You are on page 1of 31

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151

'a deposition I'll tell that you ask you

if we didn't to take

have

a few exhibits.

So and

2
3

a look

at a few documents, to hand you

me if you I've if you A.


Q.

-- I'm going

a document
1, and

4 5
6

labeled

as Defendant's that?

Exhibit

ask

recognize Uh-huh. And what

7
8

is that? of the intake study

A. concerning Q. A.
Q.

That's

part

9 10 11

the school. So that's Yes. I'll a part Yes. (Off-the-record Mr. Hodge discussion between hand you Exhibit intake
2,

part

of the

intake

study?

12
13 14 15 16 17

and

ask you:

Is

that

also A.

of the

study?

and the plaintiff) And so the first you would

Q.

(By Mr. then

Bernstein)

18 19
20

document send

is something in the mail?

that

apparently

a parent A.
Q.

Yes. For them to complete and send back to

21 22
23
24

you? A.
Q.

Uh-huh. And would at the same ---you also time? send them a second

25

document
--

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& SIMPSON

COURT REPORTERS

StlREVEPORT, LoUISIANA

_ (318) 429-2160
.

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:THELMA
(." 1

FORD

7/21/97 152

A.
Q.

Yes. And using are those in 1995 the forms that New Bethany

3
4

'Home

was
A. Q.

and

1996?

Correct. How long had you-all used those forms

5 6
7 8 9

roughly? A.
Q. A.

These Yes?

particular

ones?

Probably them.

five years,

but we've

already

10
11

changed
Q. A.

When
I

were
I
I

they have have bit

changed? new ones new now.


I

12
13 14

mean, but

don't will be

have

any

kids,

forms.

They

different.
Q.

A little

different. the same kind of

15
16 17
18

But

is it basically

forms?
A. Q.

Basically Looking It's

this =or

same. information? instead of

the same

19
20

A. off of our
Q.

just

off of the co~puter

21 22 23
24

Okay. years Yes. Before school,

And ago?

these

two

forms

date

back

about

five
A. Q.

that,

was there

there just

a separate one form

form for
_.

25

for the
..

or was

the
____J

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SIMPSON COURT REPoRTERS

_.
SHREVEPORT, LOlJlSIANA

BAIN

(318) 4292160

I .-.! THELMA

.... _..
FORD
7/21/97

153

1
I

school like

and one

form

-- that

has one

form

it looks

2
3 4 5 6 7

for the school? A. ...


Q.

Uh-huh. Okay.
2,

And

then

the second

form,

the for

Exhibit the

have

you always form

had a separate

form

school A.

and one No.

for the Home? it five years ago,

When one.

we changed

8
9

we

added
Q.

this

In other years Correct. Why


I

words,

you

had the

form

for the

10
11 12

school

five A.
Q.

ago?

did you

add

the form why

for the it.

school? I don't

13
14

A. know. Q. ask in you


'95,

can't

remember

we did

15 16
17

And if this
'96?

I'm going is another

to show form

you that

Exhibit you

and

all used

18 19 20 21

A.
Q.

Yes. And that was the form that you would send

to-A. Q. school To the schools. the schools asking basically for the

22 23
24 25

transcript?
A.

Correct. when did you-all start REPORTERS

Q.

using
.

that

form?

L_._.
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154

A.
Q.

We've

used

that

for years. you Exhibit packet


4, and

2 3 4

I'm going a part

to hand

ask

you:

Is that A.
Q.

of the intake the power that

as well?

Yes.

That's

of attorney.

5 6 7
8

Why do~you That's

send

to a parent? to keep their

A. child.
Q.

giving

us permission

With

regard

to children

that

are placed do you

I
9 10 11 12 13 14 15 16 17
18
I

with get

you

by a court

or by a juvenile in those

officer,

a power
A.

of attorney They just

cases own

as well? power on it. Did you have of

send

me their

attorney, Q. anything A.
Q.

just The

a letter power

-- letterhead form.

of attorney this up?

to with No.

drawing

But you you

just, send

as a part

of doing

the with

intake the

study,

that

to a parent

along

packet? A. Q. That's Part part of the packet. I'm going ask you to hand

19
20

of the packet. Exhibit


5, and

21
22 23

you

a document,

if you

recognize A.

that? Uh-huh. And what is that document? for who


_.

._

24 25

Q.

