| |
| |
First Set of Requests from Plaintiff to Defendant Clinton for Admissions | |
| |
| |
Notes and Comments | |
| |
| |
Depositions | |
| |
| |
Order of January 9, 1998 | |
| |
| |
Deposition of Paula Jones | |
| |
| |
Notes and Comments | |
| |
| |
Defenses: Privilege, Work Product, and Undue Burden | |
| |
| |
President Clinton's Opposition to Motions for Protective Order Regarding Subpoena to Cindy Hays | |
| |
| |
Reply of Cindy Hays to President Clinton's Opposition to Motions for Protective Order Regarding Subpoena to Cindy Hays | |
| |
| |
President Clinton's Opposition to Motions of Paula Jones and Paula Jones Legal Fund for Protective Order | |
| |
| |
Order of November 25, 1997 | |
| |
| |
Order of December 4, 1997 | |
| |
| |
Notes and Comments | |
| |
| |
| |
Analysis of Work Product Doctrine | |
| |
| |
| |
Discovery: Relevance and Privacy | |
| |
| |
Introduction | |
| |
| |
Relevance and Privacy Issues as to Parties | |
| |
| |
President Clinton's Motion for Protective Order | |
| |
| |
Memorandum in Support of President Clinton's Motion for a Protective Order | |
| |
| |
Plaintiff's Memorandum in Opposition to the Motion of Defendant Clinton to Limit Discovery | |
| |
| |
President Clinton's Opposition to Plaintiff's Motion to Compel Responses to Plaintiff's Second Set of Interrogatories | |
| |
| |
Order of December 11, 1997 | |
| |
| |
Notes and Comments | |
| |
| |
| |
Balancing Privacy and the Scope of Discovery | |
| |
| |
Privacy of Nonparty Witnesses | |
| |
| |
Affidavit of Jane Doe #6 | |
| |
| |
Order of January 9, 1998 | |
| |
| |
Notes and Comments | |
| |
| |
| |
The Role of Public Policy Concerns | |
| |
| |
Discovery versus the First Amendment | |
| |
| |
President Clinton's Opposition to Motions for Protective Order Regarding Subpoena to Cindy Hays | |
| |
| |
Reply of Cindy Hays to President Clinton's Opposition to Motions for Protective Order Regarding Subpoena to Cindy Hays | |
| |
| |
Order of November 25, 1997 | |
| |
| |
Notes and Comments | |
| |
| |
| |
Discovery: Sanctions | |
| |
| |
Introduction | |
| |
| |
Excerpts of Deposition Testimony of President Clinton | |
| |
| |
Orders Imposing Sanctions | |
| |
| |
Jones v. Clinton, 36 F. Supp. 2d 1118 (E.D. Ark. 1999) | |
| |
| |
Jones v. Clinton, 57 F. Supp. 2d 719 (E.D. Ark. 1999) | |
| |
| |
Suspension of Law License | |
| |
| |
Agreed Order of Discipline | |
| |
| |
Notes and Comments | |
| |
| |
| |
Rule 37 Sanctions | |
| |
| |
| |
Comparing Rule 37 Sanctions with Rule 11 Sanctions | |
| |
| |
| |
Joinder and Intervention | |
| |
| |
Introduction | |
| |
| |
Joinder | |
| |
| |
| |
Variations on Joinder | |
| |
| |
Rule 20 Joinder | |
| |
| |
Rule 19 (Necessary Parties) and Rule 14 (Impleader) | |
| |
| |
Rule 24 (Intervention) | |
| |
| |
Rule 23 (Class Actions) | |
| |
| |
Intervention | |
| |
| |
Limited Purpose Intervention--A Case Study | |
| |
| |
Confidentiality Order on Consent of All Parties | |
| |
| |
Motion for Leave to Intervene, Motion to Modify and/or Rescind Confidentiality Order, and Motion for Access to Court Records and Discovery | |
| |
| |
Order of March 9, 1998 | |
| |
| |
Notes and Comments | |
| |
| |
| |
Summary Judgment | |
| |
| |
Introduction | |
| |
| |
Memorandum in Support of President Clinton's Motion for Summary Judgment | |
| |
| |
Plaintiff's Memorandum in Opposition to Motion for Summary Judgment | |
| |
| |
Judge Wright's Ruling | |
| |
| |
Jones v. Clinton, 990 F. Supp. 657 (E.D. Ark. 1998) | |
| |
| |
Notes and Comments | |
| |
| |
| |
Celotex and Summary Judgment | |
| |
| |
| |
Settlement and Default | |
| |
| |
Introduction | |
| |
| |
Text of Settlement | |
| |
| |
Notes and Comments | |
| |
| |
| |
Appeal | |
| |
| |
Introduction | |
| |
| |
Order of January 29, 1998 | |
| |
| |
Plaintiff's Memorandum in Support of Motion for Section 1292(b) Certification | |
| |
| |
President Clinton's Opposition to Plaintiff's Motion for Section 1292(b) Certification | |
| |
| |
Notes and Comments | |
| |
| |
| |
Interlocutory Appeal of a Discovery Order | |
| |
| |
| |
Articles of Impeachment | |
| |
| |
| |
Jones v. Clinton Chronology | |
| |
| |
| |
Standard Forms | |
| |
| |
Civil Cover Sheet | |
| |
| |
Waiver of Service of Summons | |
| |
| |
Subpoena in a Civil Case | |
| |
| |
Notes on Sources | |
| |
| |
Index | |