vs.            CASE NO. 04-CP-15-382










DATE:          December 4, 2006

TIME:          9:00 a.m.



123 Walter Street

Walterboro, SC  29488





P.O. Box 73129

North Charleston, SC  29415

(843) 762-6294









123 Walter Street

Walterboro, SC  29488

(843) 549-9544







206 E. Washington Street

Walterboro, SC  29488

(843) 549-9330














Witness Sworn                                 4


By Mr. Utsey                             4

By Mr. Chaplin                         225

By Mr. Utsey                           229




Certificate of Reporter                     250

Deponent Correction Sheet                   251







Plaintiffs' Exhibit Number 1                 77

Plaintiffs' Exhibit Number 2                106

Plaintiffs' Exhibit Number 3                117

Plaintiffs' Exhibit Number 4                163

Plaintiffs' Exhibit Number 5                189

Plaintiffs' Exhibit Number 6                200

Plaintiffs' Exhibit Number 7                204

Plaintiffs' Exhibit Number 8                214









RALPH GORDON STAIR, having first

duly affirmed, testified as hereinafter set forth.



Q.   Can you give me your full name, please?

A.   Ralph Gordon Stair.

Q.   Mr. Stair, we are going to take your

deposition here today.  Have you ever provided a

deposition before in any other cases?

A.   Yes.

Q.   On how many occasions?

A.   One time.

Q.   Do you generally understand how this

process works?

A.   Very well.

Q.   I am going to go over a few points that

I normally cover with folks before we begin.  You

may know some or all of this, but I think it's

helpful sometimes to tell people what to expect

and how this process works.  It makes it go a

little more smoothly and quickly, hopefully.

I am going to ask you some questions,

and you are going to give me answers to the best

of your knowledge and to the best of your

ability.  And, of course, your answers need to be

truthful, as you affirmed you would do.

The purpose here is for me to

investigate, or what we lawyers call discover,

different parts of this case.

Under our laws, I can't talk to you

except for two occasions, one is here in the

deposition with your attorney present and the

other is if we go to trial and you are on the

witness stand.

So it's important for me to take this

time to understand the knowledge you have about

these cases and to investigate the case from that


A.   All right.

Q.   I explain that to you now so that you

will understand I'm not taking your deposition for

any other purpose, and particularly not for any

improper type purpose.  I am not just here out of

curiosity to delve into your private life, for


I'm not here to try to ask what I would

characterize as trick questions or try to get you

to say something that is not accurate.  It doesn't

do me any good and it doesn't do you any good.

It's simply an investigation tool.

And I also give that introduction so

that you will know that if I ask you a question

that you find to be confusing, or one that you

would rather me rephrase or repeat before you

answer it, please let me know and I will be happy

to do that.

Because it's not my intention to try and

confuse you with questions, but I know that we

lawyers sometimes will talk too much and make what

could otherwise be a simple question more

complicated than it needs to be.

A couple of ground rules that will help

with ensuring that your testimony is recorded

accurately and transcribed accurately when our

court reporter prepares the transcript.

It's difficult for her to type two

people speaking at the same time, and so it will

be important for me to wait until you finish your

answer before I ask you a question and for you to

wait for me to finish asking a question before you

begin answering it.

Now, in my experience I will probably

ask you a question before you are finished

answering, and you will probably answer a question

before I'm finished asking.

If that happens, you stop me or I will

stop you.  I want you to understand it's not

because I'm being rude if I do that.  It's because

I want to make sure that everything is accurate on

the record.

Fair enough?

A.   Sure.

Q.   Another thing is if you and I were just

talking on the street, we might have a

conversation where one of us shakes or nods our

head or says uh-huh or huh-huh, or something like

that, that might not be entirely clear if it were


So in response to a question, if your

answer is yes or no, you need to say yes or no

rather than shaking your head.  And if you forget

to do that, I might remind you.  Again, it's not

because I'm trying to be rude.  It's just because

I want to make sure that your testimony is

accurate for the record.

A.   Sure.  Yes.

Q.   If you need to take a break at any time

during the deposition, let me know, a rest room

break, coffee break, whatever, and I will be happy

to accommodate you.

I will tell you that under our rules, if

you have any conversations with anyone during a

break, including with your attorney, that when we

resume I'm entitled to ask you about the

conversations, even if those conversations might

otherwise be attorney-client privileged.