L._.~__ ""
BAJN

just

an explanation
------------

we are
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(31 R) 429-2160

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THELMA

FORD

7/21/97

and

what Q.

we

are. I notice it says: New mailing in Arcadia address_ at some

2
3

Did

you

change

mailing

addresses

4 5
6

point?
A_

Yes. And Route And Yes. And Yes. And how long have you had that phone is that the correct phone number? what
2,

Q. A. Q. A. Q.

was Box you've

the
2222.

old

address?

7
8 9

now

changed

to

the

P.O. Box?

10 11
,.

A. Q.
number? A. Q. A. Q. Mrs. And Mack that's A.

"

12 13 14 15 16 17 18 19 20 21 22 23 have.

Ever since Yes. And Ford, you? That's And

since the

we've early

been '70s?

there.

this

form

at

the

bottom and

indicates dorm mother.

assistance

director

me. are responsibilities -mean? assistant. letterhead indicates that it says that assistant you

Q.

those the

You're

director that

director. A. Q.

What I'm The

does the form

_.

24

pastor's on the

25

BAIl'

& SIMPSONCOURT REPORltRS

SHREVEPORT,LoUISIANA

(318) 429-2160

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I THELMA
I
.-,

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156

there's Is that A. Q. Seminary A. Q. A. Q. A. Q. Bethany Bethany A. course

a Bethany in Arcadia? No. And

Theological

Seminary

Extension

2
3 4

That's who runs in

in Dauphin, the Bethany

Alabama. Theological

5
6

Extensio~ Dr.

Dauphin,

Alabama?

Shoemake.

7
8 9

S-H-O-E-M-A-K-E?
I

think do

it's you

spelled it's

different. spelled?

How

think

10 11 12 13 14 15 16 17 18 19
20

S-H-U-M-A-K-E. And what's the connection Extension between and the New

Theological Baptist The

Seminary

Church? staff this what could college. would they study in that take a correspondence

through

Q.

And

correspondence A. know. Q. account, the or Does the Oh,

course?
I

didn't

take

it,

so

really

don't

New

Bethany

church

account, in

home any way

21
22 23

school

account, Seminary

support

Bethany A.

Theological No. Does suPPor~ the

Extension?

24 25

I
LxtenSion

Q.

Bethany the

Theological Home, the

Seminary _S_:h001~ ~~

e~ther

_j

BAIN

&

SIMPSONCOURT REPoRTERS

SHREVEPORT, LoUISlAI'IA

(318) 429-2160

!" THELMA
;ORD--'--~

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157

I
1

the

church? A. Q. No. I'm


A,

I
going to that for show I've you, you another as document, Exhibit I'll 6. ask a

2 3 4 5 6
7

I two-page
~And Iyou: I've

document, got is a copy that?

labeled Counselor.

What A.

That's at and

our

testimony we've

of been

who and

we

are

and we're

8 9

where going.

we're

where

where

10 11 12
~\

Q. or the

And

is sent

that to

a part the

of

the

intake

packet

packet A. Q.

parents?

Yes. Now, statement? when was I'm the sorry. -- you How call did it you your refer to

13 14 15 16 17 18
19 20

witness this? A.

Our

testimony. I'm prepared? been -- let's see 24 know. we've


I

Q.
was this

Testimony. testimony Must

sorry.

Testimony.

When

A.
been know. Q. dorm the it? had newly what?

have

24 years?

I don't

really

don't

21 22
23

It would been

have

been though

after

the

new it

girls to

completed

because with 500

refers

24

completed

dormitory

beds,

doesn't

f'-.
"-..

.'

25

-'
BAIN

.. _..._- ._I
(318) 429-2160

&

SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

-_.-._---- ---

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-- .. --------

.. -158

A. Q.

Yes,

it does. to show
7, and

2
3

I'm going Exhibit

you

a document What

labeled is

as Defendant's this?
A.

ask you:

11
5
6

This they

is the sheet in telling three

of paper them

the parents days -- and the

get

when

come

what

7
8
9

I give child

them comes
Q.

a date, in, they And then

weeks

from

the day call. day

can have it tells on?

a phone them what

of the

10 11 12 13
14

month

they
A.

can call Uh-huh. And One


I

Q. numbers: other numbers separate A. side. This

notice

it refers

to two

telephone and the

for business

and referrals, Do both

for calling ring

the child. same

those they

phone

15 16 17 18 19
20

in the

office,

or are

or what? This is one phone call but for the boys the girls

is the girls

side,

telephone Q. here

line

is not even words,

on here. the number that it says

In other

21 22 23

to call A. Q.

the child

is for the boys

side?

