Beruflich Dokumente
Kultur Dokumente
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._._--1
THELMA
\
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{
'
FORD
7/21/97
._.)
1 2 3 4 5 6
UNITED WESTERN
STATES DISTRICT
DISTRICT
COURT
OF LOUISIANA DIVISION
SHREVEPORT
..
NEW FOR
I
7 VERSUS
8
...... * * * *
CIVIL JUDGE:
ACTION DONALD
NO.
96-2065
* *
9
10
STATE OF LOUISIANA, ET AL
MAGISTRATE
JUDGE:
11
.~-.j
..... _,/
12
13 14
15 16 17
18
19
t
t.
20
21 22
23
DEPOSITION
24
25
CCR
L_
BAIN
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SUREVEPORT, LoUISIANA
(3lH) 429-2160
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!THELMA
r:
-,
.I
FORD
7/21/97
1 2 3
4
MR. JOHN S. HODGE - Davidson, Nix & Jones 509 Market Street, Suite 800 Shreveport, Louisiana 71101 COUNSEL FOR PLAINTIFFS:
6 7
8 9
MR. BILLY REX HARPER, JR. 113 North Myrtle Street Arcadia, Louisiana 71001-3414 COUNSEL FOR DEFENDANTS, LOUISIANA DEPARTMENT OF JUSTICE: MR. HENRY M. BERNSTEIN Assistant Attorney General 330 Marshall Street, Suite 777 Shreveport, Louisiana 71101 COUNSEL FOR DEFENDANT, OFFICE OF THE STATE FIRE MARSHAL:
10 11
r" "-
12 13 14 15 16 17
18
MR. WAYNE R. CROUCH Department of Public Safety P.O. Box 66614 Baton Rouge, Louisiana 708960 COUNSEL FOR DEFENDANT, DEPARTMENT OF SOCIAL SERVICES: MR. ANTHONY CARUSO Bureau of General Counsel for Department of Social Services P.O. Box 1887 Baton Rouge, Louisiana 70820 Also present: Reverend Mack Ford Brenda Kelley Topper Johnson Denise Fair Vicky Haynes JameS Myers Glen Flesher
19 20 21 22 23
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24 25
....
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BAIN
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---SHREVEPORT, LoUISIANA
&
(3IR) 4292160
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THELMA
FORD
7/21/97 3
'-
./
S TIP
U L A T ION
2
3
of Thelma Mr.
Ford,
taken
by pursuant for
4 5 6 7 8
9
Henry
Bernstein,
counsel, Rules of
purposes
by Kay A. Moore,
Certified
10 11 12
13
counsel
the exception
of the swearing
14 15 16 17 18 19
20
of the deposition
is waived
by counsel
except
as to the
responsiveness of trial.
of the answer,
21
22
23
24
,,-.-
25
I
I
____ J
RAIN
&
SHREVEPORT, LOUISIANA
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1'-
~THELMA
FORD
7/21/97
4
,/
I ~ D E X
;
2 3 4 5 6
I Examinati~n
7
8 9
Exhibit
Description
Page
1
2 3 4
Portion
of intake portion
10 11 12
/
for school
13 14 15 16 17 18 19 20 21 22 23
5
6 7 8 9
schedule number
telephone
10 11
Affidavit
(All exhibits
retained
by Counsel)
f\.
'""./
24 25
L _.
BAIN
._.-._
&
SIMPSON COURT REPORTERS SHREVEPORT. LoUISIANA
._. __ ._~..-....:.. _ __ .~_:_.
(31B) 429-2160
~ _ !:'"_
~:t3P:'r.'_
THELMA
FORD
7/21/97
5
2
3
sworn,
testified
as follows: EXAMINATION
4 5
6
BY MR.
BERNSTEIN: Q. Mrs. Ford, as you know, lawyers I'm Henry for the bit of ever State,
7
8
9
of the
want
preliminary given
discussion
Have
you
10
a deposition A.
Q.
before?
11
f '\
./
12
13
though? A.
Q.
14 15
16 17 18 19
20
session,
you
questions
to which
Yes. One of the things a good that will help and out loud
21 22 23
24
/
you're because
doing
reporter so if you
as a back tape
recorder have
--_
...
picks
it up because picking
---.---
typically and
-----
25
recorders
---_.