Under our rules, once a deposition

starts, then the witness is sort of on his own as

far as what he's going to say and testify and

can't get assistance from his attorney unless it's

with respect to a question of whether to claim

attorney-client privilege to a particular


Do you feel like you understand that?

A.   Oh, yes.

Q.   If you have any questions about the

deposition itself, or about the process that we

are using here, I will need for you to address

those questions to me and I will do my best to

answer those before we go on.

Fair enough?

A.   Uh-huh.

Q.   Any other questions that you have before

we get started?

A.   Not that I know of.

Q.   Are you feeling well enough to give your

deposition today?

A.   Oh, yes.

Q.   Are you taking any medication or under

the influence of anything that would affect your

ability to hear, understand and respond truthfully

to my questions here today?

A.   No.

Q.   Let me get some background information

on you.

What is your date of birth?

A.   3rd of May, '33.

Q.   Have you ever gone by any other names?

A.   No.  Brother Stair.

Q.   Okay.  Well, I understand, yeah, title.

A.   No.

Q.   Are you married?

A.   Yes.

Q.   And your wife's name?

A.   Teresa Grace.

Q.   Is Grace her maiden name or is that a

middle name?

A.   That's her middle name.  Her maiden name

is Erconolino.

Q.   Can you spell that?  I'm putting you on

the spot, I know.

A.   I'm sorry.  I don't know if I can do

that or not.  E-c -- Erco -- E-r-c-o-n-o-l-i-n-o,

somewhere like that.

MR. CHAPLIN:  You can clarify it later


Q.   How long have you-all been married?

A.   I think about 25 years.  I'm not sure of

the exact date.

Q.   Is that your only marriage?

A.   No.

Q.   Who was your previous marriage to?

A.   Jeraldine -- let's see.  What is her

name?  It's been so long.  I remember her middle


Q.   That's okay.  What was her maiden name?

A.   Hilbert, H-i-l-b-e-r-t.

MR. CHAPLIN:  I apologize.  I am going

to ask you just to give me one second here and put

this fire out because it's involving a judge, and

then I won't have to bother you anymore.  It will

just take two minutes.

MR. UTSEY:  Sure.

(A recess was taken.)

Q.   Before we took a break you were telling

me about the fact that you were previously married

to Jeraldine Hilbert?

A.   Yes.

Q.   And that marriage ended how?  Did she

pass away or did you-all get divorced or what?

A.   No.  She just divorced me.

Q.   And approximately when was that?

A.   Well, like I say, about 25, 30 years

ago, something like that.

Q.   Oh, okay.  And in what state was that?

A.   That was in Georgia.

Q.   Do you remember what county?

A.   No.

Q.   And what were the grounds for divorce?

A.   There wasn't any.  She just divorced.

Q.   It wasn't as if anybody accused anybody

of any wrongdoing or anything?

A.   No.

Q.   Fair enough.  Are those your only two

marriages, or did you have any marriages before


A.   That's it.

Q.   Any children?

A.   Yeah.  I have five from the first wife

and one from the second.

Q.   Let me get their names and ages, please.

A.   Oh, man.  You are asking me questions

that I don't know if I can give you the answers


Q.   I thought these were the layups.

A.   Well, I don't know how old each one of

them are.

Q.   Give me -- I assume they are all over

the age of 18 if you had been married to her 25 --

A.   Definitely.  All of my children from her

are -- the oldest is probably at least 50s and

then down to 40s.  Probably the youngest one is

somewhere, I would say, in his 30s.

And then I have a young daughter with my

second wife, and she is 20.

Q.   What is her name?

A.   Naomi.  Her last name is Bowles,

B-o-w-l-e-s.  She is married now.

Q.   Where does she live?

A.   Up near Columbia.

Q.   Do any of your children live in Colleton


A.   No.

Q.   Other than your wife, do you have any

other relatives who reside in Colleton County?

A.   No.

Q.   How about any relatives through your

wife's side of her family?

A.   No.

Q.   Where is your wife from originally?

A.   New Jersey.

Q.   How long have you been in the Colleton

County area?

A.   At least 25, 30 years.  Almost 30 years

I would say, 25 for sure.

