1

2:

I-

MACK W. FORD -- 7/22/97 152 -d-e-t-e-rm-i-n-ei -s-w-he-t-~ ~~ -~-h-a ~-m~:~-s---t-h-a-t-i tis po s sib 1e that it happened whether turned and that he doesn't recall it, or

3;

he doesn't

recall any times when they had been there is ambiguity

I

4
5 6 7

away, because

there.

MR. HODGE: question witness. in that it calls Subject

object

to the form of the of the away.

for speCUlation

to that objection,

speculate

8
9

BY MR. BERNSTEIN:
Q.

Reverend

Ford, when you say,

don't

recall,

10

my question recall

to you is:

Does that mean you don't when they have been turned away;

11 12
13 14
151

any incidences

or you don't A. turned Q.

A. Q.
I

recall what happened? don't recall any instances when they were

away. Okay. Right. Okay. Now, paragraph lawsuit 5 of your in paragraph lawsuit 9 says Prior to 1988?

16 17

18 19
I

sorry, that, Second church,

page 5 of your "Shortly Circuit after Court

that ruling of Appeal,

by the Louisiana Pastor Ford, the and

20j

21
22

the church residing

home and several at the church

parents

children action

home filed a civil and

23
(\

in this court against action

DSS and its agents, Baptist

241

that certain

is styled New Bethany

2sl__:hurCh'

et al versus

the State of Louisiana,

et aI,

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&

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SHREVEPORT, LoUISIANA

(318) 429-2160
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MACK W. FORD -- 7/22/97 r-- ----------------1

151

can't about

recall.

And again,

if you are asking

questions

2-

investigations

of allegations

of abuse or and had an

3
4i 5
6
I

neglect,

we have not been given

the records Once

opportunity are produced

to call those records. to us, he can answer MR. BERNSTEIN:

those records

those questions. him with

I am asking

7:

regard

to his allegation

that the -- as to allegations what basis he has for faith; and in

with regard believing

I

to my clients,

9
10 i

that they were not in good

that connection, client's prior response

I want to try to see what your has been to attempts claims by the State

11 12 13

to then to investigate MR. HODGE:

of child abuse. which is

And his response,

!
14 15 16
i

permissible of Civil

the last time I checked

the Federal Asking

Rules him

Procedure,

is, I do not recall.

if it is possible
i

that it could have happened

is idle

17 18 19 20 21

speculation. MR. BERNSTEIN: though, to probe an answer, Well,

I

am entitled, to stay

and I am not going

I don't

on it all day, but if he says, recall-MR. HODGE:

want to

He did not say,

don't

23 24

want to recall. MR. BERNSTEIN: You are correct. trying He to

(\

25iL__
------------ ---

s_a_i_d_'_I d_o_n_' t __r_e_call'and all I am simply

&

BAIN

SIMPSON COURT REpORTERS

SHREVEPORT. LoUISlA.~A

(318) 429-2160

------_

------

__ -

MACK W. FORD
..

__ .... - .. _-_._-suit number A. Q.

7/22/97 --- .. _ .. - ..--CV89-1227";

--that?

153
,

1 2 3:

do you recall that.

Yes, I remember Okay.

And then continuing, injunctive

your

lawsuit

4
5 i
I

says that you "sought relief",

and declaratory "Although passed to the

and it continues

to say that,

Court ultimately Constitutional attack

found that the statute it reserved

7 8
9 10
11

muster,

your rights

the application clause

of the statute

to them under that is

the due process what your

A.

of the Constitution": it?

lawsuit Yes. Okay.

says, doesn't

I
I

121
'/' ,

Q.
I

Was there any other

action

taken

in

13i
I

that lawsuit? A. Q. A. Q. A.
I

14

can't

remember. Did you win that lawsuit?

15
16

Okay.

In part. And what part did you win? Well, we could reserve another day to attack

17 18
19l
I

that statute.
Q.

20~
I

Now, your lawsuit

10 says,

continues,

and

21 22 23 24 25,

paragraph actions against

"Since the filing of these two and conspiracy to retaliate home of the
I
I

and in retaliation Pastor

Ford, the church

and the church right

for the exercise access

of their Constitutional and in an attempt

to the courts,

to quash

I
1 ... _BAIN & SIMPSON COURT REPoRTERS SHREVEPORT,
...

