-

-_
122

__

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

Q.

Okay.

And help me understand,

what that

2:
3 4

connection someone

does that have with your assertion a signed, blank

gave Judge Butler MR. HODGE:

check?

If I could

just interrupt. Butler gave DSS a

5
6

I think his testimony signed, blank check.

was that Judge

7 s9
I

BY MR. BERNSTEIN:
Q.

When you say "signed, about No. a check?

I

blank

check",

are you

talking A.
Q.

10: 11 12
r '-

am talking You and

about a court order.

I

Got you.

were

confused,

because you were

you said a signed, saying said,

blank check, handed

and I thought Butler

13 14 15 16 17
181

that somebody

Judge

a check and

this is for you, sign the order.

A. Q.

No. Okay.

am sorry.

MR. HODGE: clear, it is my impression

Just so we are absolutely that the witness sense, testified using a they

19

that Judge Butler, metaphor, wanted

in the figurative check

20
21 22 23

gave DSS a blank

to do whatever facility.

to do at the New Bethany MR. HARPER:

May I make a motion

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

---

---

-------

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

2 3
4,

121 ------_._--,
I

Q.

And do you have a belief blank check?

as to what happened

to that signed, A. Well,

their actions that blank

proved

what happened

when he signed
Q. A.

check. actions prove to you?

5
6

And what do their

They came out, broke

down the gates, into my house, them in;

7 8
9 10 11: ,

threatened

to kill my dogs and broke

tore the doors down in my office, kept my staff captive, letting

Q. A. Q.
I

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

that somebody check

had given

15
16 17

in connection
A.

with that? they are free to

When they come out there, they want to do.

do anything
Q.

18 19
20

And by that you understood Butler a signed, blank

that somebody

gave Judge
A.

check? got a court is

I understand

that they somehow which

21 22!
23
24

order,

what they call an ex parte,

one-sided Q.
A.

Right. -- proving that they had a right to do to do.

25

___________
BAiN

anything

that they wanted

J
(318) 429-2160

&

SIMPSON COURT REPoRTERS

SHREVEPORT. LoUISIANA

MACK W. FORD -- 7/22/97

123 .....,
1

During

the break,

Brother

Ford advised

me that he has

2,

had litigation

with the Sheriff,

and he is confused, constitutes an

31
41

as well as I, as to whether
I

the Sheriff

instrumentality disclosure, engaged

of the State.

So as a matter

of full

5!
6
,

he would

like to disclose

that he has maybe of

in litigation

on at least one occasion, Ford, with

7:
I

more,

I donlt

know, Brother Parish.

the Sheriff

8
9,

the Bienville

BY MR. BERNSTEIN:
Q.

10
11

And the litigation to, was that against

that your

counsel Ardis

just

referred Whitman?
A. Q.

the Sheriff

12
/--\

13 14 15 16 17 I
181

Yes, sir. That is your lawsuit you? against him in federal

court over him hitting

A. Q.

Yes. Okay. Any other litigation with any Sheriff

of Bienville
A. Q.

Parish?

19

No, sir. Okay. And you were telling me earlier that

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

that the child protection

'"
/

24

State were not in good faith?

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

RAIN & SIMPSON COURT REPoRlCRS

_. _ ..

(318) 429-2160

...

-- _. __

._._._--

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

_._.

_._-_

MACK W. FORD -- 7/22/97

. ----

--

---

------

----_.

__

124 ._--

1
2 3i
I

Q.

When you say "carloads", Two station wagons.

how many cars?

A.
Q.

How many people Probably Okay. about

were there?

4
5

A.
Q.

eight or nine. are

When you say "who they brought", the fact that they had eight

6i 7
8

you talking people A. Deputy

Q. A. Q.

or nine

there? DSS workers. Sheriff That doesn't include the

9\
10 11 12 13 14

or the juvenile Sheriff

officer. was that?

which Deputy Lucky Raley.

And the juvenile Bob Stewart. Okay_ And when

officer?

A.
Q.

the DSS child protection to you how

15 16
17 18

workers

came in 1996, did they indicate they felt they needed I think,

many children
A. Q.

to talk to?