Yes. And girls Yes.


.-

then side

there's

a third

telephone

line

24
25

for

this A.

----------------

-------(318) 429-2 t 60

BAIN

&

SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

-_-~

THELMA

FORD

7/21/97 159

i
/"',
\

I
1

I
I

I
Q. A. this Where Into one, do those the office. that 8257 numbers Into doesn't. ring? the dormitory, It rings in the

I
I

2
3 4
5

I ! except I
Iboys

dorm. Q.
A.

~
And then the 8204 rings in the office? in the boys

6 7 8

It rings

everywhere,

except

I dorm.
Q.

And

I'm going

to hand

you

Exhibit

8, and

9 10 11 12
13

ask you
A.

if that's Yes. And what

the girls

number

on it?

Q. ask you A. parents they stuff and

I'm going is?

to hand

you

Exhibit

9, and

that

This need

is the main with

piece

of paper of stuff

that that of

the

14 15 16 17 18 19 20 21
22 23

to read

the list with them,

would with

need

to bring

the kind

the power

of attorney,

the phone and

calls,

it's

just

the general

information

the tests,

blood

test, Q.

as I was You were

saying. telling me earlier was that the

policy

on corporal sent

discipline

in one one

of the was it?

documents
A.

to the parents?

Which

In that power In the power -MR.

of attorney. of attorney. And so that

Q. would

24 25

be the

I
1 ,

HODGE:

Defendant's

Exhibit

4.

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-------------------SIMPSON COURT REpORThRS SHREVEPORT, LoUISIANA

-----,-------_
(318) 429-2160

BAIN

-- -

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-_-_ --- --------7/21/97 160 MR. HARPER: 4. MR. BERNSTEIN: Hold on. Let me go Excuse me. You didn't

THELMA

FORD

1 2
3 ~

send

_us-an~E~hibit

4
5
6

off

the Q. the

record

a second. Bernstein) what In Defendant'S language in the in there Exhibit that that -has

(By Mr. of

power you

attorney, for me the

7
8 9
I

would the

read of

language Homes on

policy

New

Bethany

corporal

I
I-

IdisciPline? A. Church Reve~end administer decisions for It 12 says: months W. And or the longer without New Bethany Baptist by to

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 other does you handed the

deemed

necessary rights necessary

Mack

Ford,

visitation to make

corporal concerning Hand you


9

discipline, medical Exhibit was

treatment. 10 and of for the the ask you: Is


I

Q.

Document

which

girls. boys?

this

corresponding

document

A.
Q. what A. parent not

Yes. I'm that going is as is to well, in hand you Exhibit ma'am? whe~ one or the that 11 and ask

please, cases the has child cases

This has

divorce of

custody

child, to sign

the

one

have

legal

custody to the

this there. have you

affidavit

agreeing If in

being -how

placed long

I
1__ BAIN

Q.

divorce

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SHREVEPORT, LoUISIANA

THELMA

FORD

7/21/97 161

----~ used that


A. Q. A. Q. custody the form accept child from the A. Q. accept, the or

form? Long.

2 3 4

..

Long Yes. In the is the

time.

More

than

five

years?

5 6 7
8

divorce

cases,

if

the

parent the one obtain do

that with

has whom

domiciliary if

parent, they for

residing, other

cannot

that you

parent

guardian,

9
10

child? No, So
I

don't. words, any child be that executed you

11 12 13 14 15 16 17 18 19
20 21

in other

you

require or

that

affidavit

by

noncustodial A. Q.

nondomiciliary

parent?

Correct. And how long has that been a policy of

New

Bethany A.

Home? For I'd over like which ten to was years. refer the the back to Exhibit the for the No.1,

Q.
please

ma'am,

application, student Day an

enrollment the New

application, Bethany ACE that,

information School. On

Christian there is

22 23 24
t" -,

second Financial

page

of

area

captioned:

information. Yes. NOw, the first line of that says:


$350

A.

25

Q.

L_.
BAIN

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--_._--7/21/97

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162

I
1 2
3

!
!

I tuition each month or $4,200 a month year? _....~~.. ~I . A. That's what it would amount to.
Q. about That's was? what the tuition we were talking

4
5 6 7 8

earlier
A.
Q.

Correct. And that says not tax deductible? out to the school, and

A. I don't
Q.

Because think it's

it's made

tax deductible. words, it's not a contribution

In other

10 11 12
/ -.\

to the church? A.
Q.