Q.   Before that where were you?

A.   I lived in Savannah for awhile, and I

pastored a church in New York and one in Boston.

Q.   Where are you from originally?

A.   Bethlehem, Pennsylvania.

Q.   When did you leave that area?

A.   Oh, many years ago.  I would say at

least 40 years ago, maybe longer than that.

Q.   So the states you have lived in include

Pennsylvania, South Carolina, New York, Georgia?

A.   I lived in Georgia.  I lived in Alabama

for a long time years ago when I first started to


Q.   Any others?

A.   Where I lived?

Q.   Yes, sir.

A.   I lived in California for awhile.

Q.   Anywhere else?

A.   Of course, you know, for many years I

was a traveling evangelist so I was in a lot of

states, and I would sometimes stay in those states

for who knows how long, as far as living.  I can't

say I lived in most of them, no.

Q.   I guess I'm looking more for your

residence rather than --

A.   I would say Georgia, Alabama, New York

and California would be the states I lived in.

Q.   And then when you were doing this

out-of-town evangelism, how long would you stay if

you said you had a protracted stay?

A.   Sometimes months and sometimes weeks.

Q.   Now, the case here is pending in

Colleton County, and one of the things that the

lawyers for both sides will do is to try and make

sure that we have a jury that doesn't have any

connections to either the plaintiffs or the

defendants in the case.

That is why I asked you about your

relatives that may be in the county.  But also,

obviously, I would also like to understand who are

members of your congregation or your ministry?

A.   We don't have any membership.

Q.   Do you have folks that associate

themselves with -- am I using the term correctly

to say congregation, or do you call it fellowship

or --

A.   We have people who come to our meetings,

yes, but they are not members.  They just attend

our services, and that could be some from here,

some from locally.  People drive in from various


Q.   Do you have folks who live on the


A.   Sure.

Q.   Are there any lists of such people that

can be produced?

A.   Oh, yes.

Q.   So is it fair to say that if we were

preparing to try this case, if we get to that

point, I could get a list from Mr. Chaplin just to

make sure I could compare that against the

prospective jury list?

A.   Correct.

Q.   All right.  What would I call that list

if I was to ask for it?

A.   I guess the residents of the Overcomer

community.  Of course, they don't all live with

me.  There are other people in the area.

Q.   Who attend services?

A.   Yes.

Q.   Do you maintain a list of donors?  Say

someone doesn't live on the community but they

donate money?

A.   Yes.  We have people who donate money.

We have a list of every one of them, sure, but I

don't know if I could give you that list.

MR. CHAPLIN:  I think we provided

something in discovery already with regards to all

of the different plaintiffs.

MR. UTSEY:  Right, but I'm looking more

in terms of selecting a jury.

MR. CHAPLIN:  Selecting a jury.  Okay.

A.   You are talking about somebody in the

area that could be potential jurors?

MR. CHAPLIN:  Somebody that might have

donated money so that he could actually --

Q.   Yeah.  Hypothetically, I guess a jury

list has 150 names on it.  If one person buried in

that 150 names is someone who regularly attends

and donates --

A.   That wouldn't be a problem.

Q.   -- I want to know that.

MR. CHAPLIN:  On voir dire, wouldn't

they have to answer that, though, if they ever


MR. UTSEY:  In my experience, not

everybody answers those questions accurately.  And

that's not always intentional.  I mean, I think

sometimes they get confused or don't know what

they should answer.  But there is always some --

A.   If I understand your question correctly,

you are wanting to know anybody in this general

area that could be a potential juror?

Q.   Who has a relationship with you.

A.   Right.  That isn't no problem.

Q.   Okay.  If you-all want to do the same

thing with the people that might have a

relationship with my clients, we will give you

that, too.

A.   Sure.

Q.   Easy enough.  Let me get some more

background information on you, Mr. Stair.  How far

did you go in terms of formal education?

A.   I went to 10th grade.

Q.   Where was that?

A.   In Bethlehem, Pennsylvania.

Q.   What school is that?

A.   Bethlehem High School.  That is the last

one I attended.

Q.   Did you get a GED after that or any

other formal education?

A.   No.  I took Bible study courses and

things like that from various religious

organizations, but I never --

Q.   Did you ever serve in the military?

A.   No.

Q.   Tell me about your religious training,

your Bible study courses or however you want to

characterize it.

