MACK W.

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

-_._-------

182

1,
I

Home? A. Q. to adopt, Louisiana A. Q. No, sir. Okay. The two children that you are seeking in

2!
3

4
5: 6
7:

are they children or living outside Outside Okay.

that were living of Louisiana?

of Louisiana. Were they children or outside that were living States?

8'

in the United A.

States

of the United

Inside the United Inside the United were

States. States. Do you know where

10
11

Q.

the children A. Q. A.
I
I

from originally?

12
-:

Texas. From Texas? Yes. MR. HODGE: Can we have a short break so I can speak to the

-.

13 14
151

16 17 18 19 20 21

for one second, witness?

just one second

(A discussion Mr. Hodge

was held off the record

between

and the witness) MR. HODGE:

I

spoke

to the witness and there by

to is

ask him questions some confusion mandate record parents

about this adoption,

22
23 24

in his mind between

a custody

and a formal is clear,

legal adoption.

Just so the by mandate. The

he is the custodian the guardians

25

of the child,

of the children
-. (318) 429-2160

--------BAIN

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

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LolJISIANA

I 1: 2i
3~ 41

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

- ... -

-- -----.
that is

191

Okay.

Now, staff children, of staff members?

biological A.
Q.

children True.

How many biological are out there? Five, Okay. I believe.

children

of staff

members A.

Q.

And that leaves

two other

children

to

account A.

for, and what

is their status?

They are my children. They are your children? Yes, sir. them. there are two children at you I am adopting them. I am going

10 11

Q.

A.

12
13

to try to adopt Q.

In other words,

14 15
16

New Bethany

right now that are staying

there while

try to adopt them? A. Ves, sir, until this thing is settled, these

17 18 19

court proceedings

are settled. it is settled,

We are going at least until

to try to it is

keep them until settled.

Q.

And any other children No, sir. So you don't

out there

right

now?

21
221

A. Q.

have any -- other

than children that you are not \

23
24 251

of staff members

and other

than two children

and Ms. Ford are going any other children

to seek to adopt,

there

that are living

at the New Bethany

---_j (318) 429-2160

I
BAIN
._---_.

&

SIMPSON COURT REPORlCRS

SHREVEPORT, LolJlSIANA

------

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

MACK W. FORD
I 1
1

7/22/97
---

--_.

----.

- -_._- - -

.-

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

. __ . ------,

183

involved Reverend

have entrusted Ford.

the care of these children

to

21 3
4 5
I

I am not sure if there are any intentions point extent to permanently there adopt the children. and
I

at this

So to the there by now. to is just the to

is a difference, between

believe

6:

be a difference mandate,
I

adoption

and custody

7 8 9' 10 11 12 13 14 15 ' 16 17 18 ! 19 20 21 22 23 24 25
1

we hope to clear that up on the record the confusion, about and you are welcome this,
I

think

question confusion

the witness

think

there

in terminology. between

He doesn't custody

understand and

legal difference adoption. BY MR. BERNSTEIN: Q. about,

by mandate

The two children Reverend

that we have been talking power of

Ford, do you have a signed parents

attorney

from one of the biological seen today, the form? order.

such as we

have already A.
Q.

This

is a mandate

It is a mandate Yes, sir. Signed

order?

A.

Q.

by the parents

or signed

by --

A.
Q.
A.

Signed by the parents. Signed by the parents?

Yes, sir. It says that they are placing the children

.

Q.
----BAlN

--_.- ~

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

:-

MACK W. FORD -- 7/22/97 --_ .._---_ ... _ .. --------_._.- ------------------...::.....;;",__184 with you? A. Q. By mandate. By mandate. And when you were talking about

1
2i

4 5 6, 7 B
9

adoption, adopt

were you intending

to say that you would be as if they were to share, just from

the children

so they would

your biological

children

and entitled

like your biological you? A. Q. systematic A. Filing school courts;

Q.

children,

in any inheritance

By a mandate

order,

whatever

it consists the

of.

10

What acts do you contend pattern I think of harassment? I have already

constitute

11
12 13 14

answered

that.

the two lawsuits; and bring

one to get me to the high the other one in the

the students,

15 16
17
181

same day, same time. Anything else? Anything to? well, I want -- this is in addition to

MR. HODGE:

what he has already

testified

19

MR. BERNSTEIN: an entirely about different

20
21 22

allegation

than we have talked that what

so far.