_j
LoUIS lANA

(318) 429-2160

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._/

MACK W. FORD ---1

7/22/97

----_. __ ._--rights to express

. - --1
its agents, to home in to

154

exercise

of their First Amendment beliefs,

2
3,
I

their religious

the State through has devised

DSS and the fire marshal, harass Pastor

a scheme

4 5
6 7

Ford, the church

and the church

an attempt close

to force Pastor

Ford and the church school".

the church What

home and the church

is it that you have seen, heard or been told

8
9;

that makes you think that the State has taken any action in retaliation for the filing of those in

10
11 12i

lawsuits, retaliation A. Q. A. there;

or a State employee

has taken any action lawsuits?

for the filing of those Because

of the way the things was handled. things were handled? of DSS workers in 30 minutes order and with a of the State out

13 14
151

The way which Sending sending

two carloads

two fire marshals

16 17 18 19 20 21 22 23,
24

ordering

that with a habeas

corpus

filing of a lawsuit of Louisiana

Q.

from the fire marshal me.

against

And that is in June and July of 1996? Yes, sir. Okay. Anything else? Anything else that acted in or for

A. Q.

leads you to believe retaliation

that a State employee

for your lawsuits the lawsuit

in 1989 and 1988, The

your defending lawsuit against

in 19 -- sorry.

25

you in '82, the lawsuit

against

you

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SIMPSON COURT REPO~RS

SHREVEPORT, LoUISIANA

(318) 429-2160

._/

MACK W. FORD
,
I

-- 7/22/97 ---

155 _. --_._----- '--"'1

Ii

'88,

and the lawsuit

you filed

in '89; anything

else?

2
3.

MR. HODGE: I believe involving the witness

As well as the litigation. about litigation

testified

4
5

some type of licensure Jenkins testified.

in which

Representative

MR. BERNSTEIN: 7 8 9 "Since the filing of these it refers

The lawsuit

says, I take

two actions",

which

to at least the 1989 lawsuit, lawsuit it refers

and I am not to

sure what other two actions.

to; but it refers

Let me ask the witness.

11 12
13 14' 15

BY MR. BERNSTEIN: Q. there? A.

Q.

What two lawsuits

are you talking

about

I think the one in 188 and Okay.

'82.

And what else leads you to believe has acted in retaliation against of

16 17 18 19
20!

that a State employee you, your church those

and the church in '82 and

home as a result

two lawsuits A.
Q.

189?

Taking

the children

out of the home.

And when was that? Well, along about that time or a little

21 22

A. after. Q.

When was that? They would When take the children out. out, wasn't that

24 25

A. Q.

they took the children

RAIN

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SHREVEPORT, LoUISIANA

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MACK W. FORD -- 7/22/97

0. _

156
'I

1~~B8?

2
3

A. Q.

It was some after Okay.

that. since
1989 that

What has happened

4 5

makes you think that a State employee retaliate against you for you filing

is seeking the lawsuits

to in

7 8 9
10 11

A.

Well,

after

that we were denied

-- when a to be to

child would

run away, we were denied

the right

in the presence

of that child or in the courtroom

hear what went on. Q. A.

Q.

Okay.

Anything

else?

No, sir. Okay. Now, what is it that you have seen, there is a and

14 15
i

heard or been told that makes you think conspiracy your church rights rights? A. Here we were to retaliate against

you, your church

161

home as a result

of the exercise

of your

17 18 19
201

of access

to the court and First Amendment

in our camp meeting

1996,

the last

I
!

week of June,

first part of July, from the Department

two carloads Services part of

21

of case workers

of Social

22
23
24i

and two fire marshals our youth a lawsuit camp,

showed up in a business

and both of them because us and against

of that filed It seems,

against

the church.

2sl

t _o ___ m_e t_h_a_t t_h_e_y w_e __ r_e __ r_e __ t_a_I_1_'_a_t_i_n_g a_g_a __ i_n_s_t w_ha __ t_h_a_s
BAJN

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COURT REPORTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

MACK
------.

W. FORD

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

-_

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._ ..._---

157

1 2
3;

happened

in the past; times,

if not, why didn't

they show up

at separate didn't

or why didn't

they call and why

they show a little

courtesy? to let me know two corning

4i 5 6
7
8
9

They at least could have called that they have a problem carloads within
Q.

instead

of bringing

of case workers apart.

and the fire marshals

30 minutes

I want to go back and make sure I am real Is there anything that you have seen, that a

clear on this. heard

I
I

10:
11

or been told that leads you to believe since

1989 has sought

State employee against

to retaliate

12
..-. .

you for the exercise or the right

of your right of access your religious

"

13 14 15 16

to the courts beliefs A. Q. I

to express

that you haven't No. Okay.

already

told me about?