The order, Any other intense

said 84. else that you think Fire

anything scrutiny

19 20
21

constitutes Marshal
A.

by DSS, the State

and their agents? It has just been a series the years, and it seemed of investigations time

22 23
24

through

like that every

they did that, order, never,

that they always right after

came with an ex parte and they have

one child

another,

25

ever believed

the truth.

They have always

_J

BAIN

&

SIMPSON COURT REPoRlCRS

SHREVEPORT, LoUISIANA

(318) 429-2160

MACK

W.
-

FORD

-- 7/22/97

----1 2:

--_---------'-----the lies. We have lived under that burden

125

believed

for 22 years knowing believe through, the truth.

when they come they will never And those children have went they

3
4
5;

all the way through their way through

life up until where or manipulating

were lying through.

Q.

their way

6
7 8
I

And on some of the occasions they wouldn't

that they would

come out, would

get to talk to the children,

they? A.
I

10 11

guess

they have been

-- every

instance except in and

they have managed

to talk to the children

12
13 14 15
I

rare cases when they wanted then they removed

to talk to everybody, permission

the kids without

from the

court or the permission Q. members?

A.

of the family. to interview staff

And have they ever sought

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

side of the story,

A.

No, sir. Okay. So the only information that they as a

Q. received

24!

was what they had either

which precipi tated their

received

p 2sLe ort,

visi t ~._.~: __ what they

BAIN & SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

MACK W. FORD
1 ~-ained in

7/22/97 talking to Children~-------------.--.

2i 3
4' 51

A. affidavit,

Understand,

Mr. Bernstein, I know where

they had an that affidavit of a borderline teacher

and I believe

came from, would retarded that

I

be the only source, took the names

child,

to a school

feel that wrote

that affidavit. Excuse me. Is your

MR. HODGE:
B 9
I

question

limited

solely

to 1996? No. sure the witness

MR. BERNSTEIN: MR. HODGE: understands that.

i

101

Just make

11 12
13 14 15

BY MR. BERNSTEIN:

Q.

Reverend

Ford, you made the statement

that

they believed A. Q.

the lies and not the truth.

Right. And when you say "they", workers? you are referring

17 18

to the child protection A. Q. referring A. Q. referring A. Right.

19 20 21
22

And when you say "the lies", you are to what? What the children Okay. tell them. you are

And when you say "the truth",

23
24

to what? What we tell them.

25
1L

Q_. __
BAJN

O_k_a_y_. __ A_n_d_I_t_h_i_n_k_y_O_U_J_' _ll_s_t_h_a_v_e _-__o_n __a_n_Y _ __j

COURT REPORTERS SHREVEPORT, LoUISIANA

& SIMPSON

(318) 429-2160

MACK W. FORD

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

_.-.

127 Homes

occasion refused 3
4
5.

have staff members to be interviewed

at the New Bethany

by the child

protection

workers? A.
Q.

Yes, sir. Okay. Has that happened on more than one

6
71

occasion?
A.

Yes. Okay. And if a staff member is not how is it

8;
9
10i,
I
i

Q. interviewed

by a child protection worker would

worker,

the child protection

learn the truth as

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

investigations, you to court information A. Q.

it is your preference than obtaining

that they take

rather

both sides of the

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

that they take you into the courtroom information premises? A. Q. A.

Q.

rather

than doing

it by interview

on the

Before

the judge.

May I add -all along?

And that has been your position All the while. Going back to paragraph

2si
BAiN

7, you said that you

-------------------------& 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.

Did you have any meetings

with that particular office yourself

4 5
6 7 8

representative face to face? A.

of the fire marshal's

Not in the office,

but with

the man that

came on our premises, Q. Okay.

on our church

grounds. to believe to

And do you have any reason

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

He was the one handling Q. Okay.

our home. -- so if

And that would

have been

16 17 18
19
20

and that would

have been the same man that you had a with there at the church or the

face-to-face

meeting

in the offices? A. Q. On the school grounds. And that would have

On the school grounds. '80s?

21

been in the early

!
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

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 429-2160
.