So with regard pattern

to the allegation of harassment,

there was a systematic acts does the witness, contend constituted

force

23 24,

the plaintiff

in this lawsuit, of harassment

to

a systematic
the church

pattern

251

deSigned_to

home and_._.~h~rch school

BAIN

&
-

SIMPSON COURT REPoRTERS

...

SHREVEPORT, LoUISIANA

(318) 429-2160

---

-.--

-----

MACK W. FORD

7/22/97

---1

------

- -----

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

185

shut down its operations; list. BY MR.

Q.
1

and I want an inclusive

2: 3
4 5i

BERNSTEIN: So, you have told me the lawsuits, filed by the fire marshal
'96?

the two

lawsuits summer
A.

and DSS in the

67

of

All of the lawsuits,

the order

in 1982 and after

8!
9:

the way they handled that,

that, and then the lawsuit because

I felt it was systematic

the way of the

101 11 12
-'

two lawsuits. Q. So you are talking about the

182

lawsuit

and

the one after that?

i

-"

131

A. Q. 1988 where

Yes, the one in '96. And the one after that would they were seeking be the one in and examine

14 15
1

to interview

161

the children?
i

17

A.

No.

That is from the DSS for this other the two. And then, of course, the '88

18 19
20
I

fire marshal;

by the DSS, and the 1996 by the DSS.

Q.

Okay.

So that would be the fire marshal '96?

in

21
22
I

'82, and DSS in '88 and A.

Q.

Yes. And those are the three acts that are the pattern Yes, sir. of harassment in your mind?

231 24

systematic A.

25

L
BAIN

_
&
SIMPSON

Cousr

REPORTERS

SHREVEPORT,

LoUISIANA

(318) 429-2160

----- -----

---

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

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

._----

186

Q.

Okay.

And your lawsuit

in that same what you had to deliver 84

paragraph 3 4
5

says that you were required, that you were required

told me earlier; students

to the high school,

and that you were

also to

be in state court. couldn't

A.

And you said it was -- you at one time.

6:
7
8

be in two places Right. Okay.

Now, does the New Bethany children? Home have

Q. any means A. Q. A.
Q.

91
10'
I

of transporting

Not that many, no, sir. Okay. Do you have any buses?

11

12
13i

I have one van. Okay. In other words, in 1996 you didn't

14 15
161
i

have any school buses? A.

Q.

No, sir. And didn't buses? We used to. We sold them. have any, I am going to call them

171

Greyhound-type A.
Q.

18 19
20
j I

No, sir.

When did you sell them? It was years before that. about complying with

A.
Q.

21

And what was impossible as alleged

22 23
24

those demands A. getting supposed

by your lawsuit? I didn't have any way of of all, I was

First of all, the children

there.

Second

25

to be in court

that same morning.

BAIN & SIMPSON COURT REPORlCRS

SHREVEPORT, LOUISIANA

(318) 429-2160

MACK W. FORD -- 7/22/97

-_1.

---

__

..

187

Q. A. Q.

Okay. So I couldn't be in two places at one time. to be at

r- ...., 2
3,

Now, were you personally High School? Well,

required

4
5,

Arcadia
A.

I am the one that is the pastor to do it.

you

of the

6 7

church.
Q.

I felt like I was required

Felt like the Court was requiring to take the children to Arcadia

8~ 9
10
III

personally School? A. whether

Q.

High

I am not the one to make they do or they don't.

that decision

12 13 14 15

But how is that impossible at one time? If I was in court, to the high school. them. What attempt did you make

for you to be in

two places
A.

I couldn't I didn't

deliver

the

children deliver Q.
A.

have a way to

16
17 18 19
20
!

to resolve

that?

I went to court. Okay. I mean before you went to court.

Q.
A.

It was impossible

for me to do it, so it I decided we better

21

wasn't

no need for me to do it. Why would

22 23!
24 25

go to court. time?

they do that all at the same

Why didn't

one of them do it one day, and one

the next?

We could have been at both places.

Q .
I.

