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MACK W.

FORD -- 7/22/97 92
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/

....-"".

r- ~~~nciPles
I
I

of sc:~Ptur~ from the King James by New Bethany Baptist Church

Bible as

2
3

interpreted pastor".

and its home that

Are there any policies other

of either

,
4'

are in writing
A. Q.

than the words

of the Bible?

5 6 7!
I

We donlt need anything Well, that is what


I

else, do we? to figure

was wanting

out. home; Bible;


!

When you say that the policies in other words,

of the church

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that is what you find in the by New Bethany Baptist is: Baptist interpret

and as interpreted

10 11 12

Church,

how does New Bethany


I

Church

the Bible? Baptist A.


Q.

guess

my question

New Bethany isn't it?

Church Yes.

is a group

of people,

13' 14

And how does New Bethany the Bible?

Baptist

Church if

go

15 16 17 18 19 20
21

about

interpreting

In other words,

there was -- let's take, with regard

for instance,

the question seek to

to when child protection

workers

come in, and you had earlier they come in if the church my question is:

this morning

told me that in. And

decides

they come

What sort of decision-making go through in either deciding

process to let what

does the church

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24

the child protection the policies Bible is? A.

workers

in or in deciding

of -- what the interpretation

of the

25

We are an independent

fundamental

-- you

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SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 4292160

MACK W. FORD

7/22/97 - ----- ---

-----the name -- or what is the

91

Q.

Do you remember

name of the child

that you got that child

support

3:
4 5-

check

from Texas? MR. HODGE: Objection. Well, that is right. produced those

MR. BERNSTEIN: That is right. documents yet. I forgot.

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 I 21 22 23
; I

We hadn't

We will have to get to that. MR. CARUSO: The objection deals only We

with the specific are simply asking

instances

of abuse and neglect.

for the name of a child. We have confidentiality of

MR. HARPER: our records also. MR. CARUSO: Counsel? MR. HARPER: MR. CARUSO: counsel?

Under what

statute,

It is the privacy Which privacy act,

act.

Can you cite me the statute? MR. BERNSTEIN: Gentlemen, we are going

to resume

the deposition

at some point

after documents

are produced, it.

and we will cover

that when we get to

BY MR. BERNSTEIN: Q. The lawsuit also says that the policies of

.....

24 2S

the church, policies

and this is in paragraph

6 on page 3, "The by the

\. -

of the church -------_

home are governed

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,-_._-_.
1!

MACK W. FORD -- 7/22/97 -----_._. know what Q. A. fundamental Yes. Believing is?

---

93

2
3

every word

inherent,

preserved. (phonetic), and means we

4
5'

We are pre-Millenium, believing what

pre-tribyletarian

that the Bible

says what it means

6 7 8 9 10 11
12

it says.

And so in this case, Mr. Bernstein,

have a little brown book called

rules and regulations, the

and then we have a black book that is called Bible, cannot and there is some real controversy,

and we

go past the fact that this is the final (indicating) Okay. The word of God is the final authority. to God the Father and we

authority
Q.

13 14 15
16

A. That don't

is why we pay allegiance pay allegiance


Q.

to Caesar. You said that there was a brown in it? the color

Got you.

17 18 19
20,

book with rules and regulations A. right That is what

it used to be, about

there Q. A. Q. A. Q. A.

(indicating).

And how big a book was it? It was about Loose-leaf this size (indicating) type? remember the --

21 22 23
24

spiral

notebook I don't

I can't remember. Where

is the book now? regulations.


..

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The book is the state governing ----------

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MACK W. FORD

--

7/22/97
94

-I
I ,

guess

it would

be statute

14:403 or whatever

it is,

the statute 3
4

that is giving

them the right

to do what

they are doing. Q. Well, okay. So when you said earlier what were a

5
6

brown book with you A.

rules and regulations,

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8 9

That is what

it used to be.

am talking department. at

about the regulations


Q.

of the state welfare

Okay. Home?