Right. And fees, then the next line says: $200 for for

13 14 15 16 17
18 19

entrance 12 months? A.
Q.

registration,

and ACE

curriculum

That

was

for

the school that

material. purchases them

In other materials? Right. ACE,

words,

$200

the ACE A.
Q.

the different about?

paces,

the

72 paces

20 21 22 23
24

that

we were A.
Q.

talking

Correct. And also includes entrance fees and

registration? A. Q. Uh-huh, Is that yes. registration with the New Bethany

25

L
BAIN

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SHREVEPORT, LoUISIANA

__
(318) 429-2160
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SIMPSON COURT REPORTERS

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f~H~~M~
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FORD

1 --, s c h'o 0 lor


2
3

wit han

the r sc h 0 0 1 ? School. And then the $100 is for

A.
Q.
s,

New Bethany New Bethany.

4
5 6

what? A.
Q.

Uniforms

..

for the girls. sort of uniforms are those?

And what They They From rent rent

7
8

A.
Q. A. Q.

them. them from whom?

the Home. words, from the New Bethany

10 11
12
.. '

In other

Home? A.
Q.

Yes. Okay. And what does that uniform consist

13 14 15

of? A. red vest


Q. A. Q.

Navy

blue

skirt, lapel.

a white

blouse,

and

16
17 18 19

and a little And when Only And

do they

wear

that

uniform?

to school. they wear that uniform to school

20
21

every

day? A.
Q.

Every

day. such uniforms does a girl get

22 23
24
I '\

How many rent

that

$100
A. Q.

for her? two. words, the $100 rents her two


,

She gets

25

So in other _

l._ ..
BAlN

&

SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

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FORD

7/21/97
164

./

1 2
3

;uniforms

----~.~
A. Q. year A. Q.

.
a year? Correct. And then if the uniform wears out during

for

4
5 6
I

doing

We

just

replace it. the And

it. that or $200. to the Does Home? the

Replace that To And home? $200


I

7 8 9

jparent

pay A. Q.

to

school

the

school. the school rents the uniform

then

10 11 12 13
14

from

the

A.
Q. A. Q. A. Q. the Home? A. Yeah. It's Q. A. Q. A. Q. Houston,

is

for the

the $100?

paces.

We

order

them.

mean,

Yeah. The $100 is paid to the school?

15 16 17 18 19 20 21 22 23
24

Uh-huh. And you said the uniform is rented from

Yes

-- well, from do Agnes

all the you

of

it's

together.

rented And From And where St.

school. obtain the uniforms? Texas.

in Houston,

is St.

Agnes?

Uniforms. Uniforms. Texas is In other words, -_. I


(318) 4292160

St.

Agnes

in

25

a uniform

store

--------.----BAIN

&

SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

THELMA

FORD

7/21/97

165

A.
Q.

Yes. -- or company? Uh-huh. Do you have ACE any children Day School Bethany? that that attend do not the

2 3 4

A. Q. New Bethany

5
6 7 8 9 10
11

C~ristian

reside

on the premises
A. Q.

at New

No. So the only ACE Christian children Day School that are attend those the New

Bethany that are


A. Q.

children

living

at the New Bethany

Home?

Correct. Let's talk about last


21,

12 13
14

year.
1996,

My some Services

understanding employees came out A.


Q.

is that

on June

of the State to New Bethany. Yes. Were you

Department Do you

of Social remember

15 16
17 18 19 20 21 22

that?

present

when

they

came

out

there? A. Q. understand State Fire


I

was present. did you on that

was

in the office. and


I

When that

first day some also

also of the to New

employees came out

Marshal's

office

23

Bethany?
A.

r .".

24

Yes. Do you remember


.._--._--

25
'-----_

Q.

whether
---.-

the employees
. --- ..

of
._j

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SHREVEPORT, LoUISIANA

(318) 429-2160

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_._._.:1
166

FORD

;the
I

Fire

Marshal Services The

or the employees got there

of the

Department

2
3

of Social
A.

first? Department got there

Fire

Marshal

4
5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
20

first. Q. somebody Bethany? A.


Q.

And when
~

did you

first

learn office

that was at New

from

the Fire

Marshal's

Within

a few minutes. learn? told that me. was?

And how did you Someone Do you I don't Is there came

A.
Q.

in and who

remember know more who

A. Q. Bethany? A. use one


Q.

that

was. office at New

than one

There's office.

more

than

one

office,

but

we only

And where

is this

office?