---_

MACK W. FORD -- 7/22/97

---.

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...

_._-----

129

Q. 2
3'
4 5:

Okay.

Do you think

it was a Mr. Rob

Robinson? A. belligerent Q. crippled A. Q. A. Q. A. Q.

I
i

He was a crippled

man, but he never was

I

and mean; Mr. Robinson. Okay. Do you remember

remember

him. a

Mr. Robinson

being

6
7 8 9'

man? Yes, sir. Do you think that is the same crippled

NO,

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

that the State, church quote, meeting A. Q. about

home and church was somebody with? Yes, sir.

were shut down",

that you had a face-to-face

17 18 19 20 21 22
23 24 25

And that would

have been

in the early

'80s,

the same time as the lawsuit you? It was before Okay. Early '80s. before before that.

that they filed

against A. Q. A. Q. A.

Shortly Shortly

that lawsuit? the lawsuit, along about thatJ

I
BAIN

&

SIMPSON COURT REPoRlCRS

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

that, Mr. Bernstein. on the dockets handled with

I remember

3
4

and find out, because Then Mr. Herring

that case.

51
6'

it in Baton admitted NOW,

Rouge,

and the guy that said saying it.

readily Q.

it to Mr. Herring,

the only two -- there are going that I am going to be producing

to be to your and

8
9'

some documents lawyer shortly,

but I have got one of them here;

10 11
121
1

in looking

at it, it looks like the only two names from the fire marshal's in the early '80s

that I can see that were office I were involved

with New Bethany

13

initials

R.N., quote,

"Rob Robinson",

and a

14
15

Mr. Richard A.

Calhoun. that Richard Calhoun is the one.

I believe

16 17 18
19

I am believing Q.

that is him. for believing that

And what is your basis

that was him? A. remember. Just something about it rings. I can't

20

I
211 22

Q. church, been

When you say that you, meaning the home and the school of intense

you,

the have

and your staff,

23
24,

the subject

scrutiny

by DSS, the state

fire marshal

and their agents, to?

when you say

25

who are you referring

BAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

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

--_.-'---- --

--

_.

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

that DSS has used Homes

with the New Bethany use in any other A. depositions

I

is any different facility? because

residential

8
9

I believe

it is different,

in their before.

they said it has never happened recall it.

11
11,
I

Some of them said they don't Q. A. Q.

Well now, back in -That is why I don't know.

12 13

Back when

-- you say ~in the depositions~, the depositions we took in Baton

14
15

you are talking

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

that you were being were being treated

New Bethany other

20 21 ; 22 23 24 25
L

religiously-oriented A. Yes, sir, because

residential

I felt like through what has happened with

has happened

with the Sheriff, what happened

the fire marshal, Social against Services,

the Department vendetta

it has been a personal

me and that ministry.

BAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT. LoUISIANA

(318) 429-2160

MACK W. FORD

7/22/97 132

Q.

How does what happened

with the Sheriff

tell than

r'

you that the DSS employees they treat other

4.

treat you differently residential

religious-oriented

facilities? A. Ardis The Sheriff made the statement, Sheriff

5 6

Whitman

made the statement he said, by God,

I

when he beat me up in will turn the fire and they will will get you one

that office,
8 9 10;

marshal

loose on you and his agents,

I

take care of you; he said, by God, way or the other.

Q.

11 12 13
14 15 16

And that was in 1982? Somewhere Not 1982. along that line. back. And how

A.
Q.

That was further Whitman Sheriff

much

longer was Ardis

of Bienville

Parish? A. Long enough to persecute us. do to persecute

17 18 19
20

I
you?

Q.

What else did Ardis Whitman

A.
Q.

Told all the bad tales, Okay.

all the lies. Whitman was

How did know that Ardis

21
221

talking A.

about you? Because of the parents. Parents related to

23
24

me everything his office

Q.

that was said; and we got another the same thing. that related

guy in

doing

25

Can you tell me a parent

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.

that the Sheriff

I can't call the names.

It was a lot of

3 4:

You said there was a guy in his office.

