The following is the “stipulation of settlement and release” in the case of Paula Corbin Jones v. William Jefferson Clinton and Danny Ferguson.
It was signed on Friday 13 November 1998 by lawyers for the parties – Robert S. Bennett, representing Clinton; William N. McMillan and Donovan Campbell, representing Jones, and Bill W. Bristow, representing Ferguson.
Text of stipulation of settlement and release in Jones v. Clinton.
Whereas it is the desire of all the parties to end the above-captioned litigation for all purposes, it is hereby stipulated and agreed as follows:
- The Plaintiff, Paula Corbin Jones, will receive and accept a total payment of $850,000 . . . in full satisfaction of all claims for damages, including but not limited to any physical and personal injury, civil rights violations, emotional distress and any fees and expenses incurred in connection with this litigation of the facts and circumstances underlying it;
- William Jefferson Clinton will cause said sum to be paid to the plaintiff within 60 . . . days of execution of this agreement;
- The parties . . . hereby unconditionally release each other and their representatives in connection with any claims which have or could be made in or in connection with the litigation or the facts and circumstances underlying it;
- Upon the execution of this agreement, the parties will jointly file a motion with the U.S. Court of Appeals for the Eighth Circuit, seeking voluntary dismissal of appeal No. 98-2161 EALR, each party to bear his or her own costs;
- Nothing in this agreement shall be construed to be an admission of liability or wrongdoing by any party;
- It is understood and agreed that this is the entire and only agreement between the parties and that it will be filed in open Court;
- It is understood and agreed by the parties that the agreement of each of them to this stipulation fo Settlement and Release is not subject to any conditions, and that the consideration recited herein is the sole consideration for the parties’ agreement to this Stipulation.
- It is understood and agreed that the parties have designated their counsel to execute this agreement on their behalf.