A.
Q. A. Q.

In the girls And Yes. By all the By all the Where There's dorm. that's

dormitory. office that's used?

the only

21

staff? staff. offices located? side above

22
23 24

A.
Q. A.
I

are the other one over

on the boys

25

the boys

--------BAIN & SIMPSON COURT REPoRTERS

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SHREVEPORT, LoUISIA. .... A

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THELMA
('

FORD

7/21/97 167

Q. A.

Is it used No. I want

for anything?

2 3 4 5

Q. -about

to go back

and

ask you

a question the are

something that

I just we had

thought talked

of.

Besides earlier,

ibuildings there

about

6
7

any other A. There about But

dwellings were some

like

a mobile homes,

home? but we've

mobile Now, there

!sold
9 10

just
Q.

all of them. in '95,


'96,

they're were

all gone. homes

mobile

out

there? A. Q. A.
Q.

11

Right. Who

Yes. in those mobile ho~es?

12
13 14 15
16

lived

Nobody. Even nobody No. So the first word that you have dorm, and is that somebody say to while was they living were there on the

property,
A.

in them?

17

Q. you're comes you,

18
19

in the office in and

in the girls to you?

says what you

What

do they

20 21 22
23

as best A.

remember? know. Maybe or the like fire they said that

I don't Marshal

the

Fire

people

department They'll

people have

are here to wait


Q.

to inspect. Reverend

And Ford

I said, is here.

24
25

until

What

happened

after

that?

L_
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THELMA

FORD

7/21/97

A. Q.

I don't And Yes. And

know. remained in the office?

2 3 4
I

so you

A. Q. 'Fire Marshal A.
Q.

at that

point,

you

didn't

see the

people
I

at all?

6 7 8 9

didn't. happened next with regard to

So what from

somebody A. don't said, out said what

the State? in a few minutes, it was. two car


I

Well, how

an hour know.

10
11

know Well,

long

don't loads

They

there

are

of people Agency. so
I

12
13 14 15 16

here

from

the Child Ford wasn't

Protection was there,

And don't

-- and Brother was


Q. A. Q.

know

said. And Yes.

there. in the office?

you were

17
18 19 20

And was at that (Shakes How

Brother point? head

Ford

in office

at the

same

time
A. Q.

negatively) learn that somebody Bethany? told me. from

did you Agency Mack

21 22
23 24 25

Child

Protection A.
Q.

was at New came in and

Brother And what He said I said,

did he tell two car Really? loads

you? from the DSS is

A. here. And

And he brough~~iCkY_~

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"-'l
I

1 2
3 4

Denise, one the

I guess, into

it

was.

One

of them. And -she

He brought said, Here's

of them list
Q.

the office. And

I
I

of people. And what I just Okay. Well, And

I said say?

did you

5
6

A.
Q.

said, What

Well,

too bad. by that?

did you mean was other

-,
7
8 9

A. Q. your

the decision there any

his. conversation Reverend Agency? Ford in and

was

presence Fair A.
Q.

between with

your

husband

10 11

Denise

the Child know.

Protection

I don't

-: .. \

12 13 14 15 16 17 18 19 20 21 22 23 24

I'm sorry? I don't remember said, what was said, what they

A. said. coming

But we just in.


Q.

She's

not

-- they're

not

How with

long do you you? know.

think

Denise

Fair

was

in

the

office A. Q. A.
Q.

I don't Five Maybe And

minutes?

30 minutes?

15 minutes. she had a list of names?

you said

A.
Q.

Uh-huh. And what did she say to the best of your

recollection?
A .

. --"

25

I think

Brother

Ford

had

the list

by

I.
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/:"
\

1 2
3
4

then,

and Q.

don't You

recall have

what any

was

said. of what

don't

recollection

Denise

Fair A. Q.

said? I do Is to of no t know. any would was no document refresh said one that in or person memory in but the me that or office? and you
I

5
6
7

there that what

could remind

talk you A.

your day

.!

There Mack, and

was

there

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
/-\
I

Brother Q. was that


A.

her. recollection Is there or what of you said

And

your

about

15 minutes.

a list

names

Yes. -- your And do husband, you Reverend Ford, had at

Q. that that point?

recall

anything

else

about

meeting? A.
Q.

(Shakes And is
t

head ha t a

negatively) no?