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

the Sheriff Q. saying

A. Q.

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

in the home would and they would

call the Sheriff's say, don't that place the kids

Department, out there; prison;

that is a bad place;

is a little

they are mistreating

them;

they are beating

them; all the bad things that ministry.

Q.

that could be said concerning

21
22

Why would before

in other words,

this would be a

23
24

parent,

they placed office?

their child with you, would

call the Sheriff's

25

l
BAIN

A.

They called

the DSS, and they would

do the

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

MACK W. FORD

-- 7/22/97
134

1 r--s-a-m-e--t-hi-n-g-.-~-e-p-a-~t-m-ent of Social Services

2!

would

tell

them the same thing and then forbid a runaway

Q.
i

them if they were

3
4 5!

to bring Who would

them back. forbid what? of Social Services would back.

A. forbid

The Department the parents

6 7
8

from bringing

the children

You cannot Q. instructed back? A. find out. Q. through A.

I

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

I would have to go through

our records

and

Okay.

How long would

it take you to go

14
15
161

your records I would it.

and find out? and find

have to call the parents

out and verify

Q.

17 18 19

Okay.

How long would

that take you

to do?

A.

We have already

been trying

to reach some of They was out of the

the parents charged home.

Q.

that has had that problem. the children

20 21

for the DSS taking

They was what? The parents were charged for services

23 24

A. rendered

by the DSS by taking was involved,

the child out; all taking care of that

25

the -- whoever

BAIN

&

SIMPSON COURT REPoRTERS

SHREVEPORT. LoUISIANA

(318) 429-2160

MACK W. FORD

7/22/97 135

1 2

child, Q. records

they were

sent bills

for. is: Are there parents that

But I guess my question

3 4 5 6
71
i

that you could go to to identify

reported Sheriff home? A.

to you that they had conversations or Bob Stewart or DSS employees

with the the

about

What I could do is call the parents

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

have had children A. Q. children? A. Well,

I am sure it is on the school Okay.

15 16
17'

Is that a list of parents

all the applications and addresses

of the school numbers.

has

18
19

the parents'
Q.

names

and phone

And how long do you all keep those

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.

to look at? send home. So I don't go with know

What they didn't

25

how many we would

have left that didn't

the

BAiN

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

_._-

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

-- 7/22/97
--------=-------------------=-=-; 136

1 21

child when the child Q.

left.

Probably

very

few. take you to

How long do you think it would to obtain

3 4 5
6j 7

find the parents,

the names of the parents had instructed them

that told you that a DSS employee to not put their A. call. child back

in New Bethany? I would just have to

I

We would It would

have to call.

take time to call all those parents,

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

bad about New Bethany? be John Potts.

The one child would

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

just have to look it up. name? his daddy's name.

And his parents' I can't remember

Mr. Potts Q.

is all I know. Okay. And when was John Potts a student at

New Bethany? A. Probably in aboui 1991, '92, '93, somewhere

23
241

along

in there. Q. Okay. You recall that one of his parents

_

25
L-

BAJN

&

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SHREVEPORT, LoUISlANA
..

(318) 429-2160

--_ ....

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MACK W. FORD

7/22/97

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137

told you about a conversation? A. Yes, sir. They brought the boy back out to

get his things, bring

and he said that they told him not to that he would be

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

Services. not to bring him

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.

And did they say whether or Texas Department No.

of Social

That was up at the courthouse

17 18 19 20 21
22

MR. HODGE: Mr. Bernstein. (A discussion

Excuse

me one moment,

was held off the record

between

Mr. Hodge and the witness) MR. HODGE: involved an allegation I asked my client if this in which that we are

of abuse or neglect, in the records

23
24 25

case that would be involved awaiting production

from DSS.

If we could defer

questioning

on this line

RAIN & SIMPSON

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

MR. BERNSTEIN: come back to it. We are going That

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.

We will come back and pick

I
9

Q.