BAIN
trouble
up nods
shakes
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REpORTERS
SHREVEPORT, LoUISIANA
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!
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_._-_
FORD
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7/21/97
the head A. Q.
and
things
like
that.
2
3 4
I something
something confusing
A.
or no. that,
Okay because
5
6
at times. Okay. And you I'm having may need to speak trouble up a little hearing you bit
1,
7
8
9 10
a little
there's
an air
conditioning a question
11 12
13
14
above you
that
don't
think
has
double
meaning just
if you'll
I'll
15 16
it or ask
it another
way.
So can we
agreement Yes. -- that Yes. And about then the last thing I wa~t such to check an if
I
17
18
do that,
you'll
tell
me?
19
20
A. Q. with you
21 22 23 24 25
is there
any reason
as either of me
sort
that
understand that
I'm asking
things
-... _--BAIN
have
happened
--.
in the past
me
----_.-
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SHREVEPORT, LoUISIANA
& SIMPSON
COURT REpORTERS
(318) 4292160
THELMA
FORD
7/21/97 7
1 2
3
answers? A. Q. No.
...
4 5
6
7
In
other
words, your
you're
not
on or
any your
sort mind
of or
clouds
thinking
that?
start For
9 10 11 12
/
would an
you
your
please, Ford at
'\
13 14
Ford? A. Q. A. Q.
A.
15 16 17 18
19 20
29,
1932.
were
born
where?
In Jonesboro, And Yes. Would is? Through Okay. I am and a pastor's it. the you you grew
Q. education A.
I
I
briefly
tell
me
what
your
21 22 23 24 25 [
I
II
eleventh
grade.
Q. A. mo_ther,
wife,
a housewife,
that's
---_._
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(31 R)
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&
SUREVEPORT,LoUISIANA
429-2160
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Q.
My next and
question
you've
ever
2 3
4 5 6
worked, formally A.
Q.
I gather
from what
answered,
not
in a job setting? I do not have Okay. What a job. I have a calling. your calling?
do you
consider
A. people.
Q.
My calling
is to minister
to young
7
8
And
just
sake, job?
you've
not
9
10 11
held
what A.
Q.
call
also
just that
bit
more
about you
12
I' -.
married -- married
because
13 14 15
16
to Reverend
Is this A.
Q.
marriage?
17
18
married? A. Q. A.
Q.
In Jonesboro, Was
No.
Louisiana
1n 1949. point?
19
20
he a minister
at that
21
22
What
was he doing
in 1949? here in
A. Shreveport.
Q.
Working
at B. F. Goodrich
23 24 25
I
And
where
Ford,
at that
time,
set up housekeeping?
---SHREVEPORT, LOUISIANA
Il. __
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BAIN & SIMI'SON COURT REpORTERS
--.---
(318) 4292160
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7/21/97
'''-'l
II
,
I
A.
Q.
in Shreveport. long did you-all me five What live years in Shreveport or ten years.
2 3 4 5 6 7 8 9
roughly? A.
Q.
can tell
' 63 .
'49 to That's
good And
need.
'49 to'63.
time,
you
were
housewife
A. Q.
and mother? Correct. And during No. And did he work at B. F. Goodrich that he worked that secular jobs? He .w a s not a
10 11
/,
minister A.
Q.
time?
.....
-;
12 13 14 15
entire
time? A.
Q.
16 17
18
A. then
God called
to go into Q. And
Shreveport
at that
19
20 21 22 23
point?
A. Q.
A.
Q.
24
\
missionary? A. Yes.
25
i_..
BAIN
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&
SIMPSON COURT REPORTERS
..
SHREVEPORT, LoUISIANA
_ ... ----
_
(318) 429-2160
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!THELMA
FORD
7/21/97 10
how
long
were
you
in
Australia?
2 3
4
5
When Home My
we
we
started
the
work
at
For
7
8 9 10
11
missionaries
is
that
a religious
de~omination.
A.
Q. denomination A.
they
are
missions
for.
What
12 13
14
Q.
opened the
Bethany
Home
15 16 17
18
A.
Q. returned in
Correct. At from the time that was you the and New Reverend Bethany Ford Church
Australia,
19 20 21
22 23
pastor
started
a church?
where
did
you
all
start
the
New
24 25
Bethany
For
A.