A. Q. help you A. office. Q. that doesn't

Tha t 's no. Is ~here anything that you think day? there in the might

remember That's

what all

happened that

that

happened

Well, sound

the

reason what

I'm

asking take

you

that

is

25

like

would

15 minutes

I l_
BAIN

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(3 I R) 4292160

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____ o._

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THELMA

FORD

7/21/97 171

1 2
3 4

from

my A.

experience Oh, I don't

to

happen? know how long she stayed in

I don't know. I'm

there. Q. more

I don't. to find out if there was

And

trying

5
6 7

conversation? A. Q. Not And

.
I recall. not any I don't -- do back if recall you you about at think read it, all? or any. you would come

that

there's that

8 9 10 11 12
13

have

a memory or just A.

something do you

heard not

somebody any was

else

talk of

have

memory too

that to

I probably -- my And name. what

upset

remember

anything Q. A. times. Q. meaning A. everything Q. What would A. come in Q. have


1 BAIN

upset I done

you? went through this too many

14 15
16

Because

And what?

done

went

through

this

too

many

times

17
18

Meaning getting And what

my

schedule

getting and things your

disrupted like that.

and

19 20 21 22
23

disturbed would things? the No,

disturb

schedule?

disrupt Disturb

children, it always that

having upsets the

visitors the cart. don't

like

that.

24
/

Even

those the
.__

times Child
. __

children Agency

'

25

contact
. __ .. -

with

Protection
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r~HELMA
!

FORD ----7/21/97

../

people? MR. question. MR. Q. (By Mr. you were BERNSTEIN: Bernstein) upset -Okay. You told me that HODGE: I don't understand your

2
3
4

5 6 7 8

A.
Q. because A. Q. it upset

Yes. on their It And the June 21,


1996.

And upset

you the

were cart?

upset

9 10 11 12
( \

being should what

there would. I'm

would

trying

to

find

out

is:

How

cart? they of recognize them want maybe to go the would home. what happened people have and to go

13 14 15 16 17 18
19

A.
they home, know and Q .. next?

Because that they After some

didn't that

15 minutes,

A.
left the Q. anybody A. that day. Q. Marshals

I don't office. And from is

know. I don't that State Yes. the

He

left

the

office.

She

know last

what that

happened. you saw of

20 21 22 23 24
'- ...

the

that No --

day? I think, yes. Yes,

Yes.

That anymore

day. that

So

you

didn't

see

the

Fire

25

day?

..--.--------

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_-----------SHREVEPORT,

_
LOUISfANA

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---- ------THELMA FORD 7/21/97

--------~

173

i
I

A. Q. any more A. Q. that day A. Q. A. Q. A.


I

I did And that No.

not. didn't see the people from DSS

2
3 4 5

you day?

Did
about

you

and

your

husband

talk

anymore
,
-I

"
6
7 8

what

had

happened

that

morning?

Sure. Okay.
I

And

what

did

you-all

say?

9 10
11
/'--, ,

don't you

recall. recall sure that we you-all but

But Well, recall.

did

talk? know.

I'm

did,

I don't

12 13 14 15 16 17 18 19 20 21 22 23
24

don't Q.

What with Agency you


I

was

the

next to

thing

that

happened from Child

in

June,

1996

regard or

either the

people Fire

Protection Office that A. and that went was. Q. through A. Q. A. and the the

from

State

Marshal's

remember? it the was the next day they came out

think

through

buildings.

I don't

know

when

And

you

say

they

came

out

and

went

buildings? Yes. How One many? Denise and one of the deputies,

25

attorney.
,

---------------------BAIN
-",

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SHREVEPORT, LOUISIANA

(318) 429-2] 60 -----------

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---[-THELMA
/:

._-

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.- -' . 174

FORD

7/21/97

.. '\

1 2
3

Q. Mr. Harper? A. Q. A. through Q. buildings? A. them. Q. arrived A. Q. arrived A.


Q .

And

when

you

say

the

attorney

--

Mr. And They the

Harper. what went did they do? the buildings -looked

4 5 6 7
8 9

through

buildings. Were you there when they went through the

Yes.

I was

there,

but

I didn't

go

with

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
/"'
-,

When at New In And at New They

the

sheriff's where

deputy were

and you?

Denise

Fair

Bethany, the how office. did

you

learn

that

they

had

Bethany? came through tot he


0

the

front

door.

Wa I'k e din Not in

f fie e ?

A. the

the

office.