Okay. 1980s,

The lawsuit

also says,

"Commencing began a

in

10 11 12
/
\

the early constant against

the State of Louisiana campaign

and unremitting Pastor

of harassment the church home and

Ford, the church,

13

its staff". been

What is it that you have seen, heard or leads you to believe campaign of

14 15 16
17 18

told that makes you believe,

that there was a constant harassment? A. Q. Louisiana harassment Go through Okay. began

and unremitting

that question

again,

please. "The State of campaign of

Your lawsuit a constant Pastor

says that,

19 20
21

and unremitting Ford, the church, is:

against

the church is it

home and its staff",

and my question

What

22 23
24 25

that you have seen or heard that leads you to believe and unremitting A. campaign

or been told by somebody

that there was a constant of harassment? that were given have

Because

of the orders

BAIN & SIMPSON COURT REPoR1CRS

SHREVEPORT, LoUISIANA

(318) 429-2160

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MACK W. FORD -- 7/22/97

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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

The Department determined of letting what

and what

is invalid

the judge do that.

They have

8
9 101
I

always

put the pressure

on for psychological That

,
1

evaluations,

and I feel like that is an insult. I may look crazy, but I ain't

is a real insult. crazy. Q. A.

I

11 12
131

Anything

else? during that time we know that

And of course, court ruled

14 15 16

the appellate

in our favor and knocked

down those examinations agency no chance

and gave the child protection the children.

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

ask you if you can narrow A. Q. The Department

that down. of Social Services. that there this

21
221

And do you have reason

to believe

was an individual constant A.

that made the decision campaign

to begin

23
24

and unremitting

of harassment? office. I couldn't

It has to be the Minden person.

25l__ name
BArN

anyone

&

SIMPSON COURT REPoRTERS

SHREVEPORT. LoUISIANA

(318) 429-2160
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...

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MACK W. FORD -- 7/22/97

r---- ---.

140

Q.

Okay.

In other words,

you cannot

say that

, 2'
3i 4

this person

or that person

was the person

that made

the decision? A. referred

I

It was two women, to when they would

can't

recall,

that they when the

call, the parents

6;
7 8
9!

they would Bienville

call me; along with Bob Stewart Parish Sheriff's Department.

with

There

has to of

be a tie between Social Services

Bob Stewart

and the Department

and the fire marshal;

has to be some

10 11

kind of tie.
Q.

Do you have any reason

to believe

there

is a

12 13
141

tie?
A.

Yes, sir, because

of what was said through

the years. Q.
A.

15 16 17
18 i

What

is it that was said? down the home, always down the me.

They always always

ministry,

had a personal the report

vendetta

against

Bob Stewart buying

Q.

has made

that I was out there over the place. that there is a as a

19 20

up land and out there Okay. Now,

I

taking

understand

21
22

question Deputy

in your mind as to whether is somehow connected

Bob Stewart

Sheriff

with the State, there is any of

23

but do you have any reason connection between

to believe

Bob Stewart other

and the DSS agency

25

the state government

than the fact that Bob

BAiN & SIMPSON COURT REpORTI:RS

SHREVEPORT, LoUISIANA

(318) 429-2160

-----

. _. ---

MACK

W.

FORD

7/22/97

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

---that has

_ _ __._. been Parish? to call when the the designated

-=1.!,1
I

Stewart as the

is the juvenile They

Deputy officer have

Sheriff for

2 3

Bienville said

A.
Department wants

always

we have and then

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

I am talking runs the of away

Sheriff's and they

a child Sheriff,

goes

juvenile

probation and said

officer says, blah, of the we

calls have

10 11 12 13 14 15 16 17 18
191 20

Department problem blah. in, and

Social this

Services child the has

got

here; So they

blah, Social

blah, Services they that

i

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

obligation Department report of

a Deputy when

Sheriff they

Social

Services or

receive

chi ld abuse They that say they

neglect? cases that they have the an

A.
agreement
I

in some are

21
221 i I 231 24

obligated

to call

Department Q. mandates

of Social So you that are

Services. not aware of a state to call law DSS? that

certain

people

have

25 ______
RAIN

A_._.__ I __ t_h_~_.n_k_t_h_a_t_~_._s_a_n __ a_g_r_e_e_m_e_n_t_' __ I_t_h_i_n_k_t ha~

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SIMPSON COURT REPoRTERS SHREVEPORT, LoUISIANA

(318) 429-2160

MACK W. FORD -- 7/22/97 ----- --- -1 2

3:
I

142

is an agreement Services Q.

between

the Department --

of Social

and the juvenile

So you are not aware that certain

that there people

is a state

4 5
61

law that mandates certain things

have to report to the State of a crime;

that look like child abuse themselves be accused

or that they could

7 8

you are not aware of that, are you? A. Q. Yes,

I

am.

