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Released on Monday, March 30, 1998

Following is the full text of a letter submitted by Paula Jones's legal team on March 12, agreeing to protect the identity of certain women by identifying them only as "Jane Doe" in future filings.

March 12, 1998

The Honorable Susan Webber Wright
United States District Judge
United States District Court for the Eastern District of Arkansas
Federal Courthouse
600 West Capitol Avenue
Little Rock, Arkansas 72201-3325

Re: Jones v. Clinton, et al., No. LR-C094-290 (E.D. Ark.); Court's Request Concerning "Jane Doe" Names in Plaintiff's Summary Judgment Responsive Materials; Court's February 6, 1998 Order

Dear Judge Wright:

In accordance with your request to Plaintiff's counsel in our telephone conference among all parties on March 10, 1998, regarding the above-referenced matters, please be advised as follows.

Plaintiff staunchly contends that, based upon the overwhelming weight of authority previously cited to the Court, Plaintiff cannot be compelled to file any of her summary judgment responsive materials under seal, nor can Plaintiff be compelled to redact, obscure, or otherwise obfuscate proper names or other information filed in her responsive materials. Nevertheless, after giving the matter further consideration, Plaintiff and her counsel, because the Court requested it and as an accommodation to the Court, will agree to the following procedure. If and to the extent that Plaintiff's summary judgment responsive materials reference the proper names of any "Jane Doe" who sought protection from this Court during the discovery phase of this case, Plaintiff will agree to redact such proper names and replace them with their previously used "Jane Doe" who sought protection from this Court during the discovery phase of this case, Plaintiff will agree to redact such proper names and replace them with their previously used "Jane Doe" designations herein; provided, however, that with respect to such materials (if any) relating to Monica Lewinsky, Plaintiff will not undertake such redaction and replacement chore. Plaintiff believes that the public has already been so inundated with Monica Lewinsky-related news and reports that any attempt on any party's part to obscure references to Ms. Lewinsky would constitute merely wasted time and effort.

We believe that the procedure outlined above will suffice to protect any legitimate concerns for the privacy of any of these "Jane Does," even though Plaintiff denies that she has any legal obligation to protect any such privacy concerns at this summary judgment stage of this suit.

In accordance with the Court's Order of February 6, 1998, Plaintiff hereby notifies the Court and opposing counsel that her summary judgment responsive pleadings may contain some materials that some party may consider "sexually explicit or salacious."

Thank you for your continuing attention to these matters. By copy of this letter, all counsel of record are being notified of this communication.

Sincerely yours,

Donovan Campbell, Jr.

cc: Robert S. Bennett, Esq.
Bill W. Bristow, Esq.
Kathlyn Graves, Esq.
Stephen Engstrom, Esq.