And is there anything

else that you

17 18 19 20 21 22 23

have seen, heard or been told that leads you to believe that a State person employee has sought against to conspire you, your to or in

with another church

to retaliate

and your church

home with regard

retaliation

for the exercise

of your right of access your

to the court or the right religious beliefs?

MR. HODGE:

for you to express

r>.

24

Other than what he has

2slalreadY

testified

about?
i
______ . __ .-J
j

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SIMPSON COURT REPoRTERS

SHREVEPORT. LoUISIANA

(318) 429-2160

MACK W. FORD
I

7/22/97 158

11
2
3

MR. BERNSTEIN: already testified to.

Other

than what he has

THE WITNESS: Department marshal's joint I

I

We felt like that the had contacted the fire

4 5 6
7:

of Social office,

Services

which going;

they did, to get a double, that they could put the

inspection

pressure

on me, push me out of the ministry.

8'
9

BY MR. BERNSTEIN: Q. When did you first believe somebody that somebody at

10 11 12

DSS had contacted office?

at the fire marshal's

.
i

A .

They had to, or they wouldn't together. And that is the basis Yes, sir. Now, your lawsuit its agents,
a scheme

have

showed

up

131

that close Q. A.
Q.

14 15 16

for your belief?

says that,

"The State has and in

through devised
19 20 21 221
23 24
I

DSS and the fire marshal, Pastor

to harass

Ford, the church have participated

the church

home~.

What employees

that scheme? MR. HODGE: reading from? MR. BERNSTEIN: page

5.

What paragraph

are you

It is the bottom
10.

of

It is still

in paragraph

25

MR. HODGE:

The question?

_J
(318) 429-2160

BAIN _.

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SIMPSON COURT REPoR'ffiRS .. - ..

SHREVEPORT, LoUISIANA

__ . __ ..... _

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._----_-

MACK W. FORD -- 7/22/97

,-----

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._--

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159

1
2 3:

BY MR. BERNSTEIN: Q. devising church My question a scheme is: Who participated in and the

to harass

you and the church

4;

home? The fire marshals, the Department of Social

I
5

A. Services.
Q.

6
7

And what

is it that you have seen, heard or that they did

81
i

been told that leads you to believe that? A. The only thing

I had was that they showed that they

up

11
12 13

at the same time, and we felt in our heart had to get together is no accident to devise

some kind of scheme. show up that quick,

It

that they would 30 minutes

14
15

that time, within Q.

apart. up together

What is it about them showing

16
17 18 19

that is bad? A. showing Q. Because they had really no probable cause of

up together. Well, wouldn't it actually is something that would be -- I am trying significant be different and one on about than

I
201

to understand them showing them showing Friday? A. marshal

why there up together

21

22
23

up, say, one on Thursday

r>.

24

Well,

if

they had come early fiath,

-- if the fire the

25

had come in good

and of course,

BAlN

&

SIMPSON COURT REPoRTERS

SHREVEPORT. LoUISIANA

(318) 429-2160

----------

MACK W. FORD -- 7/22/97

____ ._ _,__ . __ .,_ .. __ . . ..._. __ .._ ... _ 160

11

fire marshal

hadn't

been there

in over ten years~ the Department of

all of a sudden Social

41

they show up with we had to believe They hadn't

Services,

that there must be been there in ten

some kind of scheme. years.

I

5
6!

Q.

So there actually object

wasn't

anything

-- you except for

7
8 9 10
111
I

wouldn't

to them coming

out together there

the fact that you think that means conspiracy? A. Q. Right. Okay.

is a

So you don't have anything of them coming

you

12
I '

don't have any criticism same time except were working A. that

out at the

13 14 15
161

it makes to harass

you think that they you? time of time

together

Right.

And then at the particular our youth

our camp meeting, of the season. Q.

camp was the busiest

17 18 19 20 21

In other words,

they showed

up during

the

camp meeting? A. Q. A.
! j

Right. And that was when? That was last of June, first of July.

22
23 24
2Si

Q. A. Q.

How long is the camp meeting? They usually Okay. run about four or five days. of July

And that is the Fourth

BAlN

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COURT REPORlERS

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MACK W. FORD

7/22/97 161

i
11
2 3

weekend?
A. Q.

Always

on the Fourth

of July week.

And what day of the week does the camp start? It starts Okay. If the 4th falls in that week, it starts on on a Monday.

4:
5;

meeting A.
Q. A.

6 7 8
9

that Monday.
Q.

Okay.

And if the 4th falls on a weekend? we follow the it

10 11 12
13

A. after.

If the 4th falls on a weekend, If it falls on a Sunday, it.

then we follow

4th after Q.