They

came

in

through

dormitory Q. A. Q. And

doors. was there anybody right with them? (indicating) Fair, the deputy,

Those In Harper, And Which

people

there

other the two

words,

Denise

and

Mr. A. Q.

attorney? of my daughters.

25
I '--_..
BAIN

two

daughters?

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SIMI'SON COURT REpORTFRS

THELMA

FORD

._----_-7/21/97

-..-. ---. -... I


175

A.

Penny Penny? Penny Anyone Not seeing And

and Theila.

2 3
4

Q. A.
Q.

and Theila. else? -I

Was

your

husband so.

with
I

them?

5
6 7 8 9

A. remember
Q.

that him. when where just they

don't

think

don't

they did went

came

through

the

doors

of

the dormitory,
A. Q. A. Q. A. Q. A. Q.

they go? down the hallways. sight?

They And

10 11

walked

out of your

Uh-huh. And Yes. And you stayed in the office? you were ~n the office?

12
13
14

15
16

(Nods head Did you see

affirmatively) them again on the grounds at

17
18

New

Bethany?
A.

Someone to the

-- Mr.

Harper

took did

-- they one day,

wanted and we

19
20

to talk didn't

staff any

or somebody

answer
Q.

questions. words, somebody to interview from Child staff

21
22 23 24

In other Agency

Protection members?
A.

wanted

some

Yes. And do you remember who that person


. --

25
.

Q.
BAIN

was?
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&

SIMPSON COURT REpORTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

r------.- ..
iTHELMA FORD
7/21/97 176

MR. ;member, or who MR.


Q.

HODGE:

Who was --

the staff

2
3
4

was

the person

BERNSTEIN:

I'm sorry. Who was the Child

(By Mr.

Bernstein)

5
6 7 8 9 10

Protection
A. Q.

Agency ~ person? I don't Do you Agency even remember who it was. about the Child Tall? that?

remember person? Brunette? remember. attempt

anything Man?

Protection Short?
A. Q.

Woman? like

Blonde?
I

Anything

don't they

11 12 13

Did Yes.

to interview

you?

A.
Q.

And who was present you? Mr. Mr. Harper. Harper,

when

they

attempted

14
15 16 17 18 19 20 21

to interview A.
Q.

the attorney?

A.
Q.

Uh-huh. And you, and the Child Protection worker?

A.
Q. A.

Uh-huh. Anybody Ms. Wafer was the one that was going to

22
23

talk

to me.
Q.

Ms.

Verna

Wafer?

24 25

L
RAIN

A.

Uh-huh. you,
"" was
__________ . _. ___J

Ms. Verna

Wafer,

and

_Q_. &

SIMPSON COURT REPORTeRS

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(318) 429-2160

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jTHELMA
,
\

FORD

7/21/97 177

I
1 2
3

IMr. Harper?

A.
Q.
~-

Correct. And She and And


I

what said
I

did Ms. Wafer she'd


I

say?

4 5
6

A. questions,
Q.

like don't

to ask me some answer any questions.

said,

then

what

happened back

next? to the that. asked you that office, and

7
8 9
I

A. don't
Q.

got up and went what happened were

know

after

Where

you when

she

10 11 12
J "

question? A.
Q.
I

had went

upstairs you,

ln the Verna

second Wafer,

lounge. and

And was

it just

13 14 15 16 17 18 19 20 21 22 23 24
(

! Billy
I

Rex Harper
A.

in the

lounge? were some more people

Oh,

no.

There

there.
Q.

Who
I

else

was

there?
I

A.
Q.

don't

really any

don't Child

know. Protection

Were there?

there

other

workers A.

Yes.

There

were

some

more

there

somewhere. Q. A.
Q.

But Yes.

were

they

ln the

lounge?

How many
I

of them know.
__ --

were

in the

lounge?

25
L..-

A.

don't
---

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SIMPSON COURT REpORTERS

SHREVEPORT,LoUISIANA

(3 U9 429-21
--- ---------

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-

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I THELMA
1

FORD

--7/21/97

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178
Q.

How Bethany

about

New

Bethany

staff?

Were

there besides

2
3
4

.any

New

staff

members

in the lounge

! yourself?
A. when I was Q. do you I don't there. Well, my question being Harper, all in the is: In the lounge, who really know where they were at

5
6

7 8
9

remember Mr.

lounge

besides

yourself, A. don't else.


Q.

and Ms. Wafer? I remember concerning me.


