Professional Documents
Culture Documents
-_
122
__
Q.
Okay.
what that
2:
3 4
connection someone
check?
If I could
5
6
7 s9
I
BY MR. BERNSTEIN:
Q.
blank
check",
are you
talking A.
Q.
10: 11 12
r '-
Got you.
were
confused,
13 14 15 16 17
181
that somebody
Judge
a check and
No. Okay.
am sorry.
Just so we are absolutely that the witness sense, testified using a they
19
20
21 22 23
to do whatever facility.
to
take a short break? (A brief recess was held) Back on the record now.
r>
24 2S
MR. HODGE:
BAIN
&
---_j
SIMPSON COURT REPORTERS
-
SHREVEPORT,
LoUISIANA
(318) 429-2160
---
---
-------
121 ------_._--,
I
Q.
as to what happened
proved
what happened
when he signed
Q. A.
5
6
7 8
9 10 11: ,
threatened
kicked
imprisonment
in a room without
them go to the bathroom And that was in 1988? Yes, sir. Okay.
for hours.
12
13 14
And how did you come to understand Judge Butler a signed, blank
had given
15
16 17
in connection
A.
do anything
Q.
18 19
20
that somebody
gave Judge
A.
I understand
21 22!
23
24
order,
one-sided Q.
A.
25
___________
BAiN
anything
J
(318) 429-2160
&
SHREVEPORT. LoUISIANA
During
the break,
Brother
Ford advised
me that he has
2,
had litigation
31
41
as well as I, as to whether
I
the Sheriff
of the State.
So as a matter
of full
5!
6
,
he would
like to disclose
in litigation
7:
I
more,
I donlt
the Sheriff
8
9,
the Bienville
BY MR. BERNSTEIN:
Q.
10
11
that your
counsel Ardis
just
referred Whitman?
A. Q.
the Sheriff
12
/--\
13 14 15 16 17 I
181
of Bienville
A. Q.
Parish?
19
21 22
when they came out last year they were not in good faith, and my question to you is: How did you workers from the
23
determine
'"
/
24
25,i
A __ .
B_Y __W __ h_o __t __ __ h e_Y __ b_r __ O_u_9_h_t __ ,__ c_a_r __ l_o_a_d_S O_f __ t_h __ e_m_' _
SHREVEPORT, LoUISIANA
_______j
(318) 429-2160
...
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------
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124 ._--
1
2 3i
I
Q.
A.
Q.
were there?
4
5
A.
Q.
When you say "who they brought", the fact that they had eight
6i 7
8
or nine
9\
10 11 12 13 14
officer?
A.
Q.
15 16
17 18
workers
came in 1996, did they indicate they felt they needed I think,
many children
A. Q.
to talk to?
anything scrutiny
19 20
21
constitutes Marshal
A.
and their agents? It has just been a series the years, and it seemed of investigations time
22 23
24
through
one child
another,
25
ever believed
the truth.
_J
BAIN
&
SHREVEPORT, LoUISIANA
(318) 429-2160
MACK
W.
-
FORD
-- 7/22/97
----1 2:
125
believed
when they come they will never And those children have went they
3
4
5;
their way
6
7 8
I
they? A.
I
10 11
guess
-- every
12
13 14 15
I
from the
16 17 18 19 20
Yes. Were they able to interview No. So they were not able to obtain so to speak? the other staff members?
Q. A. Q.
21 22
23
Q. received
24!
received
p 2sLe ort,
SHREVEPORT, LoUISIANA
(318) 429-2160
MACK W. FORD
1 ~-ained in
2i 3
4' 51
A. affidavit,
Understand,
and I believe
child,
to a school
MR. HODGE:
B 9
I
question
limited
solely
101
Just make
11 12
13 14 15
BY MR. BERNSTEIN:
Q.
Reverend
that
they believed A. Q.
Right. And when you say "they", workers? you are referring
17 18
19 20 21
22
And when you say "the lies", you are to what? What the children Okay. tell them. you are
23
24
25
1L
Q_. __
BAJN
& SIMPSON
(318) 429-2160
MACK W. FORD
7/22/97 -------.
_.-.
127 Homes
occasion refused 3
4
5.
by the child
protection
workers? A.
Q.
6
71
occasion?
A.