Highway
------BAIN
---------------SHREVEPORT, LoUISIANA
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(318) 429-2160
_THELMA
/"
,
FORD
7/21/97 11
Q.
you describe
the New
Home
For
for troubled
3
4 5
6
7
children
or generically, how
trying
to explain
Bethany,
do you
it to people? For troubled Do you call Home. In other words, you would describe it as youth, teenagers. home, school?
it a center,
8 9
10 11
like
a home
A. Q.
youths,
teenagers?
"
12
,
started have
the New
Bethany
Home
For
13
Girls
A.
which
,70.
been
in about
19707
14
IS
16 17
18
Q. only home
been
associated
A.
19 20 21 22 23 24
/
Q. Highway A.
Q.
would
be the one
located
on
9 in Arcadia? Correct. When did you the New have Bethany Home For Girls was in
any role
of doing
anything,
or at that
"
25 a housewife and mother?
_
SHREVEPORT, LoUISIANA
-----'
BAIN
&
(3IR) 429-2160
.,.'"''
1
I was children. So in in
-- both
of
us
lived
2n
the
dorm
2
3
other
words,
you
were
actively
4
5
Horne itself?
was was
not not
that
your
7
8 9
husband's
your And
10 11 12 13 14 15 16 17 18
19
know
incorporated?
remember don't.
when
that
was?
participated you?
in
the
didn't
you
an
officer
or
director
of
that
20 21 22 23 24 25
L-
I was
the
Q.
Bethany who Home else For A.
In
the
initial Girls,
and
your
involved
the
New
Bethany
had
a mothering
church.
----.
BAJN
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&
SUREVEPORT, LoUISIANA
. -
(31R) 429-2160
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THELMA
FORD
7/21/97
13
r-.
1
Q.
A.
church?
2 3 4
5
Q.
A. ITexas.
, Q.
church Baptist
was
that? in Henderson,
Church
6
7
West
Main?'"
A.
Uh-huh. And Could West you you Main said they were that Church a mothering relationship and New Bethany
8 9
Q.
church. between Home For A. Q. ministry? A.
describe Baptist
10
11
12
13
can't. for
No. your
the
mother
church
14 15
16
Q.
ministry that be A. Q. West Main A.
17 18 19
20
the
West
Baptist
Would
at
that
time
was
the
pastor
of
21 22
23
Q.
creation A.
24 25
the
Bethany remember.
For
Girls?
can't
_- .._
BAIN
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LOUISIANA
(3IR) 4292160
-- .. -.-_
'THELMA
r>.
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..._
14
-'-'1 I
FORD
7/21/97
1 2
3
Q.
anybody creation Girls,
to was
check
out,
see In
if
terms
Bethany
4 5 6
7 8
was A. Q.
A.
Lester
Roloff
involved?
know
who
Reverend
Roloff
is?
Q. Reverend troubled
A.
you had
with
the
that to
9 10 11 12
/
Christi that
Are
aware
Q. Christi?
A.
home
for
troubled
youth
in
Corpus
"
13 14 15 16 17
18
Q. your
ministry A. Q. No.
that
Reverend
What
did
you
see
between
19 20 21 22 23 24 25
yours
and A.
I would
know
of
is
the
food.
Q.
A. Q. teachings,
is
that?
Biblical Bethany
precepts would
or follow
believe
New
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BAIN
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(318) 429-2160
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THELMA
- . ---FORD 7/21/97
...
15
1
2 3 4
the
same
basic
Biblical
teachings
as Reverend
established her
5
6 7 8 9
to describe
that not
to identify
say that;
if she
she
describe
MR. Q. the basic Troubled A. Q. participate just way New in the with (By Mr. precepts Youth No.
10
11 12
Roloff's
or Ministry?
13 14 15 16
17
did Reverend
at any
-- participate
in any
or helping
or assisting
18
19 20 21 22 23
Bethany A.
Q.
Reverend heard
W. N. Otwell of him?
from
Texas?
A.
Q.
A.
know
who
he is?
./-
24
25
Q.
been
involved
with
L.
_ ...
--------------BAIN
...
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SflREVEPORT, LoUISIANA
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THELMA FORD 7/21/97
16
---,
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r
I I
New
Bethany A. Q. A. Q.
For
Girls?