D i dy__ o_u __o_r_a_n_Y_b_O_d_Y_O_n_y_o_u_r __b_e_h_a_l_f._a_t_t_e_m_p_t

SHREVEPORT, LoUISIANA

RAIN

&

SIMPSON COURT REPORTERS

(318) 429-2160

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

188

contact

either

DSS or the fire marshal

to say, look, let's do

2
3;

we can't be in two places

at the same time;

one today and one tomorrow? A. Best I can remember, to respond we didn't have time to

5
6'

do nothing, Q. required School A. Q. paper

,

to anything. -- okay. The order to Arcadia it? High

When did you get that you deliver

I

7
8
9!

the students believe,

in the morning,
I

didn't

can't

remember. How long did you have that piece of

10

Okay.

11 121
13 14 IS' 16 17 18 19
20

ordering A.

you to deliver
I

the students? Mr. Bernstein. remember.

Again,

can't remember,
I

There was so many papers, Q.

couldn't

How long had you known

that you were going suit before the

to be in court on the fire marshal's day of court? A. Q.

I

can't

remember

that. "The harassment by DSS

Paragraph

16 says,

and the State Fire Marshal aforethought retribution

was made with malice at plaintiffs beliefs". in What is it you

and was directed

21 22 23
24

for their religious

that you have seen, heard or been told that makes think that a State employee aforethought? malice Stop. acted with malice

Do you know what that means,

25

aforethought?
_J

L--______________________________________ _
BAIN

& SIMPSON

COURT REPORTERS

SHREVEPORT, loUISIANA

(318) 429-2160

..

11--"
r>

MACK W. FORD

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

189 ----=-:....;

A. Q.

Explain Okay.

it to me. Well, I didn't pick those words, so I

2'
/

don't them.
I

know what

is meant,

what you choose

to mean by your I

4 5: 6 7

I want to find out, you know, may want to tell you what ill will. that. means

and perhaps

lawyer

that is.

Malice,

take to mean, A.
Q.

I believe

81
9

And aforethought

thought

out

beforehand? A.
Q.

10 11 12i
,-r- "
./

I bel ieve that. So, can we agree I believe Okay. that.

1S

on that definition?

A.
Q.

13 14 15 16 17 18 19 ' 20 21, 22 23

So what

it that you saw, heard

or

been told that makes with

you think

that a State employee did

ill will and ahead of time, aforethought,

that harassment? A. When they came and I wouldn't let them in,

they went back to the courthouse believing, out before

Q. A.

to get the order made

I believe,

that the order was already

they ever came out there. Okay. Because And why do you believe of the time element. that? It didn't take

them long to get that order.

Q. order?

,/

"\

24

And that is refering

to DSS getting

the

25L

RAIN

&

SIMPSON COURT REPORTERS

SHREVEPORT,

LoUISIANA

(318) 429-2160

----

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

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

-- 7/22/97

---,
190

11 I

A. Q.

Yes. Okay. Now, let's see. DSS had an order

2 I
3 4

when they came out the first time that morning? A.

I

can't

remember but
I

about can't

that.

It seems

like

51

there was paperwork,

remember.

It seemed

61
7

like it was the names on the listing, in. Q. When did you determine

but not to come

that a State employee

9
101
11:

had acted with ill will beforehand?

A.

Because

there

is no way

in the world

--

Q. believe

My question

is when.

When did you come to was acting with ill will

12
/" ,

that a State employee

13

beforehand? A.
Q.

14
15

When they drove Okay.

up so close

together.

And it was the fact that the fire later DSS came that was ahead

16 17 18
191

marshals

came and then 30 minutes as meaning

you interpreted with

that a State employee planning you? or acting

ill will or maliciously

of time to do something
A.

to harass

20 21

Yes, sir, because

we were running were very

our camp

meeting,
Q.

and the time elements And what is it

important. or

22
231 24

that you have seen, heard that makes

been told or whatever

you believe

you think for your

that this was directed religious beliefs?

at you in retribution

25

BAiN

& SIMPSON

COURT REPORlCRS

SHREVEPORT, LoUISIANA

(318) 429-2160

----

------

ll-~~
._--

MACK W. FORD

7/22/97
..

_-_

....