If the 4th of July falls on a weekday, is --

your

14 15 16 17
18

camp meeting A.
Q.

The week of the 4th. That 4th; and if it falls on a weekend, following? then

it is the week
A. Q.

Right. Okay. And do the students, Homes the children

19 20
I ;

that are in the New Bethany

I

stay at New Bethany

21 22
23

during A.
Q.

the camp meeting? Oh, yes. Now, your 6 says, last --in paragraph 1996, 11 at the top Fire

24 25

of page Marshal

"On June 21st,

the State scheme

and DSS implemented

a joint

to harass

BAJN

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SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

MACK W. FORD

7/22/97 162

1.

and retaliate church home,

against

Pastor

Ford, the church, and their

the Is

./",

2
3,

the church besides

school

staff".

there anything

what you have already

told me

4 51
6 7 8 9 10i

that you have seen, heard that supports a joint scheme A.

Q.

or been told or just believe that they were implementing and retaliate against you?

your belief to harass

No, sir. Okay. As I understand up together, it, it

1S

the fact

that they showed

i

or showed

up on the same

day? A. Q.
1996

11 12
,r',

Yes. On that day, the first time in the summer were the State of

131

they were out there,

Fire Marshal

14 15
I

employees time? A.
Q.

and the DSS employees

there at the same

16 17
18. 19

No, 30 Okay.

minutes

apart.

A. second. Q. marshal A.
Q.

The fire marshal

came first;

the DSS came

20 21 22 23 24

And were you there the first time the fire showed up? On that day? On that day. Someone Okay. come got me, I believe. Where were you when they first showed

A.

2SL
BAiN

Q_ &
SIMPSON COURT REPoRTERS SHREVEPORT, LoUISIANA

(318) 429-2160

MACK W. FORD

7)22/97

---1

._- --- ._

163

up? A. office.
Q.
I

2 3
4:

can't remember.

Maybe

was in the

Okay.

The first time the fire marshal

5
6

showed A.
Q.

up, did you speak to them? Sure did. Okay. What did they tell you? the premises.

8' 9

A.
Q.

They came to inspect

And what did you say to them?

I

10 11 12 13 14 15 16 17
18 j
I

A.

am sorry,

you can't

inspect

the premises. the

They said, you tell me that we can't premises.

Q.

inspect

First

-- we can take it slowly.

When the

they

said to you that they had come to inspect premises A. you can't
Q.
I

said, you are out of your jurisdiction; these premises. else at that point?

inspect

And did you say anything

I

19
20

A. Q. A.
Q.

can't remember.

was upset. already?

You were upset by that point Yes, sir. Okay. Because Okay.

21
22 23
I

And why were you upset? of their arrogant And at that point attitude. the only thing they

A.
Q.

24'

25

had said was that they had come to inspect

BAIN

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the

COURT REPoR1CRS

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--

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MACK W. FORD
r--I

-- 7/22/97

--------.--premises? A. Yes.

.. --------------=~

164

I'
2

They were demanding.

They

are very

31
4,

demanding. Q. A. midst And you were upset I was upset because of calling at that point? they were right in the

6 7 8

-- instead

me or making

some kind of pad and you are

I

arrangements, pencil,

we are here, with his little

we are here to inspect to let us inspect

the premises;

not going
I

the premises,

he said.

10! 11 12
13

said, you are right,

Q.

you are out of your

jurisdiction.

Okay.

And then after you said, you are out did they say anything? they said, we will be back; best

of your jurisdiction, A. All right,

14
15

I can remember. Q. Marshal A.

Q.

And do you remember employees These were?

who those State

Fire

16
17 18 19

two men here

(indicating). Mr. Flesher and

And you are indicating sitting

Mr. Myers I
I

down at the end of the table? are, but yes.

201

A.
Q.

I don't know what their names Okay.

21 22
23
24

But those were the two men that you

spoke to? A.
Q.

Yes, sir. Okay. And then what did you do after and go back to the office? that?

25

Did you turn around

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MACK W. FORD

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165 .-_._-----_ .. -----=~

A.

started

back to the office with the camp.

I

or making don't

some

2
I

kind of arrangements what was happening.

Q.

remember

3: 4

Okay. Then all of a sudden, showed up, two carloads. to one of the two cars of case

A. workers Q. those

6i
7 8
91

And did you speak to somebody,

case workers? A.
Q.

Ms. Fair. Okay. She said, we have come to investigate; we have got to investigate. the complaint,
I

10 11 121
I

A.

have got a complaint;

I

And

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

said, who you got to see; who made to that effect.

something already Q.