And you used those

regulations

10. 11

New Bethany A. Q. asking

No. Okay. I was confused, because when I was

12
13
./

you about how the church the Bible to either whether

went about decide the policies child a

14
15,

interpreting

of the home or to decide protection workers,

to admit telling

16 17
181

you started

me about

brown book with rules and relations, that was the policies A. The problem of New Bethany.

and I thought

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20j

is that we know what We know what

they teach,

and we know what we teach.

the Bible says, and

21 22 23
24

says and we know what that little it is such controversy the Bible
Q.

brown book

over that that we have to use or the standard.

as a guidebook What is the --

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MACK W. FORD

-- 7/22/97 -------_. -----was held off the record between


95 - --,

- --_._-----------(A discussion

Mr. Hodge and the witness) MR. HODGE:


4:

Counsel

is asking

the decisions; the

witness

how does the church the pastor Could

go about making

51
6

is it through

or alone;

is it through

board of deacons.

you explain

-- the question make the

7! 8
9: o

that is on the table is how does the church decisions; is that correct? MR. BERNSTEIN: THE WITNESS: know what they teach, Yes. The people

10

of the church

you know.

And all of them feel to be

12
13

just like I do; if they come out, they are going contrary determine to the Bible. on each casei

So we don't have to really we know through the years of

14 15
16,

what they have done and how they did it. BY MR. BERNSTEIN: Q. difference correct A. years,
Q.

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Let me ask you this: of opinion within

Is there ever a as to the

the church

191
I

interpretation

of the Bible? has been over the period any. of opinion of

20 21 22 23
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I am sure there but I don't recall

And how is that difference

resolved? A. Q. Well, Okay. through prayer and study of the Bible. holds

25

And if the other person

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MACK W. FORD -- 7/22/97

r----.
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------to his belief and that is different

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steadfast

from the

interpretation conflict A.

and belief

that you have, how is that

resolved? Excuse me. We still disagree. We still

5
6

love each other.


Q.

Right.

So how do you resolve take a stand as to what

that? its

How

71
8 9
1

does the church interpretation A. study

of the Bible

is then? and we pray and it out and

Well, we have the Bible, We follow

10'

the Bible.

it out, check

111
121 131 141
15 16

see if everybody that way. Q.

is in the text, and we get it settled

We donlt have any problem. Would it be a fair statement to say that a Homes, by

staff member becoming

at either

of the New Bethany chooses

a staff member

to follow your

interpretation A. Q. A. question, believe

of the Bible? of the Bible.

171
18 19

No, not my interpretation Whose interpretation?

The Bible,

the word of God. this Bible:

I ask the they say yes, we it is say

do you believe it.

We ask the question, preserved

do you believe They either

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.... ,.

the inherent,

word of God.

yes, or they say no. there

There

is a lot of differences; there is a lot of

(\
~"

is a lot of denominations: opinions,

different

but it depends

on -- if they are
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MACK W. FORD

7/22/97

saved, believe

they believe

the Bible,

and they may not

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3

every dot and tiddle

as we do as for God

fundamentalists.

But if they got a heartbeat we can get it settled. settle

4
5.

and they love children, Q.

And the way you would

it is that if

there was a difference appropriate


A.

of opinion

as to the --

7!

policy

for either

of the Homes

For the Homes' For the Homes' would

training training resolve

of the children. of the children, that is through the

Q.
10: 11 12 13 14 15 16 17
181

way that the church prayer? A. instance? Q. A. Sure. Yes.

For instance

-- could

use a for

For instance, in speaking

you came, in tongues do.

or John came, you and falling from

all believe grace.

A lot of people

We just simply

say, in

that area that is a rough out with them because here.

area, but we will not fall teach it of the

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20

of that, but just don't that is the doctrine That

We don't believe Baptist

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24

fundamental doctrine. have worked people

Church.

is not in the And we

Just stay away from the doctrine. with people allover.

We have different helping us. We

of different those

denominations issues.

25

never discuss

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.______J

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MACK W. FORD -- 7/22/97


--_
..

--_

..

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of

98

Q.
2:

But now how -- what would or the home

be the policy

the home for the girls regard

for the boys with Let me ask for

3
4 5
6;

to your hypothetical,

your example?

you, can you put that in the context either the home

of a policy

tor boys or home for girls

that would

come from the Bible? A. As a book written Or a policy. of the church of Scripture you are talking says, about? "That the

8 9

Q. policies principles

Your lawsuit

home are governed

by the Bible as

10 11

from the King James Baptist Church

interpreted pastor". the church A. Q. is derived A. Q. A. separation,


1

by New Bethany

and its of

121
13 14 15 16 17 18 19

Can you give me an example home that is derived The Scripture. Can you give me an example from the Bible? We can give you an example Okay. Okay. For instance,

of a policy

from the Bible?

of a policy

that

of teaching.

we believe

in from

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22

that a child ought

to be separated

smut and from prostitution, That is where

from drugs,

from alcohol.