2 3 4
what
was
his
role?
Staff. He was on the staff. W. N. And Otwell Girls? could was you on give
5 6 7
8 9 10
11
me
roughly of A.
when New
Reverend Home
the
staff
Bethany
For
No. Do of you this know type, if your that than husband is a home has for ever had
Q.
a ministry youths, A. Q. A. Louisiana.
troubled
other
Arcadia,
Louisiana?
12 13
where
was
14 15 16 17
18 19 20 21 22
South
Carolina,
Q.
there? A. Q. A. Q. New Bethany? A. Q. A.
._- -_.
RAIN
And
where
in
South
Carolina
was
the
home
Walterboro, When
I
was
cannot it
Would
after
23
r>. . 24
Oh,
yes.
In Arcadia? Yes.
'
25
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SHREVEPORT, LoUISIANA
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THELMA
FORD
Q. A. Q.
And
then
where
in Alabama?
2
3
4
5
6 7
Walterboro? A.
Q.
Yes. Were you ever Short And No. And in Alabama, or was recall. you said here in Louisiana. a home Do in Opelika, there another was it also your trips there just short visits,
'1 1
or were A.
Q.
there?
8 9
how
in Opelika?
10
11
12 13
Bethany,
I
name?
don't then
14
15 16
And
if your
husband other
for troubled
youths
any place
A.
Arcadia?
17 18 19
20 21
Longstreet. Longstreet. or girls? Boys. And did Yes. And did you function on the staff? For Were Boys in it go under the New Bethany name? And was Longstreet a home
Q. for boys
A.
Q. A.
Q.
22
23
24
25
I you
1__ .
on the staff
Home
) Longstreet?
--BAIN
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SHREVEPORT, LOUISIANA
(318) 429-2160
',-,---,
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THELMA
FORD
7/21/97
18
A.
Q.
No. So you have the question. you have been on the about your staff 1970, calling -- I'll the only to Bethany
2
3
rephrase place
Since
4
5
6 7 8 9 10
that
fulfilled youths
minister Home
to troubled
the New
For Girls A.
Q.
in Arcadia,
Yes. Have youths Home you ever heard City, of a home Missouri for called the
troubled Rebecca A. Q.
I
in Kansas
For Girls?
11
12 13
14 15
For
Girls? A.
Q.
16 17
18
19
point been
the Rebecca
For Girls
Bethany
Home
For Girls?
Not But
it could
happened?
20 21 22
23 24
you're have
a memory have
it, so I but
my question
It could saying
happened have
don't you
----,
it could
happened,
.~-
25
don't
,-
._--BAIN
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,
SIIREVEPORT,
LOlJISIANA
(318) 429-2160
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~HEL~~-'
I
FORD
7/21/97 19
I
1
No, Okay.
none In
from
Rebecca
Home.
2 3
4
Corpus
Christi?
Right. NOw, the my understanding Home youths that City, For is Girls moved that in at some
5
6 7 8 9
closed, Missouri,
were was
there
in was
Kansas closed,
Missouri. of
a number
10 11 12
13
Bethany? Yes. And so That's those the correct. girls were Home transferred For Girls in to
New
Bethany City, A. Q. A.
from
Rebecca
14 15
16
Kansas
Missouri? Excuse Sure. But they with were them. staff no part of just us. used
I
me.
May
clear
that
up?
17
18
We had
one of the know
to
do
19 20 21
22 23
them.
don't
words,
they
just
simply were
took a tenant
the
buildings.
Basically,
24
25
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RAIN
&
SHREVF.PORT, LoUISIANA
(31 S) 429-2160
I THELMA
{
FO-;D-
7/21/97 20
.. -,
1 2
have other
you
had
at
the
New
Bethany
Home
For me
words, in the
you so
been
-- you you
told would
3
4 5
6
that how
you would A. Q.
lived you
I guess, Dorm
describe
mother?
Supervisor. Supervisor. what words, else are Okay. have in the you Besides done of at being New a Bethany?
7 8
9
you with
charge
the
10
11
kind
things I'm
looking
bookkeeper. I oversee
answerer --
of
12
13
everything
kitchen,
14 15
16
sounds Home
S1r.
to For No.
~e
like
you're
in
charge
of
Girls?