And by that time it had

put us all in a tailspin. So in other words, she carne up and said, we

need to investigate A. Q. A. Q. A. Q. already A. Something

some complaints? to that effect.

And you said, who made the complaint? Yes. Okay. And I said at that point And at that point in a tailspin? Yes.
I

She said, we can't

tell you.

-you were

your words were,

f\

25

said, we will

find out who made the

RAIN

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COURT REPoRlCRS

SHREVEPORT, LoUISIANA

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-_._._---

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MACK W. FORD -- 7/22/97 ----So when

2;
3
I

-_
looked,

__
I

...

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166

saw the cars loaded have had any kind that home, they

with case workers, of -- I mean,

and if they would concerned about

really

could have called

I

me and said,

look, we have got a Ms. Wafer

5:
6
7

list of names here we want did that. they were checked

to check out.

We gave them the boys; we gave them whoever looking for, and there was no problem. with it. She

81
9

it out, and we had no problem

But when they came in, I said, who you got to see.
I

10 11 12
13

They said, we have got a list of names of 94,

and it blew us away.

Q.

Okay.

How did that blow you away? out of 84 you are going or whatever, to

A.

Well, because

14 15
16 17

find, or out of 200 children going will to find children

you are that

that are just disgruntled liars.

lie, and we know they believe

So here we

are in a camp meeting. because people

I told Mama,

here we go again; these

18
19

kids know just exaclty and get what they want.

how to manipulate I say today

that one

20 21
22

day they are going instead Q.

to be working

for the juvenile

of -- juvenile

can take them then.

Now, after you asked who made the complaint --

23
24 25

and you were told we canlt tell you that A. Q. Right. Okay.

What did you say at that point?

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7/22/97

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--_ .. _--_._._ toward

167

1 2

A. the best
I

I think we were walking can remember. We went

the office, My

in the office.

31
4:

wife was in there.

Q.

And that was -- when you say "we", that was

5
6 7

you and A. Q. A.
I

Ms. Denise. Ms. Denise Right. And what do you say next?
I

Fair?

Si
9

Q. A. something
Q. A.

10
11

told Mama, we got more problems,

or

to that effect. And what happened

I

12 13

next? at all.
I

can't remember

We were

--

just said

I
14 15 16 17

simply before

said, you can't see them. if they are going

have always

to have any kind of to do is sit down with have the parents be it.

investigation, the parents,

what they ought call the parents,

IS
19 20 21 22

there and everybody

sit down together

and discuss here.

But they said, we don't want didn't before.

Q.

the parents

She

say that, but we have been

told that in times

Okay.

What did Ms. Fair say to you? with her and you turned

Did to your

23
24

you walk

in the office

wife and say, Mama, we have got trouble, have got problems?

or Mama, we

25

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SIMPSON COURT REPoRlERS

SHREVEPORT, LoUISIANA

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

1

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168

A. Q. A. was going !

Something Okay.

like that. next? -- my mind

21 3

And then who says something

I think as far as I can remember so fast, I said, they want

4
5i

to investigate

84, examine, Q. A. Q. "huh-uh" A.

investigate

84 names. next? "huh-uh".

6 7 8:

Okay. My wife

And what happened said "huh-uh",

and I said

Your wife said "huh-uh",

and you said

9
10 11:
i

We both said "huh-uh". What happened next? got with the Deputy to have I said,
I

Q.

12
/

A. Sheriff,

She left, went outside,

13

and she said to me that she was going and I said to her, Ms. Denise, buried someone

14 15
16
171

to investigate, God has already

out of that department,

and it looks like he is going bury some others. Q. A. And what did you mean by that? I meant that God had already buried it and

18

19 20 21 22 23
24 25

Mr. Armstrong knocked

who had come out and raided down, threatened

the gates

to kill my dogs and

held my family Q.

in prison. it was your belief of the actions that

In other words, died because

Mr. Armstrong against A.

he took

I really

believe

that.

BAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT. LoUISIANA

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MACK w. FORD -- 1/22/97 ---_ ... ... "'--' ,

._----,

169
;
I

Q. were
3;

Okay.

And by making to communicate

that statement, that you believed New Bethany

you that

intending

because would

she was investigating

that she

4
5;

die as well? A. It wasn't a threat. I said, it looks like

6
7 8 9

the Lord will have to get some more of you. Q. belief A. Q. because A. Q. tailspin. A. meeting, of Social trying In other words, that the Lord would it was you indicating take your

Could do it, right. that he was going they were Yes. investigating to take some action New Bethany?