God said, present

your body as a living service,

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24 ::::.

sacrifice not being

and God will give you reasonable conformed to this world, of being

transformed;

and you all know that Scripture

as well

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_.

--_._-

MACK
r -

W. FORD

7/22/97

._--_. as
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11

do.

Then we have

--

the Bible

don't

say, don't

smoke,

but it says present

your body as a living We talk about that we

sacrifice. 4 the moral

So we teach those things. issues that is taught

in the Bible;

can back up everything


6;

that we believe.

We try to

back it
Q.

up with the Bible. I think you have given me a good example gets to that point. I gather to
I

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9'

ask me how it a policy smoke;


A.

that it is

of the homes that the children

will not

10
11

is that a fair statement? Well, we are saying we are not going to let say

12 :
/'

them smoke as long as they are there; they won't


Q.

that doesn't

'.

13 14
15

smoke when While Right.

they leave there. they will not smoke?

they are there,

A.
Q.
I

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And the Scriptural

support

for that are the of God?

passages
A. Q.

that say that your body is a temple Right. Okay. And whose reading of that

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19

20 21
i

Scripture smoke,
I

-- that Scripture

does not say, do not

does it? Right. So, help me. How do you get from that or rule that a child

22'
23

A. Q.

24

Scriptural

text to the policy

25

will not smoke while

they are at the horne?

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SHREVEPORT, LoUISIANA

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MACK

W. FORD

-- 7/22/97
----.----

r------I' ,

-_ .._---_
the Bible

.. _.-

--

...

_--against the

---l

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1

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it.

A.

Simply because

teaches

If the Bible teaches then we are going

it is wrong

to defile

3:
4

temple,

to stop them from defiling

the temple while


Q.

they are there. that Scripture and

And who is it that reads means

6;

says, smoke?

this Scripture

that a child will not

7
8
91

A. believe

Well, that.

all the people That is whether Temple

of the fundamentalists it is Bob Jones or Charles or or

10
11

whet-her it is Tennessee Bible Baptist


Q.

Anderson, that.

or Trinity,

all of them believe is: Whose

12

Okay.

But my question of the Bible

1- "

13 14 15 16 17 18 19 20 21

interpretation being a policy A. everybody

is it that results Homes? You know,

in that

of the New Bethany

That is the church believes

policy.

that in that church.


in the past

You wouldn't or future that

find anybody wouldn't


Q.

in our church that.

believe

NOw, the lawsuit includes

also says that the ministry of Biblical to

to the children correction there?

a program

and instruction.

What are you referring

23

MR. HODGE: reading from?

What paragraph

are you

r---_

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25
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MR. BERNSTEIN:

I am still in
. _ . _

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MACK W. FORD

7/22/97

-_--------

--

101 ---,

11
/"-\

paragraph

6.

It is the next sentence. THE WITNESS: Could


I

I
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read that from

31

the Bible? BY MR. BERNSTEIN: Q. A. Yes. In the Book of Proverbs -- does everybody "Train up a

41
51

6!
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,

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read the Book of Proverbs? child

It says this:

81
91
101 111

in the way he should go, and when he is old, he from it". Let me give you this one: but

will not depart "Foolishness

is bound up in the heart of a child, should drive it far in".

the rod of correction give you this one:

Let me a rod

12 13

"Thou shall beat him with his soul from hell". That

and shall deliver in Proverbs. There son while his cry", spareth

is found

14
15 16 17

is another there

one that says here,

"Chasten

my for

is hope and let not thy sole spare one: "He that

Let me give you another

181
19 1

his rod hateth

his son; but he that loveth him

chasteneth Q.

him many times". And how are those Biblical that would constitute verses translated of

20 211 221 23
24,

into action Biblical A.

a program

correction Well,

and instruction? is outwardly rebellious and

if a child

he continues warrant,

to be rebellious,

and things

that would

',,-./

25

there has to be a correction;

and God has

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MACK W. FORD -- 7/22/97 -_ ... _---_ .. ---.---

102 That has got to It has

1f
3
4 5'

provided

correction right.

in the right way. It cannot

be ministered

be done wrong.

got to be done right. wrong, lives.


Q.

In other words,

we do this

and we will have an enemy

for the rest of our

6 7 8

And how do you do it right? By praying with them and counseling with and them

A. them, assure because

telling

them what they have done wrong

them that we are not trying

to discipline

10

we hate them; that we discipline

them because

11
12
13 14
15 16 17

we love them and we are trying right place.