--------

191 has happened. the have

In the past ways how episodes that -- we believe

21

They believe church

in separating

and state.

We also believe permission

that we donlt

4 5 6 7: 8! 9
10 11 12
I

to have permits, tribute

from the State;

we pay

only to God our Father,

and the news had come that they that we care of

to us before didnlt

that we were too religious; that we were

believe

-- they believed capable of taking

were a cult and we werenlt the children. Q. A. Q. A. out there. Q. A. contacted Okay. Anyone Okay. Again,

Who is "they"? I canlt remember the names.

Who told you that? Well, Judge Taylor said it was too religious

13

14
15

else?

The parents

that said that they had of those of runaways, believe they

the DSS workers

18 19 20
I

were told that they didn't that we were too strict, didnlt believe

what we were doing; and they

too religious,

in the discipline;

that it was nothing

21
22

but a prison. Q. action What is it that makes you believe that any

23
24

taken by a State employee religious Simply beliefs?

was in retribution

for your A.
1
I

25

saying

it was too religious.

BAIN

& SIMPSON
..

COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

_- ._------

-----

--.

MACK W. FORD
------

7/22/97 192

Q.

Who said that? Mr. Taylor, for one.

2
3' 4'

A.
Q.

Judge Taylor? Yes, sir. Any other

I

A. Q. A. !

5
6 7

individual

that you can identify? but it came

can't

identify

the individual, Services.

from the Department

Q.

of Social

8
9

Can you identify

I

in any way who it was that said it, They said it

A. because

can't

identify

10 11 i
12
/

they didn't

say who said it.

came from the Departrment.

Q.

How did you learn of that? From the parents. And how did the parents By contacting learn of that? of Social

'

13 14 15

A.
Q.

A. Services. Q. contacted

the Department

16
17

And when has a parent the Department

told you that they Services and were

18 19
20 21 22 23 24 25
L__ __

of Social

told what you have just told me? A.

Q. In '88.

Any other And in the

time? '90s. in the '90s?

A.
Q.

How often did that happen Twice. Okay.

A. Q.

When was the first time?

.._. __ _

_J
(318) 429-2160

BAIN

&

SIMPSON COURT REPoR'ffiRS

SHREVF.PORT.

LoUISIANA

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

-------

MACK W. FORD

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

-----

193

A.
r>.

The first time was with a little The second

boy from

North

Carolina.

time was with John Potts, Texas. the little boy

I believe,
4

from Childress,

Q.

And any way you can identify

5
6

from North Carolina? A.

Q.

No, sir. Is there any record that you could refer to

7 8 9
10 11

that would North

inform you as to who the little is?

boy from

Carolina A.
Q.

I thought

that was all confidential. you for the name; I am just

I am not asking

12
13 14 15

saying

is there a way that you could

find out the

boy's name? A. Q. name? A. Carolina.

Q.
I

I could

find out the boy's name. you go about finding out the boy's

How would

16
17

Probably

calling

the pastor

in North

18 19
j

Okay.

And how would you know which

pastor

20
21

to call? A.
Q.

The church

used to support

us. of a

22 23
24
25

And you know that that boy was a child of that congregation? They knew of that child. What?

member A.
Q.

I
BAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA
__

(318) 429-2160

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

._-.

--------_.

- _.--

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

Q. 3!
4 5 6

194 _--_

They knew of the child. They knew of the child? Yes, sir. Any others? No, sir. Okay. How many parents in
18B

A.
Q.

A.
Q.

told you

that

7
8

they had been told that? A. remember. Q. directly?

I

couldnlt

say to that.

donlt

really

9 10 11 12 13 14 15 16 17

How many do you recall

telling

you that

A.
Q.

By phone? Or face to face or by letter. Probably Okay. four or five. that you have staff member call and us?
I

A.
Q.

Are there any others

heard

about,

any other

times when another

I have

came to you and said,

had a parent things

IB
19 20

tell me that DSS is saying A. Q. My wife.

these

about

And how many times has she told you, or how has she told you called her and told her

21 22 23
24

many parents that? A. several. Q.

Several.

I donlt know the exact

number;

25
1

Several;

is that less than ten?