10
IIi

12
/
"\

He could do that, yes. that you were in a

13 14 15

You said earlier

What do you mean by that? So disturbed fire marshals Services, over us being already in a camp the Department

16 17
18

arrived,

here they come, and we are now our camp. My mind was going in

to get through

19
20 21 22

so many different disturbed,

directions

that we were so always caused problems

and we knew that it

when they came. Q. up while A. enough And the biggest a camp meeting They should courtesy problem was that they showed on?
I

23
24

was going

have called us; at least have

25

to call us.
..- _ ....

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(318) 4292160

RAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT. LoUISIANA

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

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._-----was going on on

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170

Q.

And the camp meeting

'\
/

2i
3 4

June 21st? A.
Q.

They destroyed And after

it. in your office

that conversation happened

and she walked

out, what

next? or they left,

61

i
I

A.
I

think they called

I

the judge;

71
8;

think.

And then later on Mr. Harper,

got in touch with our

I

attorney, remember
Q.

and they negotiated.

don't

all that happened. Okay. Did the DSS case workers that day? think it was that day. on June 21st? maybe come back

10
11

out to New Bethany A.

Q.
I

12
13 14 15 16

don't

Okay. But
I

So they made one visit think they delivered on the habeas And-excuse me, but

A.

the papers

the next morning

Q.

corpus.

Okay.

17
18 19
20!

A.

Time element

don't

know

the time elements. Q. A. Q. A. And that destroyed Yes. And how did that destroy The parents the camp meeting? were so afraid that they the camp meeting?

21 22 23
24 25

of those children

that they would began to leave.

Q.

come and take their children

How -- it destroyed

the camp meeting

that

BAlN

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

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

7/22/97

11
/",..

day? A. Q. out there? A. Well, Well,

-------.. ----1.
learn that DSS was You couldn't Here is a bunch of police and they show up and kids running

171

"',

2:
3

the next two days probably.

And how did the parents

4
5: 6

they saw the commotion.

help but see the commotion. cars or Sheriff with insignias everywhere.
I
I

7
8
9;
1

cars or whatever, and Deputy Sheriff

It just threw

it completely

out.

101 11

Q.
A. Q.

Why were the kids running Playing. Okay.

everywhere?

12
I

131
I

A. play. Q. A. games.

Don't you know what a camp meeting

is?

They

14
15 16
171

They were playing? Yes. They have basketball games, football and they kids

They have all kinds of activities, everywhere. I am talking about

18

are running everywhere. Q. anything

19
20

So the kids running

everywhere

didn't

have

21 22
23 24
I I

to do with the fact that two station Sheriff's car drove up?

wagons

and a Deputy
A. No,

but when they learned

who it was, And

someone

said, let's get our kids out of here. or somebody said,

25

Ms. Denise

last I saw, they was

BAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT. LoUISIANA

(318) 429-2160

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MACK W. FORD -- 7/22/97

-------_. -._-----_._-_. __ ..=....:_;;

172

Ii r,\

running

through

the woods.

So the kids were afraid, were afraid,

2
3
,

the parents

were afraid,

the counselors

of those churches

that had children

there.

,
4'

Q. A.

And why were they afraid? Because they were afraid they would take the

5 6;

children. Q. meeting?
A.

7
8

Those were kids there just for the camp

9
10' ,
!

They were

still afraid.

They didn't

know

whose

children

is who. MR. BERNSTEIN: Let's stop and take a

11 12
/

break. (A brief recess was held) In the interest of his two

"

13: 14 15 16 17 18 191 20 21 221 23 24

MR. HARPER: accuracy, dates

I fear that Reverend

Ford is mixing

and he is testifying

as to everything

happening

on one date, and actually where the DSS came out.

there was two occasions I was not there on the first and I fear say

date, but I was there on the second date, that the two dates this, are being combined.

But I will

that the pleadings

to the best of my knowledge

are correct. BY MR. BERNSTEIN: Q. Reverend Ford, I know during the break that

25L:u
BAiN

conferred

with your lawyer.

As a result

of that,

----------------------------------------~ & SIMPSON COURT REPoRTERS SHREVEPORT, LoUISIANA (318) 4292160

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MACK W. FORD -- 7/22/97

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

173 -------------------------------1

1
r\

do you want to change so far with regard A. is why

Q.
I

anything

that you have told me

2
3:

to what has happened? -I

Maybe

the dates

can't
I

remember.