Q.

to get them to the

And you are referring Yes, sir.

to paddling?

A.
Q.

And so any time a child Homes,

is paddled

at one of up with

the New Bethany prayer A. Q.

that should be followed

with the child? Always. Okay. And if a staff member did not do of the

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19

20 21 22
23 24

that, would Homes? A.


Q.

that be a violation

of the policies

Yes, sir.

We consider happen

it that. if you learned of a

And what would that paddled

staff member

a child and did not pray

25

with

the child?

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MACK W. FORD -- 7/22/97


103

A. always

We have always said never,

reprimanded

them.

We have

ever lay a hand on a child or they are angry. It has got to be

discipline
4

them when

done right or be illegal.

It would be wrong

5
6'

Biblically. Q. of page That same paragraph, 3 says, "Discipline and only 6, down at the bottom counseling, circumstances

includes

additional reasonable
10 11
12
r
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chores, corporal or policy

in limited

discipline".

Is there any sort of Homes that says gets

a program

at the New Bethany

that when a child gets counseling, additional discipline? A. Mr. Bernstein, chores

when a child

or when a child gets corporal

13 14

all of them get counseling, As a matter of fact, they will to

15 16
17 18

I mean, day and night. keep you up all night

to talk to them and somebody But there

love them, hear and understand. additional discipline besides

is a lot of

see, the story goes

19
20
21'

that we beat the Devil don't resort do that.

out of them all the time; we cases we have to

You see, very limited

to a paddle.

22 23
24

Now, here they are, they will tell you anything. For instance, they will tell the the DSS, look, don't they will beat me to death, problem, you know,

take me back out there; and terminology

25

is a serious

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MACK W. FORD -- 1/22/97 -- .. _-_-1

104

determining
Q.

what beating Yes. And


I

is and what paddling

is.

A.
4,

don't consider

five licks on the So, we paddle them

bottom

severe punishment

or abuse.

5 6
7 8
9j

where we get the -- it is all in the way it is handled that will get the results.
Q.

Who administers Homes;

corporal

discipline to?

at

New Bethany A.

who is authorized

My wife and Brother

Frank Garcia;

nobody

I
10

else. Q. A.
Q.

11 12
Cr--,
\ -'io!

So you don't Maybe Okay.

administer

corporal

discipline?

two in a year. And is it that Brother discipline Frank Garcia to the

13
14 15 16 17 18 19

administers

the corporal

with regard

boys,

and your wife with regard A.


Q.

to the girls?

Yes, sir. When corporal discipline -- is there any regard to there present

policy being when

at the New Bethany another person

Homes with

present, is --

a third person

20 21 22! 23
24,

corporal A.
Q.

discipline

Yes. That other person has to be an a adult staff

member?
A.

Not in every

case.

There

have been

some of
i I

25

the junior

staff present.

_
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COURT IlEPoR'ffiRS

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MACK W. FORD

7-/22/97

---------1i

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

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lOS

Q. A.

Junior

staff being

-finished their them

.~

2i

Somebody and decided

that has already

3 4
5

program

to stay, and we consider

still .students, but they are what we call junior staff. May I say they are never when someone allowed only in

6
71

restraint they never


Q.

is completely

out of control,

lay a hand on the child. Meaning Right. But the policy of the New Bethany staff member Homes present is the junior staff?

A.
Q.

10

11
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that there

should be a second discipline

12

when corporal A.
Q.

is administered?

r >.

13 14

Yes, sir. Okay. If Frank Garcia had to administer that to

15 16
17
181

corporal anybody?

discipline,

does he have to report

A.

Only the parents.

We request

that they will

tell the parents, discipline paddling; ball

you know, that they have had to I mean, I am talking running about the

19

the child.

20 21
22

I am not talking running

about

around

field; Q.

laps, we call it. it when I was in

That is what they called high, was you ran laps. It works. And how would

23
24

junior A.
Q.

25L
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that be reported

to a parent?
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SIMPSON COURT REpoRTERS SHREVEPORT, LoUISIANA

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MACK W. FORD -- 7/22/97 -------A.

---be on a phone call. For

106

Well,

it wouldn't

2;
3

instance,

sometimes

we will say, hold your parent So the parents notified

over

and let us talk to them. practically


Q.

are always, by phone. '

4:
5

in every Okay.

instance,

But that might

be three or four weeks

later when the monthly A.