9i

You are? MR. HODGE: Let me just object to the

form of the question.

12

If you are asking

this witness

what his opinion of the law is, questions

I

of the law is or what his knowledge object to that extent. Answer the

if you know the answers

to them.

15
16
I

BY MR. BERNSTEIN: Q.
!

My question

is:

Are you aware

of whether

or

17' 18 19
I

not there are certain that are legally abuse could to DSSi receive

people

in the state of Louisiana possible child

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,

am aware of that. false

But I am

also aware of the fact that if they make statements hiding that they are subject the confidentiality

.~

24
25

to prosecution. law, we can't

See, ever

behind

BAIN

&

SIMPSON COURT REPORTERS

SHREVEPORT, LoUISlANA

(318) 4292160

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

7/22/97
---"-.,--'--------_.

----- -----

143

I!
2
3

find out.

They need to tell us if it is not true.

If

it is not valid,

then they need to tell us who that is You see, we don't

I

where we can stop them from lying.

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

and Mr. Crouch)

BY MR. BERNSTEIN:
Q.

Going back, you said you believe between Deputy Bob Stewart

that there and DSS and

is a connection the state A.

Q.

fire marshal's Yes, sir. Okay.

office?

And what is the basis

for that

belief? A.
Q.

They roll up together

out at the Home. up

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

&

SIMPSON COURT REPORlCRS

SHREVEPORT, LoUISIANA

(318) 429-2160

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MACK W. FORD
_.

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

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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?

The best Okay.

can remember. reason to believe there

5:
61

And any other between

is a connection Sheriff

Bob Stewart

as a Deputy

in Bienville

Parish,

the DSS and the State

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 \ ,

talk to that would

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

think Bob Stewart

I
19
1

A.

If he was under oath and did not lie, he

20
21

will tell us why he is so biased.

Q. A. Q.

You think Bob Stewart I imagine he has.

has ever lied?

22

Have you sued him? No. Now, any other -- so when your lawsuit says,

A.
25

Q.

BAIN

&

SIMPSON COURT REPORTERS

SHREVEPORT. LoUISIANA

(318) 429-2160

MACK W. FORD
__

7/22/97
_ __ --0 0 _ __ .0 _

145

1 i
2

liThe State of Louisiana unremitting really campaign

began a constant

and is

of harassment",

what that

3 4:
5i 6

saying

is that Bob Stewart, office;

DSS and the State

Fire Marshalls A. Q. Louisiana", A. Q. A.

Q.

isnlt that correct?

In some cases. Okay. When you say "the State of included in that? in it.

7
8 9;
10i

is the Governor Well, Okay. Because Okay. the Governor

is not included

I have talked How about

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.

Police? the State on us. Police

15

We have reason in a helicopter And what makes Because

to believe checking

16
17 18 19 20

you think that? helicopter.

of the State Police Police

You saw a State

helicopter?

Yes, sir, low enough

we could see the

21
22 23
24

that you think

in the in

State of Louisiana the constant

that you think has participated campaign of harassment

25

and unremitting

BAJN

&

SIMPSON COURT REPoRTERS

SHREVEPORT, LoUISlANA

(318) 429-2160

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

MACK W. FORD -- 7/22/97

._- --_0__. _

146

1
2 3 4: 5;

against staff? ! A. Q.

you, the church,

the school,

the home and the

No, sir. Okay. The lawsuit against says that in 1988 DSS and the church which to
I

filed a lawsuit

you, the church ex parte

6
7

home and obtained compelled certain

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.

to the lawsuit Court

that was filed that

10 11 12 13 14 15 16 17 181 19
20

District

and the orders

by Judge Butler We won.

at that time?

Yes, sir. Okay.