~------------------------------RAIN & SIMPSON COURT REPoRnRS SHREVEPORT, LoUISIANA

_----

(318) 429-2160

----

---_.-

MACK W. FORD -- 7/22/97

195

A. Q.
3 4

Probably Would

less than ten.

it be less than five? be more than five. also says in paragraph 16 that in

A. Q.

No, it would The lawsuit

5
61
I

liThe harassment

by DSS and the State

Fire Marshal and was action for

part was made with malice

..

aforethought

7
8
I
I

directed exercising courts Ford,

at plaintiffs

as a punitive

the Constitutinal lawsuits

right of access between

to the Pastor

9! 10 11 12
13

in the prior the church, What is

the State,

the church

home and the church seen, heard or been

school".

it that you have

told or believe employee church, punitive

that makes

you think action

that a State against you, your

has taken a punitive

14 IS' 16
17
18 i

your church home or church action for exercising to the courts?

school

as a

your Constitutional

right of access A.

Because

when they took the children, called

I took

them to court. coming, Q. A. called,

My lawyer

and asked about a closed meeting.

19
20.

and they said it is closed,

And who made that decision? The lawyer made and I guess Okay. that decision. Judge The lawyer

21

22
I

he called

Butler. Butler's decision?

231

Q. A. Q.

So that was Judge

24

I think that was Judge Butler's And what is the connection

decision. Judge

25

between

L.
BAIN

_
& SIMPSON

---------------------.---SHREVEPORT. LoUISIANA

COURT REPoRTERS

(318) 4292160

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

./""'\

..

_--

196

Butler, A.

DSS and the State Fire Marshal? I don't know what the connection is, but I has

2i 3 4

know that, as I said before, always

that Judge Butler

give them right of way into the home to do they want to do. been because And we feel like in times of probable cause.
I

5;
6

whatever

past it hasn't donlt signed

Q.

7 8
9

think he has ever looked it.

at the order

when he

And why do you believe Because

that? written. I don't

10 11 12 13

A.

it is just things

see how a judge can give an order without what they can do and what they can't do. MR. HODGE: record. (A discussion BY MR. BERNSTEIN: Q. currently
1

specifying

Excuse

me.

Off the

14 15 16
17

was held off the record)

With regard

to the two children

that are

18
19

there that have been placed are you aware of whether Compact on Placement

with you by

mandate,

or not the Agency has

20
21 22

Interstate cleared A. Interstate

Q.

of Children

those children

to be placed

with you? with

We have never had no dealings Compact. Okay. MR. BERNSTEIN: With

23
24

25

that, we will

RAIN

&

SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

---_.

__

..

_-

MACK W. FORD -- 1/22/97

197

l~:::ess
.

to be resumed either by notice or agreement

of

2i
./

counsel. MR. HODGE: Yes. was excused, date at and the

4
I
I I

(At this time the witness deposition

4:25 p.m.)

5;
6 7 8 91

was continued

to a future

10 11 12 13 14 15 16 17 18 19
I

MACK W. FORD

SUBSCRIBED the

TO AND SWORN TO before day of

me on this
, 1997.

201 21 22
23 24 25

NOTARY

PUBLIC

RAIN

&

SIMPSON COURT REPoRlCRS

SHREVEPORT, LoUISIANA

(318) 429-2160

--------.

MACK W. FORD -- 7/22/97

1i
2
3
4:
I

198 ,-------------------------------~-------------------------------~~
I

C E R T I F I CAT

STATE OF LOUISIANA: PARISH OF CADDO:

5~ 6 I,

Paula D. Tieger, came before

do hereby

certify

that the set

7
8

said witness forth herein, examined

me at the time and place first duly sworn,

and after being

was

9
10

and testified

as shown;

that the deposition transcribed record under of the my

was reported supervision testimony

I

by me and thereafter

11 12
13 14

and is a true and correct given by the witness. certify that

by
I

further

am not of counselor to this thereof.

related

to or employed

any of the parties in the events

....

j. .7

15
16

cause or in any way interested SUBSCRIBED July,

1997.

AND SWORN TO this the 28th day of

17
18 19 20

21
22 23
24

PAULA D. TIEGER, CERTIFIED

RPR

COURT REPORTER

25

BAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 429~2160

_..

..

------

-.-

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