Q.

phone call happens?

71

Right. Okay. How does MR. HODGE: is there a record Record kept of what? kept?

101
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BY MR. BERNSTEIN:
Q.

11i

Is there a record

kept of corporal

12
13

discipline? A. did do it. Q. Carolina?


I

The lawyers

recommended

that, but we never

14
15

And the lawyers

being

the lawyers

in South

16
17 ' 18
191,
20

A. Q.

Christian

Association. Law Association recommended

The Christian

that you keep records? A.


Q.

Records. And whose decision was it to not keep

21 22
23 24

records? A. Q. I guess it was mine. records, would would it be possible to the

And without

25

that corporal

discipline

not be reported

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MACK W. FORD -- 7/22/97 ----- _ .. ---- ._-- -- --1

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parents? A. keeping Q. A. Q. Are you referring records? Yes. That they might Well, if there not be reported? is not a record kept of when to record -- by records,

2 3
4

7' 8 91

or if a child receives trusting

a paddling,

then you are who

the staff member

or your wife to remember don't because

they have paddled


A.
I

to then tell the parent, be hard to remember

you? it

10:
11

It wouldn't

is not all that many. Q. paddled A. Q. A. How often do you believe at New Bethany? Maybe two a month. that a child is

12
13 14 15 16 17 18
I

Have there ever been more than two a month? Not that I know of; sometimes Could
I

fewer.

Here

is what I find. Q. A. reprimand,


Q.

comment?

Yes. That a child can be corrected by rebuke or

19

20 21 22 23

they call it. Right. And I have never had a problem with one when but they

A. I speak.

They say that I have the authority,

I
24

obey.

I have never had one just up in my face and this old man said, and they respected me and

25

defy what

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. __ ..._---

MACK W. FORD

-- 7/22/97
108

1 2;
I

loved me, and I guess


Q.

it is because to corporal

of that. could

With regard

discipline,

3 4
5

there be corporal Frank Garcia A. Q.

discipline

that either

your wife or

administers

that you do not know about?

Sure. And they are not required corporal do discipline, to tell you when are they?

61
I

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8~
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they administer A.
Q.

They always Well

10

A.

-- just about

in every

case.

They say, we girl has

11 12
13 14

have had this little openly rebelled,

boy or this little

you know, and we have had to just

stop it.
Q.

The next page of your lawsuit, Ford, the church, and their agents

paragraph home,

15
I

says, church

"Pastor school

the church

the of

161 ! ,

have a long history DSS, the State of when you

17
181
I

litigation Louisiana

with

the fire marshal,

and their agents".

For clarity,

19 20
21

say "the church" New Bethany A.


Q.

there, you are talking Church?

about

Baptist

Right. Okay. What is is there any litigation Church has had with any state of the Homes or one

23
24 2S

that New Bethany agency

Baptist

that did not involve

either

of your homes?

BAIN

&

SIMPSON COURT REPoRTERS


--

SHREVEPORT. LoUISIANA

(318) 429-2160

__ ._- --------.

MACK W. FORD -- 7/22/97 - - --- --_ ---_---1

_-_--_-Mr. Bernstein. says that you, Pastor home, the church school

109

A. Q. Ford,

Clarify Well,

that again,

./

2
3 4 5
6 7 8 9

the lawsuit the church

the church,

and their agents

have a long history

of litigation and of has

with the fire marshal, their agents, litigation

DSS, the State of Louisiana to you is: Outside Homes,

and my question

involving

one of the New Bethany Church

the New Bethany State

Baptist

had litigation other

with the

that involved Homes?

something

than one of the

10 11 12

New Bethany A.

No, but we classify

the New Bethany

Home

for

Boys and New Bethany

Home for Girls Baptist

as an integral And so when

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

part of the New Bethany

Church.

they jump on and cause problems they cause problems

with the ministries, That is the same we don't is

with the church.

way with a guy that never gets

in trouble;

leave him, we try to go to his aid. the same way.


Q.
I

So the church

think that is
I

And that is -- what

want to find out is between involve the church the

that, has there been any litigation and the State over issues homes? A. Well, the litigation issue. that don't

was against

the church

on the fire marshal the church.