17 18 19 20 21 22 23 24 25
is
in
charge
of
the
New
Bethany
Home
Mack
over final
I'm
everything
sense
kitchen,
dormitory,
school?
BAIN
&
SHREVEPORT, LOUISIANA
(318) 429-2160
___-1
THELMA FORD 7/21/97 21
1
A. Q.
3
4
set of books? A.
Q.
6 7
8 9
income
received A.
Q.
Yes, Who
is your
A.
Q.
10
is she?
11 12
13
A.
Q.
Robinson at New
keep
books, words,
Bethany?
14
15 16
17
18
I don't
my question
19
20
books,
are they
at Arcadia,
or are that
books track
21 22
23
24
of your
expenses
as
25
bookkeeper,
-._- --_
RAIN
r assume
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you're
familiar
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SHREVEPORT, LOlJlSIANA
(J 18) 429-2160
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THELMA
(
FORD
7/21/97
----_ ...-, i
-"
1
financial Is that A.
Q.
on of New
Bethany
Home
For Girls.
2
3 4
are
the sources
of support
for
5
6
New
Bethany A.
Q.
Churches, So churches
7
8
9
individuals
donations? A.
Q.
Yes. When you say ~individuals, or are ~ are these these families
10 11
simply
interested that
individuals,
12
13 14
15
of youths A.
Q.
are there? -- didn't you said say understand. "individuals," "individuals," that are and my
Sorry Well,
1S:
question talking
When
you
are you in
16
about
simply
people
interested talking
17
18 19
supporting families A.
your
or are you
about
of youths Yes.
or both?
interested.
20
Q.
A. tuition
Q.
21 22
23 24 25
donations
A.
Q.
$350.
$350
per?
-------- ----BAIN
&
SlIREVEPORT,
LoUISIA.'\jA
(318) 429-2160
23
A. Q. A.
Child. For Yes. MR. HODGE: Over what period of time the entire child's stay?
2 3 4
5
6
7
are
we
referring A. Q. One
what per
was child
trying per A.
9 10
11
between
12
/
A.
Per
her
mind.
Q.
A. Q. for
one
year. is
$350
tuition
per
child?
A.
Q.
(Nods And
head
when
you
A. Q. in terms of
School. And is school New a part of what For you're over Are
.: - '\
24
25
that
Bethany
Home
Girls?
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BAIN
&
SHREVEPORT, LoUISIANA
(31R) 429-2160
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THELMA
FORD
7/21/97 24
"
1
you
over A.
Q.
as well?
2 3
4
say
you
describe
Is it a private or
or is it a
5
6
school, A.
school.
Accelerated
7 8 9 10 11
Christian
Q.
~accelerated
Christian
for me? It's a pace level program where each child He does not
in his own
time. has
, ..-. ".
12
13 14
He only
assistance
he needs
Q.
15 16 17
18
there's teaching
A. Q.
setting class
with
at one
is this or
1S
a program
that
you
19 20 21 22 23 24
.' ">,
husband furnished A.
Q. A.
that else?
it from
someone
else.
Garland,
Q.
25
You
said
that
each
. J
BAIN
&
SUREVEPORT,
LOUISIANA
,.__
.-
-- .------------" _------1
FORD 7/21/97 25
THELMA
1
2
child help
works asks
at for
own Who
pace, is
and
then to
if
he
needs
there
assist
the
3
4
children A. monitors. Q. A.
with We
5
6
Currently, Currently, And at the That's I'll Let regard Okay. When at New
' 96.
who we
is don't
the
7
8
have there
Q.
children A. Q. supervisor? frame with A. Q. children A. Q. A. Q. have
is
that
because
9 10 11
the
"
12 13 14 15 16 17 18 19 20 21 22 23 24 25
1
let's
that.
is
the
last Home
time For
that Girls
you
had
Bethany
roughly?
of
'96 . '96 .
'96?
Fall
of
'96?
And
this so to
is
so
I
that ask
we a
a frame
reference clear as
then when
you about.
question, So in June
we're of
asking in
'96,
who
was
the
supervisor
the
school? A.
_
JoAnn
Madden.
BAIN
&
SHREVEPORT, LolJlSIANA
(31&) 429-2HiO
~THELMA
FORD
------------7/21/97
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1 2 3 4 5 6
Q.
indicated
that
there in June
were of '96?
monitors.