That

4
5

told you the time frame Okay. Your lawsuit

couldn't

remember. 11 says

in paragraph

6 7

that

"On June the 21st, the fire marshal a joint scheme to harass demanded

and DSS

implemented

and retaliate,

8;
9

and that the fire marshal the facilities available

that the staff make and that is is

for inspection",

10 11 12 13 14 15 16 17 18 19' 20
21
I

what you have told me about happening that correct? A.

Q.

that morning;

Correct. Okay. And in paragraph wagon

12 says,

"About

30

minutes workers children

later two station arrived demanding

loads of social 84 of 200 and that up

to interview

on the premises

or at the school",

is what you were telling and saying,

me about Ms. Fair coming

we are here to investigate

and we have got

a list of children?
A.

Correct. Okay. And that, alleged "In making their demand, child is

Q.
I

221

the social workers abuse had occurred referring

that unspecified

23 24
25
I

on the premises",

and that

to what you have already

told me about else

Ms. Fair saying

that day, or was there something ---------------

---------------_j
(318) 429-2160

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&

SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

--

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

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174

1
2. 3

that she said that we haven't

A. Q.

about?

That is what she said. Okay. In other words, what you have already

4
51 6

told me she said? A.

Q.

Right. And then the last part of that paragraph of course, were untrue",

7 8
91
I

says,

"These allegations,

and by that, what do you mean? A. were We checked out the names of those that and that had Of course, we

10 11 12
13
/

that they accused

us of abusing,

been put on a recording didn't

of those names.

have the 84, but we have

the particular

names,

blah, blah, blah.

Q.

14
15

Okay. And we tried to cover that and see if that

A. was true.
Q. A.

16 17
18

When did you do that? That was probably sometime right after a little after they were

19
201

there,
Q.

they were there. the names of the

And how did you obtain

21
22

children?
A. Q.

They had a list of the names. Okay. Did they leave the list with you?

A.
25 Q.

Yes, sir. Okay. And you went and talked to the 84

BAIN

&

SIMPSON COURT REPoRTERS

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(318) 429-2160

MACK

W.

FORD

-- 7/22/97
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175

1
/-

children A.

yourself? No, sir. I talked that were the that to the abused, list were ones that was abused. gave you

'\

3
4

named

specifically Q. In other the victims

allegedly that they

words,

5 6
7

identified been the A. there was Q. other

i

children

supposed

to have

of abuse? the that best we I can remember, abused. any that

I understand, three Other or four the

81
9

supposedly did they

than you

list,

leave

101

papers A. Q.

with

that

first

day?

11. 12
/,

I can't The at next the

remember. paragraph home says and at that, church the "After school" home and

13 14 15
161

officials now, church A. when

church

it says

"officials

church

school", New

that Bethany

is referring Baptist when

to you?

Church. it says officials, it is

17 18 19 . 20 21 22 23 make

Q.
people?

Okay.

Well,

A. that Q. church accede CSS",

Officials. decision. So when home and

I am

the

pastor.

I will

have

to .

it says

"After

officials to

at the

church

school of the about

refused State you?

to the they are

demands talking

Fire

Marshal

and

/-,

24

25 A.
RAIN

We 1 _l_,_t_h_e_r_e __w_e_r_e __ s_e_v_e_r_a_l __o_f_o_u_r_p_e_op ~

SHREVEPORT, LoUISIANA

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SIMPSON COURT REpORTERS

(318) 429-2160

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MACK W. FORD -- 7/22/97

176

2 3

Q. A.

Who else was in and around I think Brother Garcia

there? maybe Douglas;

maybe;

maybe

some of the other pastors

Q.

from the churches. officials to go

I
5!

Okay.

Other

than you, what other school refused

6 7
8 9:

at the church

home and church

along with the demands

A. Q. A. Q.

of the fire marshals? Brother Garcia is one.

I guess probably Who? Garcia. Okay.

10 11 121
i

And how did he -- did he tell the

fire marshals A.
Q.

anything? say a thing. to you about think it?

13'

He didn't Okay. Yes.

14

Did he say anything

15 161
17

A. a right
Q.

He said he just didn't

they had

to come in here at this particular You said earlier that this wasn't True. What did you mean by that? When we went to Mr. Herring

time.

that you told the fire their jurisdiction?

18
19
:20

marshals A.
Q. A.

21
22j

in Baton

Rouge, he

or my men went to Mr. Herring assured Monroe

in Baton Rouge,

23
24

them that we would be looked office in Monroe, Louisiana.

after by the And they informed

25

me that there was

-- these men informed

me there was

BAIN

& SIMPSON

COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

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

2

--

_.

_ ...-

-----office, I think

177

no Monroe they said.