They brought

it against

25

-------------------------------------------------------------BAIN & SIMPSON COURT REPoRTERS SHREVEPORT, LoUISIANA (318) 429-2160

, ,

MACK W. FORD -- 7/22/97 .. ... ----'--Q. Didn't that involve

._-------

110 --_.,

one of the buildings it involve the

that is used by the homes? dorm? A. Q. See, the church Right,

Didn't

owns the home. is -- I am trying to

but my question

see if there referring

is any litigation

out there

that you are


I

to that I don't know about. the church

What

know

about all involves or children


10

home or the dormitories homes.

that are at the church

A.
(A

It is out there, discussion

that I know of. between

was held off the record

Mr. Hodge
13 14

and the witness) MR. HODGE: Mr. Bernstein, there may --

this is a discovery me adding involve

deposition.

I hope you don't mind but some of this may

15
16

my two cents worth, as well.

the school

So if you could maybe when you say the home, because some of these

17
18

just clarify

for the witness the school,

does it involve

191
20j

rooms that the fire marshal involve the school as well.

looks at are rooms that

211
22! 23
24

BY MR. BERNSTEIN: Q. school, church The lawsuit okay. school, Now, says church, church home, church home and between to the
. ~

I know that the church

that there have been litigation pertaining


.

your side and the State over things


L-

BAIN

&

SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

MACK W. FORD -- 7/22/97 ----------.----church A. Q.

--- .-_.

111

home and the church Right. Okay.

school;

is that right?

Has there been any litigation over just the church

between

your side and the State didn't church 7 A.


Q.

that

have anything school?

to do with the church

home or the

They have stayed Okay.

clear of the church.

A.
10 11 12
I '

As far as the building. There has not been any litigation, over just the church school? was involved the church something, in the briefs. home or the either a home that didn't any involve the

Q.

lawsuits, church A. Q. church

home or church

13 14 15 16 17

But the church But it involved school;

it involved

building or church A.

or something school?

that went on at the church

They have never hasn't.


I

been through

my church,

the

fire marshal
20 21 22 23
24

Q. mean,

Well,

am talking

about any litigation.

the tax people A.


Q.

We have just been named as tax people or anybody.


I

am asking

just

totally.

Has there been any sort of lawsuit "you" meaning

between Reverend

25

you and the State of Louisiana,

BAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

MACK W. FORD -------1


2

7/22/97
--

112 ., 'I
I
I

Mack Ford as the pastor

and New Bethany

Baptist other

Church than home or

and the State of Louisiana church


1

over something

3
4j

school,

church

school buildings, home?

church

children A.
Q.

at the church Not that Okay.


I

5 6
71

recall.

MR. HARPER: interject Reverend pretty

Mr. Bernstein,

if

might

8
9,

that the proceedings Ford and his church

that was filed against and everything, they

10 11 12 13 14 15 16 17 18 19
20

well speak

for themselves. pretty

There were orders speak for

obtained. themselves

Those orders regardless

much will

of what Mr. Ford might

say. that,

MR. BERNSTEIN: Counsel, allegation trying but he is the party of a long history

And I appreciate that has made an of litigation,

and I am of the issues. out

to probe and find out what we are talking with regard about.

long history
I

litigation litigation
I want

know about

to the home and school is not another

to make sure there that I don't

lawsuit

there

know about. Okay. He has told me not to answer to

21

MR. HARPER:

MR. BERNSTEIN:
23 24
'~

his knowledge, me.


1

and that is an acceptable

25,

III

BAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA

(3IH) 429-2160

MACK W. FORD

7/22/97

,------~--------1
,J

113

BY MR. BERNSTEIN:
Q.

2 3 4 5
61

Now, the rest of paragraph between the fire marshal

7 refers

to a and

lawsuit

and you in 1982, earlier

that was what we were talking

about

when you

told me that there was a short, fire marshalls your lawyer office

crippled

man from the to

that had made the statement not rest until

7 8 9 10
11

that the State would

the

church

home and church

school was shut down. to think about

Over

lunch have you had a chance

what the name was of the man that made that statement? A. name. Q. Pastor school Paragraph Ford, 8 of the lawsuit the church says, home, "Because the church religious I tried to think. I canlt think of his

12
13

14 15 16
17.
j

the church,

and their staff hold strongly-held which

beliefs,

in the view of some are unorthodox, of intense scrutiny by DSS,

they have been the subject the State Fire Marshal strongly-held A. state. religious

18 19

and their agents". beliefs

Which

do you refer to there? of church and

201 21 22 23
24

We believe We believe religious

in separation

that we have a right teaching

to instruct and

and bring

to our congregation

to our children Q.