8;
9
10i,
I
i
Q. interviewed
worker,
11 12
seen by the staff member? A. Q. Take us to court. Okay. So in other words, with regard to the
r"
13
14 15 16 17
18
rather
in the investigation? Before the judge, who might get the truth. it is your preference to obtain the
So in other words,
19 20 21 22
23
24
rather
than doing
it by interview
on the
Before
the judge.
And that has been your position All the while. Going back to paragraph
2si
BAiN
-------------------------& SIMPSON
COURT REPO~RS SHREVEPORT, LoUISIANA
----_
..
-----
----_._.
MACK W. FORD
.----------
-- 7/22/97
_ __ .- _
..
__:_--
1 2
3'
could
see the face of the fire marshal's that made the statement that is quoted
representative there.
4 5
6 7 8
but with
on our church
grounds. to believe to
9 10 11 12
that that is the same man that made the statement your lawyer A. Q. A. in the judge's chambers?
I know it was. And how do you know it was? He was the one that was handling our school, that case.
_-
<.
13
14
15
our home. -- so if
have been
16 17 18
19
20
have been the same man that you had a with there at the church or the
face-to-face
meeting
21
!
22i
A.
I
I
Yes, sir. If I tell you the name of the man, do you jog your memory? to say.
231
Q.
i
24
25
think
that would A.
I would be afraid
BAIN
&
SHREVEPORT, LoUISIANA
(318) 429-2160
.
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129
Q. 2
3'
4 5:
Okay.
Do you think
He was a crippled
remember
him. a
Mr. Robinson
being
6
7 8 9'
man?
sir.
10:
111
Okay. It is not the same man. Okay. But the man that told your attorney quote, "would not rest until school the end of
12
13 14 15 16
17 18 19 20 21 22
23 24 25
have been
in the early
'80s,
the same time as the lawsuit you? It was before Okay. Early '80s. before before that.
against A. Q. A. Q. A.
Shortly Shortly
I
BAIN
&
SHREVEPORT, LoUISIANA
(318) 429-2160
MACK W. FORD
---------,
-- 7/22/97
130
1
2
time.
I can't
remember
exactly
on the time frame on that -- you can look Mr. Jim Caldwell was confronted it
I remember
3
4
that case.
51
6'
Rouge,
readily Q.
it to Mr. Herring,
to be to your and
8
9'
10 11
121
1
in looking
at it, it looks like the only two names from the fire marshal's in the early '80s
13
initials
R.N., quote,
"Rob Robinson",
and a
14
15
Mr. Richard A.
I believe
16 17 18
19
I am believing Q.
20
I
211 22
Q. church, been
When you say that you, meaning the home and the school of intense
you,
the have
23
24,
the subject
scrutiny
fire marshal
25
BAIN
&
SHREVEPORT, LoUISIANA
(318) 429-2160
--_.-'---- --
--
_.
131
1
2
... 0"
A. Q. A. Q. methods
DSS workers. DSS workers? The department. Do you have any reason or approach to think that the in conjunction than they
41
5;
61
residential
8
9
I believe
it is different,
in their before.
11
11,
I
12 13
Back when
14
15
about
Rouge a couple weeks ago? A. Q. reason Yes. Before to believe Homes the depositions, did you have any treated, differently facilities? what with of that than
16
17!
18
19
20 21 ; 22 23 24 25
L
residential
has happened
BAIN
&
SHREVEPORT. LoUISIANA
(318) 429-2160
MACK W. FORD
7/22/97 132
Q.
tell than
r'
religious-oriented
5 6
Whitman
when he beat me up in will turn the fire and they will will get you one
that office,
8 9 10;
marshal
11 12 13
14 15 16
And that was in 1982? Somewhere Not 1982. along that line. back. And how
A.
Q.
much
of Bienville
17 18 19
20
I
you?
Q.
A.
Q.
21
221
talking A.
23
24
that was said; and we got another the same thing. that related
guy in
doing
25
to you
BAIN
& SIMPSON
COURT REPoR"reRS
SHREVEPORT, LoUISIANA
(318) 429-2160
_._
....
_--
MACK W. FORD
,
7/22/97
r" - -
. --_.
---
----._----_._-----said?
---
133
11
I r '\ ./
something A. them.
Q.
It was a lot of
3 4:
Who
5:
6
I
I
was that? A.
Q.
Bob Stewart. And Bob Stewart said? No. Bob Stewart was saying the same thing was telling you what the
Sheriff A.