Q.

office,

no longer

a Monroe

3'
I

So in other words,

if somebody

from Baton in the

4
5 6:

Rouge gate?

had shown up, they could

have walked

A.

Yes, sir.

There

is -- we agreed

to that.

7
8

We gave them two dates, those two dates.

Q.

and they refused

to corne on

9i
I 101

When did you give them two dates? That was at the court. Was that before No. they showed up on June 21st?

A.
Q. A.

11
12:
./

This was after

they filed charges I believe at

13 14 15 16

against

me that I wouldn't I think

let them in.

that meeting, two dates

Q.

I am correct,

that we gave them

to corne. So your statement that New Bethany was not

17
I
I

in their jurisdiction from the Monroe A. Q. were from?

A.

was because

these men were not

1S I

office?

19
20 21

True. Okay. How did you know what office they

22
23

They told me, the best They told you they were The Shreveport The Shreveport office. office.

can remember. from

Q. A. Q. I

24
25

And when did they

L_
BAlN

i
I

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COURT REPORTERS SHREVEPORT, LoUISIANA

& SIMPSON

(318) 429-2160

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MACK W. FORD

7/22/97

-----------1
.

178

tell you that?

A

2
./

During

our conversation.

3 i

Q. didn't

Did you at any time tell them that they have authority jurisdiction?
I

4 5
6,

at New Bethany

Home because

this

was God's A.

could have.

don't

recall

saying

that,

7
8

but I could have. Q. A.

Q.

Sounds

like something

you would

say?

Yes, sir. Okay. And by that you would to inspection mean that the

11

state would

laws with regard

of buildings

12
13'

not apply on the New Bethany MR. HODGE:

I

property? to the form of the that

object

14 15 16 17 18 19

question;

asking

him what he meant by something

I

he could have said.

believe

the witness

testified So we are

he does not recall making kind of speculation have meant little within

those statements. speculation.

What he could have said is a

by something

that he could

farfetched.

20
21 22

BY MR. BERNSTEIN:
Q.

Subject
MR.

to that HODGE: You are free to speculate by something that

23

away as to what you you could have said.

could have meant

r>.

24

THE WITNESS:

Give me the question

.
BAIN

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SIMPSON COURT REPOR11:.RS

SHREVEPORT, LoUISIANA

(318) 429-2160

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1-----1

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179

again. BY MR. BERNSTEIN:

./

Q. 4:

If you said, when

and I think what you said was

that

I asked you if you told the fire marshals have any jurisdiction or words there because

51

that they didn't it was God's

I

6 71

jurisdiction

to that effect,

that you said that you could have. A. I don't recall saying it. As I said, I

8:
9
10
11:

could have said it. Q. Your lawsuit on page 7 in paragraph Fire Marshal
15 says,

"The actions

by the State

and DSS were designed to

12
-'

part of a systematic force the church its operations". are you referring A. came.
I

pattern

of harassment school

'\

13 14 15 16 17
181

home and church

to shut down what actions.

When you say "actions", to there?

The way they come together,

the way they

Q. does

Does that mean the actions in filing

in coming

outi or

19

it mean the actions the orders?

the lawsuits

20
21

obtaining A.
Q.

All of it together. All that together. And what is it that you that makes pattern of

22 23
r<:
241

have seen, heard or been told or believe you think that that is part of a systemic harassment?
I

25
,

-.-------BAIN

& SIMPSON

COURT RF.POR1l!RS

SHREVEPORT, LoUISIANA

(318) 429-2160

MACK W. FORD i

-- 7/22/97
1BO

1 2

A.

We just feel like that they had already up the sentiment of the Sheriff's office, Department,

picked

3:
I

the way the fire marshal's of the fire marshal, then not showing would

the representative and

4 5
6i
I

how he acted with no respect, -- saying that he

up for another

not rest until we were shut down, and then it all, through the time, then they show up against us. you?

7 8

through after

ten years
Q.

and then file charges

What charges

did they file against

10;
11

A. again.

That we report

to them if we ever open what they were asking

That is, in essence,

12
13\

for, the purpose.

Q.

Okay. I don't

That

is not a criminal

charge,

is it?

14 15
,

A.
Q.

reckon. they actually were trying to

In other words, telling

16l

get an order the buildings? A.

you that they could come inspect

17 IB 19!
20

Right.

That

is like if we opened

again,

we

have to notify
Q.

them.

Are you open now? Not in the sense Okay. How about for the school. for the home?

21

A.
Q.

23

A.
Q.

We are taking Okay. With

children. are there today? about

__

24 25
, L-BAIN

How many children the staff children,

A.

seven.

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COURT REPORTERS

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