that is in our care. goes on to say, scrutiny". "They have

And that sentence of intense

25

been the subject

When you say

I
BAIN

&

SIMPSON COURT REPOR'rnRS

SHREVEPORT, LoUISIANA

(318) 429-2160

MACK W. FORD -_ 7/22/97 -- - ------- ._- ._._._- . - 1


2

-_._--to there? what we that. what

114

"intense A. believe, Q.

scrutiny",

what do you refer

We feel that they are against and through the years

3 4

they have proved

And why do you feel they are against

51 61

you believe? A. parents; Because the words that come back through the

71

for instance, in Caddo

as the judge says, Parish,

I will not

81

call his name, happening,

says, we like what is out there;

91

but they are just too religious we are going

101

and so therefore students sending

to have to put the in __ instead we are going of

111
12'

that we placed

out there

I
1

them back to the school, them. judge was that?

to have

13
14

to deprogram Q. Andrew A. Q. A. Q. A. Q. A.
Q.

Which Gallagher? No.

Was that

15
16

He is fine. Taylor? that?

171 181

Or Gorman

Do I have to answer Yes, sir, you do. Gorman Okay. He has placed Taylor.

19,

21 211
221

several

children

out there. stopped

231
241

And then I believe children

Judge Taylor

placing A.

there at one time, didn't he?

--

25

Correct.

L
BAiN

_
& SIMPSON
COURT REPoRTERS SHREVEPORT, LoUISIANA

(318) 429-2160

~--

MACK W. FORD
I

-- 7/22/97 ._------ 115 ...

l'

Q. he stopped A.

And did you talk with Judge placing Could


I

Taylor

about why

2
3

children comment?
I

there?

4:
5 .

MR. HODGE: to. BY MR. BERNSTEIN: Q. please why A. Q.


I

think you are required

6 7
8;

am asking

you to answer

the question, Taylor

so

tell me, did you talk with Judge

about

9 10 11 12 13 14

Sure, but could That is what


I

tell you what he said?

want to know; what did he

say? A. me. Q. A. Q. A.
Q.

Judge Taylor

asked me did the Sheriff

work

IS
16 17 18 19
20 211 22

Did the Sheriff

what?

Beat me up in the office. Okay.


I

said he did, and he just laughed.

Okay. That is all we got out of him.


I

A.

was there

to try to make a kind of agreement to send children Q. to us.

to get Mr. Taylor

23

And that was the extent

of the conversation

with Judge Taylor?


25

A.

Yes, sir.

BAJN

& SIMPSON

COURT REPORTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

MACK W. FORD ---_. ---- ---_.Q.

7/22/97
... _

--

---

116

And when he asked and he laughed,

you that question

and you next?

responded
3!

then what happened

A.
~

I just felt like it would be best

for me to

4
5
6'

leave.
Q.

You didn't No, sir.

pursue

it any further

than that?

A.
Q.

7 8
9

And you didn't

say, I don't

think

that is

funny? A.
Q.

No, sir. Okay. You assumed that his laughter was at

10

111
12 13

your predicament? A.
Q.

Right. Okay. Any other examples that you can give of intense

14 15
16

me as to how you have been the subject scrutiny? A. In 1988 the Department

of Social

Services

17
18 19'

came and took away children simply saying,

out of that home by just They took of the parents, and we told me into all

do you want to go home. out without the wishes

those children considering weren't

20
211 22

the parents;

took them to court, One parent

able to go to that court.

that was in that courtroom saying what they said,

that they coaxed

them vary,

23
24 25

and all the stories

of them are different.


Q.

So how many parents

did you talk to that had

BAIN &
..

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISlANA

(318) 429-2160

__ ----

MACK W. FORD

-- 1/22/97
117

been in the courtroom A. lawyer, can't got.


Q.

during

those

-But the
I

21
3

There was only one that was there. our lawyer, talked to that one person.

4 5;
6

recall

his name now, but that was a report

we

And what

leads you to believe constituted

that the scrutiny? and

7
8

action A. getting

of DSS in 1988

intense

The way they handled with the fire marshal, to shut us down. And anything else?

this last episode and I call it a

9!
10 11

conspiracy
Q.

I
12 13 14

A. habeas
Q.

We feel like the way they put out that corpus order. Which habeas corpus order? corpus order ordering me

IS
16
17 l8i

A.