10
11
was saying. How did you know about New Bethany? that Bob Stewart was
Okay. anything
12
13 14 15
By the parents. Which parents? The parents that called to place the
A. children
16 17 18 19 20
I
is a little
them;
21
22
in other words,
this would be a
23
24
parent,
25
l
BAIN
A.
They called
do the
&
SHREVEPORT, LoUISIANA
(318) 429-2160
MACK W. FORD
-- 7/22/97
134
would
tell
3
4 5!
A. forbid
6 7
8
from bringing
the children
take that child back out there. Which parent the parent told you that a State employee that they could not take a child
9 10 11 12
13
our records
and
Okay.
it take you to go
14
15
161
17 18 19
Okay.
to do?
A.
We have already
been trying
20 21
23 24
A. rendered
25
the -- whoever
BAIN
&
SHREVEPORT. LoUISIANA
(318) 429-2160
MACK W. FORD
7/22/97 135
1 2
child, Q. records
they were
sent bills
3 4 5 6
71
i
about
on the
8!
9
list and find out. Q. A. children Q. What list is that? The list of the parents there. And you all have a list of the parents there? records. and that that have had
10
11
12
/
"
13' 14
15 16
17'
has
18
19
the parents'
Q.
names
and phone
20
I )
applications? A. Q. worth Only five years, my wife said. you would have five years
21
22
So in other
words,
23
24
of records A.
25
the
BAiN
&
SHREVEPORT, LoUISIANA
(318) 429-2160
_._-
-_ ...
---------
MACK W. FORD
... -.... ---.. ---
-- 7/22/97
--------=-------------------=-=-; 136
1 21
left.
Probably
very
3 4 5
6j 7
that told you that a DSS employee to not put their A. call. child back
We would It would
have to call.
8
9
the ones that we have left. Q. to parents Stewart A. Q. A. Q. A. Texas. Q. A. And the same thing would be true with that told you that the Sheriff or Bob regard
10
111,
12
said something
13
/
What is the last name? Potts. Okay. I can't I would remember the name of that town in
14 15 16 17
18 19 20 21 22
Mr. Potts Q.
23
241
along
25
L-
BAJN
&
SHREVEPORT, LoUISlANA
..
(318) 429-2160
--_ ....
_---
...
_---_._----------.-------
MACK W. FORD
7/22/97
r >.
1,2: 3
----------
-- ---
- --
- -
-_.
.. _----_
137
told you about a conversation? A. Yes, sir. They brought the boy back out to
4 5 6i 7
8
I
that boy back out there; from his custody. And who told -The Department Told John Potts
l
removed Q. A.
Q.
of Social parents
91
back? A. Q. A. The daddy. Told the daddy? Yes. The mama wasn't there. that was the Services? in
10
11 12 13
14 15 16
I
Q. Louisiana A. Arcadia.
of Social
17 18 19 20 21
22
Excuse
me one moment,
between
Mr. Hodge and the witness) MR. HODGE: involved an allegation I asked my client if this in which that we are
23
24 25
from DSS.
If we could defer
questioning
on this line
COURT REPoRTERS
SHREVEPORT, LoUISlANA
MACK W. FORD
11
;
7/22/97 ---- ..
_- ----------No problem. to have to is fine. It is real evident today, so I am not that I will
138
2
3
4'
MR. HODGE:
MR. BERNSTEIN: we are not going worried up. BY MR. BERNSTEIN: about to be through
that
5
6 7
that.
I
9
Q.
Okay. 1980s,
The lawsuit
also says,
"Commencing began a
in
10 11 12
/
\
13
What is it that you have seen, heard or leads you to believe campaign of
14 15 16
17 18
that there was a constant harassment? A. Q. Louisiana harassment Go through Okay. began
and unremitting
that question
again,
says that,
19 20
21
against
the church is it
and my question
What
22 23
24 25
that you have seen or heard that leads you to believe and unremitting A. campaign
Because
of the orders
SHREVEPORT, LoUISIANA
(318) 429-2160
----_._--
---
__
...
._---_
139 .. _--------_....=..::::....::
I
always
r
>'.
been one-sided. They have always Right. Okay. Anything else? of Social is valid Services have been ex parte?
2' 3
Q. A. Q. A. always instead
4:
5
and what
is invalid
They have
8
9 101
I
always
,
1
evaluations,
and I feel like that is an insult. I may look crazy, but I ain't
11 12
131
Anything
14 15 16
the appellate
of removing
i
17 18
Q.