A. Q.
the monitors
Chen. you spell And her last April name for me?
A.
Q.
Miss
more
than
those
7
8 9
A. tutor.
Q. A. Q.
I'm sorry.
I can't
remember.
I have
10
11
/ --,
Robert
So roughly
12
13 14 15 16
before have
then,
the people
involved JoAnn
in the Madden;
been
monitors, then,
April
Russell;
the tutor A.
Q.
Brown?
17 18 19
20
or anything? A.
Q.
21
22
23
with
New A.
Q.
Bethany? Two of them And which JoAnn How are. those? Robert Brown. Russell?
24 25
A.
Q.
Madden. Miss
about
Chen
and April
L
BAIN
_
&
SIMPSON COURT REPORITRS SHREVEPORT, LoUISIANA
(318) 429-2160
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.. _--
--
..
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THELMA
FORD
-I
27
7/21/97
I I
!
Do you
know A. Q. A.
where They're
they
are now?
2
3 4 5
Russell
College
Chen's
in college
6
7 8 9
In California,
Q.
And
per
month A. Q.
cover?
10 11
/
-,
What
does A. Q.
12 13 14
were
compensated or monitors?
IS
16 17 18 19 20 21
tutor,
all reflected
on the books
of
Bethany A.
Q.
Home Yes.
For Girls?
sake, Home
understand
that
there's Is that
A. Q.
For Boys
in Arcadia.
22 23
24
25
Church.
----BAlN
Is that
--------
correct?
-_. - ._-----_.
SIIREVEPORT, LOlJlSIANA
&
(318) 429-2160
..
~.---
--_._._.-
-------FORD 7/21/97 28
THELMA
1 2
A.
Yes. Is there For a separate Girls, of for all like trying for New -or are set is of the books New for Bethany for that the
Q.
New Home Bethany For of
3 4
5
6
Home
Girls the or it
records Boys
either one
Horne or Did
I
church, that
I
of
books?
-!
7
8 9
--
sounded I'm
to you its
I
!
guess set
one
books is of there
Bethany of
Church for
10 11 12 13 14 15 16 17 18 19 20 21 22
23
one for
set the
books
Boys
Home,
one
the
don't keep,
The
books Girls
you
the
Home?
it
record
expenses
for
the
Boys
Home? A. Q. church as A. Yes. And well? Yes. All of it is under And just is the church. a separate of the docs it record the expenses of the
Q.
1
there expenses
24 25
set Girls
of
books Home?
the
.-~-----.-------~-BAJN
--_.---SHREVEPORT, LOUISIANA
._--
&
(318) 429-2160
THELMA
FORD
7/21/97 29
A.
No.
words, paid
in the out
3 4 5 6 7
8 9
were
of, that
an expense
an expense
Home, or are
expense checking
A. Q.
separate
homes?
is a checking
10
11
Girls
Home? A.
Q. A. Q. A. Q.
12 13 14
15
Uh-huh. And Yes. Yes. Don't I know nothing Okay. a checking Yes. As Mr. shake you Hodge reminded you -account for the church?
16
17
18
A.
Q.
19 20 21 22 23 24
25
to rattle
a separate a separate
and a separate
do you
have
anything --_._-_
..
to do with
_._-_.
the
-
--------
-_ ..
,
--_._)
&
SHREVEPORT, LoUISIANA
(31 H) 429-2160
------
------
-----_
.. _--_.
--_
THELMA
FORD
7/21/97
30
checking Do you
account do all
for
the Boys
Home
or the
church?
2
3 4
the checking
accounts?
A. Q.
Yes. And you reconcile and the bank things like statements this, and
5 6
balance Ms.
or does
Robinson A.
Q.
7
8 9 10
does
words,
you
A.
Q.
care
of that
for you.
11 12
13
The
people
school, Russell,
14
15
for girls,
they
teach
-- teach
is a bad word.
Let me rephrase
16 17
18
that.
A. Q.
words,
were
they
the and
19
20
monitors,
A.
tutor
for both
the boys
21
22
Q.
A. Q.
23 r>.
24
A. supervisor.
---,------
Besides
Mr.
Brown.
He
is the boys
25
BAIN
&
SUREVEPORT, LOVISIA.\JA
(31 H) 429-2100
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