I

That's what

10 11 12
13

know

happened

to the rest,

everybody

My question lounge?

is just: When said,

Was

there

anybody
~_-

else

in the

you were I'd like

sitting

in the some

14 15 16 17 18 19 20
21

lounge

and Ms. Wafer you've

to ask you you and

questions, Ms. Wafer A. lounge, in the lounge, Q. remember when and

told

me that

it was

and Mr. Harper? And we were the rest upstairs in the second were floor

of DSS workers they were

downstairs in the

lounge but they And being

or maybe were

upstairs

there

somewhere. is: Who else do you lounge,

my question in the room, said

22
23
24

the second

floor

Ms. Wafer

she wanted

to ask you

some [
-

questions? A. I don't remember nobody.

25

I ---.--_. 1

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BAIN ~ 0_

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SIMPSON COURT REPORTERS

-- -

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SHREVEPORT, LoUISIANA

(3 I8) 429-2160
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THELMA

FORD

7/21/97 179

1 2 3 4 5 6 7 8 9

Q.

You don't Huh-uh. Might Might And have not

remember

who

was

there?

A.
Q. A. Q. A.

been have

nobody been

else

in the else

room?

nobody

there.

it might there time,

have

been

a big
I

crowd? know.

Nobody At that They'd Gone Home.

hardly, where

but were

don't

Q.
A. Q.

the girls?

all gone.

where?

10 11 12

A. Q. and asked had


A.

In other you, said

words,

when

Ms. Wafer

came

out the

she wanted home? they'd

to interview,

all

13
14

girls

already Yes.

gone Yes,

already

gone

when

she

15
16

came

in there
Q.

That

day that you, a Child

Ms. Wafer was that

said

that

she

17 18 19
20

wanted that day?

to interview you had with

the only worker

contact that

Protection

A. Q.

That

day. remember anything else happening

21

Do you

22 23
/-

that

day? A. Just more remember court looking outside and there

24
25
I

were was
_

some

papers talking.

coming, but

and everybody I don't know what

standing
-----

outside

i._

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&

SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

(31~) 429-2160

-------

. --------.
7/21/97

_.-

-_-----180

----,
I

,THELMA

FORD

II
:

going

on.
Q.

!
:papers?

How could

you

tell

they

were

court

3
4

A. court

Well

afterwards,

learned

they

were

5
6 7 8 9 10 11

papers. Q. A.
Q.

And

who

told

you

they

were

court

papers?

My husband. And what did he tell had you they were? Fire

A. Marshal

Well, the next

they

to meet And

with

the all.

morning.

that's

(Off-the-record Mr.
Q.

discussion the plaintiff) The day that any

between

12
r '\

Hodge

and

13

(By Mr.

Bernstein) you,

Ms.

Wafer

14 15
16 17 18

attempted at New

to interview that

were

there

children

Bethany A.
Q.

day? gone home. there?

They'd There Except And

already were

not any children

A.
Q. A.

visitors. visitors supposed were there? our camp,

19
20

what

We were

to be having had come camp

21
22 23

summer

camp,
Q. A.

and the visitors kind always the 4th brought

in for camp. is that? summer camp

And what We just week

of summer have
a

church week.

24 25

the from

fourth

of July young

Churches

everywhere

their

people.

BAIN

.. 1

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SIMPSONCOURT REPORnRS

SHREVEPORT,LoUISIANA

(318)429-2160

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7/21/97

Q. people to A. I think place

What the

churches

would

bring

their

young

2
3

camp? Maranatha -- and had that did you from Denton, church Uh-huh. Ms. Wafer tried to with Texas. from some And

Well, that was

4
5 6

another arrived.

out Q.

in

Texas

After you,

day

that any

7
8 9 10 11

interview

have

other that

contact summer?

IChild

Protection A. Q. A. Q. No. How No. Prior

Agency

Workers

about

wit~

the

Fire

marshal's

Office?

12 13 14 15 16 17 18 19
20

to come

1996,

had to New to

the

Child

Protection to

Agency

workers

out

Bethany 1996?

investigate A. Q. there before A. Q. A. Q. A. Q. A. complaint.


--

anything Yes. When do

prior

you

remember

them

coming

out

19967 Lots Were Yes. Do you remember anything about that? of times. out there in 1995?

they

21
22 23

Yes. And what do you Wafer remember? -- came. like Said to she to had a

24
25

It was She
.. _-_.-

Ms. to

had

-- would

talk

..

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------.-SHREVEPORT, LoUISIANA

BAIN

SIMPSON COURT REPORTERS

(318) 429-2160

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