Declaration of Jeri Ryan, dated June 9, 2000.

I made it clear to [Jack Ryan] that our marriage was over for me in the spring of 1998. On three trips, one to New Orleans, one to New York and one to Paris, [he] insisted that I go to sex clubs with him. These were surprise trips that [he] arranged. They were long weekends, supposed "romantic" getaways. The clubs in New York and Paris were explicit sex clubs. [He] had done research.

[Jack Ryan] took me to two clubs in New York during the day. One club I refused to go in. It had mattresses in cubicles. The other club he insisted I go to. . . . It was a bizarre club with cages, whips and other apparatus hanging from the ceiling.

[He] wanted me to have sex with him there, with another couple watching. I refused. [He] asked me to perform a sexual activity upon him, and he specifically asked other people to watch. I was very upset.
We left the club and [he] apologized, said that I was right and he would never insist that I go to a club again. He promised it was out of his system.

Then during a trip to Paris, he took me to a sex club in Paris, without telling me where we were going. I told him I thought it was out of his system. I told him he had promised me we would never go. People were having sex everywhere. I cried, I was physically ill.

[He] became very upset with me, and said it was not a "turn on" for me to cry. I could not get over the incident, and my loss of any attraction to him as a result.