And who is it -- when you say "the State of it is kind of a broad term. I am going to
Louisiana",
19;
20
21
221
to believe
to begin
23
24
and unremitting
25l__ name
BArN
anyone
&
SHREVEPORT. LoUISIANA
(318) 429-2160
-
_._
...
......
_----
140
Q.
Okay.
In other words,
you cannot
say that
, 2'
3i 4
this person
or that person
that made
can't
recall,
6;
7 8
9!
with
There
has to of
Bob Stewart
has to be some
10 11
kind of tie.
Q.
to believe
there
is a
12 13
141
tie?
A.
the years. Q.
A.
15 16 17
18 i
What
is it that was said? down the home, always down the me.
ministry,
vendetta
against
has made
19 20
taking
understand
21
22
question Deputy
Bob Stewart
Sheriff
23
to believe
25
SHREVEPORT, LoUISIANA
(318) 429-2160
-----
. _. ---
MACK
W.
FORD
7/22/97
---that has
-=1.!,1
I
Stewart as the
Sheriff for
2 3
Bienville said
A.
Department wants
always
4: 5
6
of Social
Services,
child
to come Q. When; always have about and to call the DSS when? Department. pick them up, the a
7 8
9;
A.
When the
a child Sheriff,
goes
juvenile
calls have
10 11 12 13 14 15 16 17 18
191 20
Social this
got
here; So they
blah, Social
bring than
Department me or they
rather that
consult and
parent,
interview child
child,
believe
everything
says. Q. Do you on the of know part whether of or not there is a legal to call a the
a Deputy when
Sheriff they
Social
Services or
receive
A.
agreement
I
in some are
21
221 i I 231 24
obligated
to call
Department Q. mandates
certain
people
have
25 ______
RAIN
(318) 429-2160
142
is an agreement Services Q.
between
the Department --
of Social
is a state
4 5
61
7 8
am.
9i
this witness
of the law is or what his knowledge object to that extent. Answer the
to them.
15
16
I
BY MR. BERNSTEIN: Q.
!
My question
is:
of whether
or
17' 18 19
I
not there are certain that are legally abuse could to DSSi receive
people
obligated
to report
and that if they fail to do so, they criminal consequences, or not criminal
201
21
221
231
consequences, A.
,
i
but sanctions?
I
Mr. Bernstein,
But I am
also aware of the fact that if they make statements hiding that they are subject the confidentiality
.~
24
25
See, ever
behind
BAIN
&
SHREVEPORT, LoUISlANA
(318) 4292160
MACK W. FORD
--------
7/22/97
---"-.,--'--------_.
----- -----
143
I!
2
3
find out.
If
it is not valid,
41
5: 6 7 8
have that privilege, have a real problem Q. A. Q. How would Sue them.
and that is my big hangup. with that. you stop somebody from lying?
Any other way? No. (A discussion was held off the record between
91
A.
10i 11 12 r>. 13 14 15 16 17 18
19 .
Mr. Bernstein
BY MR. BERNSTEIN:
Q.
Going back, you said you believe between Deputy Bob Stewart
office?
for that
belief? A.
Q.
20 21 22 i 23
24
.........
And how many times have they rolled out at the Home? Every incident.
together A. Q.
A .
And how many? Two or three maybe. Okay. And this is over what period of time? i
25
Q.
BAlN
&
SHREVEPORT, LoUISIANA
(318) 429-2160
--- -_._- --
... - ... -
._----
MACK W. FORD
_.
-- 7/22/97
...... -..----~
__
..
_---
144
1 2 3 4i
A. Q.
Since Okay.
'88. So in eight years they have appeared Home two or three times
I
at New Bethany A. Q.
together?
5:
61
is a connection Sheriff
Bob Stewart
as a Deputy
in Bienville
Parish,
8
9
Fire Marshal's A. Q.
office? recall. Is there any place you could that you could help you
I can't Okay.
10
look or anybody
12 \ ,
remember?
A.
13 14 15 16 17 18
Need to depose
the juvenile
probation
officer.
Q.
Which
juvenile
probation
officer?
A.
Q.
Bob Stewart. Bob Stewart. would And what information have? would you
I
19
1
A.
20
21
22
Have you sued him? No. Now, any other -- so when your lawsuit says,
A.
25
Q.