A.   Well, you just took Bible study courses

that they had, theological, doctrines and things

like that.  That is what they were.

Q.   Are these formal courses of study?

A.   Yes.  Sure.

Q.   And when you finish those do you get

some sort of certificate of completion or degree?

A.   They would just give you a little

certificate of completion.

Q.   Give me some idea of what those

involved, or which one of those you have done.

A.   Well, I took a course with the Free

Methodist Church.  That is back when I was 17, 18

years of age.  I have never had any theological

biblical school things.

I started preaching when I was 16, and

my preaching, my manner of life, was under the

auspices of different churches where you would run

this -- they would call you an exhorter, or

something like that, and you would practice your


And they would then approve of you,

whether you were a pastor or not.  I joined maybe

four or five churches over the years, but most of

the time I just preached.

Q.   I don't have a lot of experience with

the structure or lack of structure that is

associated with that, so some of my questions may

sound like they are uninformed, and that is

because they are, so help me in understanding


First of all, in terms of certificates

of completion --

A.   I don't have any.

Q.   You don't have any of those?

A.   No.

Q.   You said that some churches have

recognized you as a pastor or --

A.   Well, you would start out -- when I

first started out, I started out in what they

called at that time was the Holiness Christian

Church, and then I went to the Free Methodist

Church, and each one of these churches would have

steps of degree of preaching.

First they would give you what they call

an exhorter's license, and then you would operate

under that for a year or two.  And then if you met

their qualifications they would advance you to

another license.  And eventually you would get

ordained.  That was a lot of different

organizations that I worked in because I was a

traveling evangelist, and I would work with a lot

of them.

Q.   Were you ordained in any of those


A.   No.

Q.   What would have been the highest level

that you attained within --

A.   A licensed preacher, a licensed pastor

or licensed evangelist.

Q.   When I hear the term license, that

suggests --

A.   They would give you a license that they

recognized as a pastor or an evangelist in their


Q.   A license being issued by that group?

A.   Right.

Q.   As opposed to some sort of state agency

or something like that?

A.   Right.

Q.   Have any of those licenses -- or any of

your licenses with any of those churches ever been

revoked or rescinded?

A.   No.

Q.   With which different churches have you

been associated where you have been --

A.   The only one I can think about that

would --

MR. CHAPLIN:  Let him finish the


Q.   I think you understand where I'm going.

I am just trying to find out in which churches

have you been acknowledged to have attained some

level as a pastor or a minister?

A.   The only two that I can -- or three of

them.  There is three of them.  One was the Free

Methodist Church.  That is very many years ago.

Then another group, which it's a very small group,

called the German Eldership Church of God, and

that was a small group in Pennsylvania.  And then

for several years I was licensed with the Assembly

of God.

The others are -- in the course of time,

you know, we became an official organized church

ourself with federal recognition.  So we have

ability to ordain our own preachers or license our

own preachers.

Q.   You are talking about current church?

A.   Yes, which has been in existence for 25

years at least, or maybe 30.

Q.   Well, I am going to talk about that, but

I just want to make sure I have covered all of the

territory in between when you began preaching and

up until the point which you formed Overcomer


Have we done that?

A.   Yes, pretty well.  I mean, like I say,

up until I came here and organized this church

group here, we started in New York and then moved

out of New York, came here and transferred here,

and we organized it here, and we got the federal

recognition and we got the organizational


And from that point on -- but prior to

that I was just mostly a traveling evangelist.  I

did pastor a few churches.  I pastored one in

Alabama.  That is another one.  That one I was

licensed by.  I pastored there for five years.

Q.   What was that called?

A.   That was called the Full Gospel Church

of God.

Q.   Okay.  Now, how long was it that you

were doing the traveling evangelism?

A.   I would say I traveled even after I came

here.  I stopped the traveling about four or five

years ago when I was pretty well tied up here with

the work I was doing here.  But even when I came

here I would travel almost every month somewhere


Q.   Was there a period before you began the

Overcomer Ministries that you were a traveling

evangelist, as you described it earlier, where you

made -

A.   I would do both.  I would pastor

churches and travel at the same time.  I had a

church for many years in Savannah, Savannah,

Georgia, and then I would travel.  But I would

have revivals, too.  So I was always either

pastoring or in the course of having meetings.

