HW told several employees throughout the relevant time period that, in substance, “I will kill you,” “I will kill your family,” and “You don’t know what I can do,” or words to that effect. HW touted his connection to powerful political figures and asserted that he had contacts within the Secret Service that could take care of problems.

At HW’s direction, “TWC employed one group of female employees whose primary job it was to accompany HW to events and to facilitate HW’s sexual conquests…These women were described by some witnesses as members of HW’s TWC “roster” or his “wing women.” One of the members of this entourage was flown from London to New York to teach HW’s assistants how to dress and smell more attractive to HW…”…

HW’s assistants were exposed to and required to facilitate HW’s sex life as a condition of employment.