Are you aware

that the Court statute that they

held that the state

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

So, the State won as well,

didn't

22
23

they? MR. HODGE: of the question. Let me object to the form

1-'\

24

To the extent

that you are asking I

25

him a legal conclusion

as to who won and who lost,

BAIN

& SIMPSON

COURT REPoRTERS

SHREVEPORT. LoUISIANA

(318) 429-2160

---_----

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

--

---- .._----holding is in

147

object. published; paragraph

He is a layman. the citation

8,

The Court's is cited

2
3'

in the complaint or agree

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

that he won, and I am just probing because believe,

the with

for his belief, opinion,

I

it is at variance isn't it, Counsel?

the Court's

9!
I

MR. HODGE: legal conclusion, that lawsuit; stated

If you are asking

me for a

10

I will give you mine.

This man won And I in the

11 12
r\

that is my legal conclusion. and

I

the holding,

believe

accurately

13

complaint

in paragraph

8.

14
15

MR. BERNSTEIN: MR. HODGE: representation

In part.

That is an accurate of the Court. In its entirety?

16 17
18

of the holding MR. BERNSTEIN: MR. HODGE: MR. HARPER:

This is a deposition. We are bickering,

19 20 21
22:

gentlemen. MR. BERNSTEIN: We will move on. BY MR. BERNSTEIN:

Q.

This

is a deposition.

23 24
25 I
1

Any reason

to believe

that when DSS filed that

that lawsuit
-

and obtained

the ex parte orders

i
1

J
SHREVEPORT, LoUISIANA

BAJN

&

SIMPSON COURT REPoRTERS

(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;

Please Sure. that you

Do you have

reason or DSS

to believe, told, that went

4
5

heard the

been

to believe Butler

that

when

employees ex parte

6'
7

to Judge orders that

in 1988 and children in good they

obtained at the faith? it, New

the

concerning they A. were The not way

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

instead Q. was not A. Q. What

of who they order? All

court

interview

a child

of them. the questions to? have you been they asked.

Okay.

said

19
20

questions A. The

you

referring

embarrassing Ford. what

questions;

21
22

molested Q. question? A. ask these

by Reverend Okay. And

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

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
;

the DS5 employees carrying A. there.

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

take a tape recorder,

and, knowing they

for a fact that coached

that child to say what

say, lead them, and then they record recorder today. Q. A. Q. coach just like this recorder

that on the right here

going

And how did you know that happened? I saw it. Okay. And in other words, you saw them

14
15 16

the children? A. Saw them dealing with the children with a

tape recorder. far enough Q. children? A. children Q. A. Q. !

I
BAIN

They wouldn't see.

let us hear, but we were

17
18

that we could

So how do you know they were coaching

the

19
20

Because got home.

of what

the parents

told us when the

21 22
23

And which parents There okay. again,

told you that? the names.

I donlt remember

24 25

A.

We have had thousands

of children

through

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SIMPSON COURT REPoRTERS SHREVEPORT, LoUISIANA

.1

(318) 429-2160

MACK W. FORD
,

7/22/97 150

l'

that home, Q.

thousands

of parents. for believing to do their job

2
3

And what else is your basis were not trying

that the DSS employees in good A.

,

4
5:

faith in 1988? Because they could have at least called, the

,
6'

give us enough proper

courtesy

to call and go through

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

By 1988 had -- well,

let me ask you this: workers of

11i 12 13 14 15 16 17
I

Prior to that in 1988, the State

had child protection allegations

come out to investigate then? am sure they did.

of child

abuse before A. Q. A. Q.
I

Okay. Most

And had they been turned instances, no.

away?

But they had been turned Not to that point,

I

away some? think.

I

181

A. remember. Q.

don't

can't

19 20 21 22j

So it is your testimony

that prior workers

to 1988 away?

at no time were child protection , A. Q. away? MR. HODGE:

I

turned

can't recall. have been turned

23
24

Does that mean they might

25

He means,

Counselor, ------

he

BAII'i

&

SIMPSON COURT REPoRlCRS

SHREVEPORT. LoUISIANA

(318) 429-2160