Q.   And when you were traveling and having

these revival meetings, was that under the

auspices of the church with which you were

affiliated at the time?

A.   Yes.

Q.   Not independent of that church?

A.   No.  The church -- for instance, the

church we had in Savannah, it was affiliated with

Full Gospel Churches and Ministries International,

which was an independent group of churches, and

that is where we had our affiliation then.

Q.   And when you would travel, was it like

the old-time tent revivals?

A.   Tent revivals, church revivals, street

meetings, jail services.

Q.   And let's talk -- if I call it Overcomer

Ministries, is that the easiest way to describe


A.   Sure.

Q.   The full official name of Overcomer

Ministries, though, is what?

A.   Faith Cathedral Fellowship.

Q.   How long has it been named Faith


A.   Oh, at least 25 years.

Q.   It has always had the same name?

A.   Yes.

Q.   As I understand it, that is a

corporation and that is the official name of the


A.   Yes.

Q.   But Overcomer Ministries is the

day-to-day name that most people refer to it as,

that you refer to it as?

A.   Well, that is the way we refer to it,

yes, because that is the outreach of Faith

Cathedral Fellowship.

Q.   When was Faith Cathedral Fellowship


A.   I don't have the exact date.  Like I

say, it's been 25 years.  Paul Siegel did it.  He

did it for us and did a good job.

Q.   So it would have been -- you mentioned

something about being in New York and then moving

here, but it would have been after you were inside

Carolina that you had it --

A.   No.  I had a church in New York and

Boston, and I also had a church at that time in

Savannah.  I was pastoring those three churches

and I would come back and forth.

And then I felt impressed to buy some

land, and so I came here and I bought some land

and then I moved here.  When I moved here, then we

moved our -- we had already started to file for a

church organization in New York.  We just about

had it done.

But then when we came here, we just

transferred it down here instead of up there.  We

did it here.  And that is when Faith Cathedral

became an official federally-recognized authorized


Q.   There are several steps, and that is

what I'm trying to break down.  The first would

have been getting a state to grant a charter of


A.   Right.

Q.   That would have been in the state of

South Carolina?

A.   Yes.

Q.   And we should be able to determine that

from the Secretary of State?

A.   I can go get it.  I have it at home.

Q.   Because you weren't sure on the date, is

why I asked.

A.   No.  I would have to go look at the


Q.   But you said Paul Siegel did the


A.   Yes.

Q.   Did he also assist you with any other

legal aspects of forming --

A.   He then got us -- he set up the

incorporation, the board, and the bylaws and

everything that is required to be recognized by

the state, and then he filed and got us the

federal recognition.

Q.   The 501(c)3?

A.   Right.

Q.   Where was Paul working at that time; do

you remember?  Was he in a law firm?

A.   Across the street, wasn't he?

Q.   Was that with Smoak and Moody and --

A.   Yes.

Q.   So has Faith Cathedral Fellowship

enjoyed 501(c)3 status continuously since that


A.   Yes.

Q.   So that would be approximately, again,

25 years?

A.   25 years, yes.  I would have to get the

exact date.

Q.   What was involved in attaining that


A.   Nothing particularly that I know of,

just applying for it and getting it.

Q.   Do you remember what the application

process involved?

A.   No.

Q.   Are there ongoing reporting requirements

associated with that status?

A.   No.

Q.   In other words, do you have to make

filings on an annual basis, for example?

A.   Not on that one.  We are not a nonprofit

organization per se.  We are a religious

organization, and religious organizations do not

have to file reports.

Q.   So other than attaining that 501(c)3

status approximately 25 years ago, have you had

any communications with the Internal Revenue

Service concerning that status since then?

A.   No, because we have met the

requirements.  We still do.

Q.   That is what I'm wondering, whether they

monitor that to make sure that you are still doing

what you began doing and that kind of thing.  Do


A.   Well, if you go outside of it -- there

is three things they require you to do.  They

require you to have church services, they require

you to be benevolent, and they require you to have

an education process, and we do all three of


Q.   I am just curious whether you hear from

them periodically to make sure you are still doing

those things?