BAIN
&
SHREVEPORT. LoUISIANA
(318) 429-2160
MACK W. FORD
__
7/22/97
_ __ --0 0 _ __ .0 _
145
1 i
2
began a constant
and is
of harassment",
what that
3 4:
5i 6
saying
In some cases. Okay. When you say "the State of included in that? in it.
7
8 9;
10i
is not included
to him. of Revenue
11 12
13
14I
the Department
and Taxation? A. Q. A. flew over Q. A. Q. A. numbers. Q. Louisiana Okay. And any other part of the State any other agency of They are not included How about the State in it.
15
to believe checking
16
17 18 19 20
helicopter?
21
22 23
24
in the in
25
and unremitting
BAJN
&
SHREVEPORT, LoUISlANA
(318) 429-2160
---------
~'
..- . ........-
146
1
2 3 4: 5;
against staff? ! A. Q.
the school,
No, sir. Okay. The lawsuit against says that in 1988 DSS and the church which to
I
filed a lawsuit
6
7
illegal
orders
the church
home to subject
the children
8
9
physical
and psychological
examinations.
take it you are refering in the 2nd Judicial were issued A. Q. ultimately proceeded A. Q.
10 11 12 13 14 15 16 17 181 19
20
District
at that time?
under was Constitutional? Parts. Okay. And are you aware that the Court to obtain an also
held order
that they did have the authority to interview A. Q. In part. Okay. children?
21
didn't
22
23
1-'\
24
To the extent
25
BAIN
& SIMPSON
COURT REPoRTERS
SHREVEPORT. LoUISIANA
(318) 429-2160
---_----
--
---- .._----holding is in
147
2
3'
and lawyers
can disagree
as to
4 5
6; 7 8
who won and who lost. MR. BERNSTEIN: layperson reasons He has a belief as a
the with
the Court's
9!
I
me for a
10
11 12
r\
the holding,
believe
accurately
13
complaint
in paragraph
8.
14
15
In part.
16 17
18
19 20 21
22:
This
is a deposition.
23 24
25 I
1
Any reason
to believe
that lawsuit
-
and obtained
i
1
J
SHREVEPORT, LoUISIANA
BAJN
&
(318) 429216()
MACK
W.
FORD
7'/22/97
__________________ 1 they were A. Q. anything leads you not in 90~-d-fa~th? give me that have seen, again, any Mr. Bernstein.
>.
l
14 B
I
2
3;
Do you have
reason or DSS
4
5
heard the
been
to believe Butler
that
when
employees ex parte
6'
7
the
Bethany
Homes
8!
,
handled
the
questions
that
10 11 121
were
asked.
Q.
mean
Stop.
The
way
they
handled
it;
what
do you
by that? A. Coming of the Okay. on the Oh, out names Did court yes. You are and questioning was on all the the children order. whose name
r:
13 14 15 16 17
181
court
interview
a child
Okay.
said
19
20
questions A. The
you
referring
questions;
21
22
is inappropriate
about
that
23 24 25
A parent kind
ought
to know
if they
are
going to be
to
of questions;
a parent
ought
_I
RAIN & SIMPSON COURT REPoRTI:RS SHREVEPORT, LoUISIANA
(318) 429-2160
MACK W. FORD
-- 7/22/97
._----_. __
.
__ ._-------
149
1
2:
present Q.
when they ask those questions. And how does that lead you to believe were not in good faith, in not that
3 4
;
out their job as they believed Because They would they wouldn
I
it to be? be in
5i 6 7 8 91 10 11 12
13
t let anybody
say, lead them, and then they record recorder today. Q. A. Q. coach just like this recorder
going
And how did you know that happened? I saw it. Okay. And in other words, you saw them
14
15 16
17
18
that we could
the
19
20
of what
the parents
21 22
23
I donlt remember
24 25
A.
of children
through
__
&
SIMPSON COURT REPoRTERS SHREVEPORT, LoUISIANA
.1
(318) 429-2160
MACK W. FORD
,
7/22/97 150
l'
that home, Q.
thousands
2
3
4
5:
,
6'
courtesy
7 8
9.
procedure
to do what they did; and at least to meet with them in my office and
give us a chance
talk
to them.
Q.
10'
!
I
11i 12 13 14 15 16 17
I
of child
abuse before A. Q. A. Q.
I
Okay. Most
away?
181
A. remember. Q.
don't
can't
19 20 21 22j
So it is your testimony
to 1988 away?
turned
23
24
25
He means,
Counselor, ------
he
BAII'i
&
SHREVEPORT. LoUISIANA
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