There was a habeas

to take those kids to the Arcadia was an impossibility charges against because

High School, Crouch

and it filed

Mr. Wayne

me to be in the courtroom This was impossible

the next for me to be

19

following

morning.

20
21

in both places.
Q.

And that was in the summer Yes, sir. Okay. We were out June.

of 1996?

22

A.
Q.

24 25

A. Q.

So we have got 1989 and 1996.

Any other

--

BAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT. LoUISIANA

(318) 429-2160

MACK

W.

FORD

-- 7/22/97
... ....

--------1 2'
3 4:

.-----

- ---~leads you to believe scrutiny that you the have fire

118

anything been the

else

that of

subject and their

intense

by DSS,

marshal A. Mr. The


I

agents? is under the impression, them entrance. up until that

See,

everyone that had with the

5
6 7!

Bernstein, fire marshal

we have free the

refused of

run

that right

place after never they

this

happening with

Sheriff, and we

8
9

happened

Sheriff, than

have but

questioned, were able Then came, come Ms. the

other to come. the

disagreeing,

always

10 11! 12 13 14 15 16 17 18
19

Department was enough was

of

Social

Services to call, long with ago. that. But

when they When She we

they would

if there in, and

courtesy not

that

proven

Wafer name

came,

we had

no problem an

had

of a child in this of the we

with

affidavit. that they

realized the code

last law

incident

worked faith,

under and

without

being

in good

so therefore

couldn't that sir. So back that was

comply.
19967

Q. A.
Q. leads intense the what you

Now, Yes, Okay.

20 21 22 23 24 25

to my question. you have been of agents and

What the

else of

to believe

subject

scrutiny Fire have

by the Marshal

Department and their 1988

Social other

Services, than what

State you

told

me

about

other

than

RAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISlANA

(318) 4292160

MACK W. FORD -- 7/22/97

1--------- -- -----.--.-.------.
Ii

119

happened A. didn't

in 1996? Okay. At the very beginning, the home

realize

the time frame, and it is documented of Social


I

4
5

that the Department against Jenkins, me because

Services

filed charges Mr. Woody

wasn't

licensed.

6
I

our state representative,

all of you know of

7~
I 8
91

him, was flown from Baton Rouge Arcadia, Louisiana,

to the courtroom on behalf Services

and testified of Social

of the didn't

home that the Department

10' 11 12
13i

have the right to do what they did. So he ruled the next morning has been waves of problems Q. A. documents. in our favor, and it

ever since.

And when did that happen? As


I

14 15
1

said,

don't

remember. Jackson

It is on the from Lafayette, Law

Grinnis

(phonetic)

16 17 18 19 20 21 22
231
I

Louisiana, Association. Q.

along with Dave Gibbs We won that case.

and the Christian

And that was -- wasn't

that the time when

the judge ruled that the State had to use the District Attorney rather than their own lawyer? MR. HODGE: judge ruled? I MR. BERNSTEIN:
I

Are you asking

him what the

am trying about.

to see if

24 25

that is the time that he is talking THE WITNESS: I can't

remember.

BAlN

&

SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

MACK W. FORD -- 7/22/97 --_ ..... _--- .'-' . ..._---

__

_ ..

_---

.....

,-

---

120

1 2
3 4

BY MR. BERNSTEIN:
Q.

Okay.

But that is the time that Jenkins came up and as a legislator

Representative

told the Court what the law was?


A.

5! 6
7
8

Yes, sir. Okay. And any others? but I can't

Q.

A. remember
Q.

I am sure there is others, them right now.

9 10 11

Now, this last time you said that they come in good faith, about, and is that what you told order; is that or is

didn't

me earlier

they had an ex parte

12
/.

what you mean by they didn't there something,

come in good

faith,

13
14

some other way that you determined

that they were not in good faith? A. Mr. Bernstein, what has happened in the past before a

15 ' 16
17 181 19 20
I

with a judge,

that when you put the papers reading

judge and he will sign them without give them a signed check,

them, and

blank check,

to do anything with it.

they want to do, we have got a real problem Q.


I

And you are suggesting blank check

that somebody

gave a the

21 22 23
24

signed, order? A.
Q.

to the judge when he signed

I am saying

that. judge?

And that was to which That is Judge Butler.

25

A.

L
BAiN

& SIMPSON

COURT REPoRlERS

SHREVEPORT, LoUISIANA

(318) 429-2160

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