A.   One time they checked us out, and then

they found out that we were still doing it and --

Q.   And they left you alone?

A.   Sure.

Q.   When was that?

A.   1988.

Q.   And who contacted you at that point?

A.   They just informed us that our status

was in question.  And they contacted Paul, and

Paul went back and whatever they had to do and had

it validated.

Q.   Were those IRS agents that contacted


A.   They didn't contact me.  They informed

me that we were under -- they inquired about our

status, and I took it to Paul, and Paul followed

through on our status and they reinstated us.

Well, they didn't reinstate us.  They didn't take

it away from us.

Q.   I'm just trying to determine who made

the contact.

A.   It was the IRS and it was the state


Q.   State of South Carolina also made that


A.   As far as I know.  It didn't last very


Q.   But I'm curious whether you know if it

was out of the Charleston office or the Columbia

office or --

A.   I have no idea.

Q.   Now, do you have a similar status with

respect to the State Department of Revenue?

A.   We have nothing to do with the State

Department of Revenue.  We don't have to do

anything with them at all.

Q.   Is that because they have given you a

status like a 501(c)3 status, or do they

acknowledge the federal, or how does that work?

A.   They just don't require anything.  There

is no reporting or anything because we are a

church organization and we operate as a church


Q.   Since you have created -- or since you

created Faith Cathedral Fellowship approximately

25 years ago, have you operated any other



Q.   Have you operated any other businesses?

A.   No.

Q.   Have you had any other source of income

personally since then other than through --

A.   No.

Q.   -- the Faith Cathedral Fellowship?

A.   No.  I haven't taken any income from

Faith Cathedral Fellowship, if you are talking

about personally.  Are you talking about me


Q.   Yes, sir.

A.   No.  I haven't had any income at all,

and that has been checked by the IRS themselves.

They came out here and asked me about that,

checked me out.

Q.   When was that?

A.   1988.

MR. CHAPLIN:  Skip, can you give me a

second?  I need to confer with my client just one

minute, if you don't mind.

MR. UTSEY:  Well, I have already told

him that under the rules if you-all confer I can

question him about your conference.

MR. CHAPLIN:  Okay.  That's fine.  Can I

just say something to him in front of you?

MR. UTSEY:  Yes.

MR. CHAPLIN:  Please listen to the form

of the question and just answer the question.


Q.   Was that the same time that the IRS

contacted Paul or you about the status of Faith

Cathedral Fellowship that they also contacted you

about your personal income?

A.   It was in the general same time, yes.

Q.   And was that the Federal IRS?

A.   Yes.

Q.   Did it also involve the State Department

of Revenue?

A.   No.

Q.   And did Paul deal with that issue as


A.   All I know is they came to see me.

Q.   Oh, okay.  You actually got an in-person


A.   Yes.

Q.   And who was it?

A.   They sent two agents out, two IRS

agents, and they asked me a simple question.

Q.   What was that?

A.   How come you don't pay no income tax.

Q.   And did that resolve the issue?

A.   Yes.

Q.   Is that the only time that they made any

such inquiry of you?

A.   Yes.

Q.   Do you have an accountant for the


A.   Just my wife.  She is our accountant.

Q.   Is she actually an accountant or a

bookkeeper or what?

A.   She is very good at it.

Q.   Well, does she have any formal training,

I guess is what I'm --

A.   No.

Q.   How long has she been in that position

of accountant or bookkeeper?

A.   Ever since we were married.

Q.   So the entire life of Faith Cathedral

Fellowship, has she been the person that has

handled that end of it?

A.   Yes.

Q.   Does she have an official title with

Faith Cathedral Fellowship?

A.   No.  She is a vice president of the


Q.   That is kind of what I'm driving at.

Who is the treasurer of the corporation?

A.   I would say she is the treasurer, yes.

Q.   Has there ever been anyone else who has

handled the books of Faith Cathedral Fellowship

other than Teresa?

A.   No.

Q.   Have the books ever been subject to any

sort of external audit by an accounting firm or


A.   No.

Q.   Have you ever used a CPA firm or any

other outside accountant with respect to Faith

Cathedral Fellowship?

A.   No.

Q.   Help me with the understanding of the

officers, the current officers and directors of

Faith Cathedral Fellowship.  Are you the


A.   I am the president, and the vice

president, and we have a chairman of the board and

we have -- I forget how many board members there

are, seven or eight.

Q.   Let's talk about the officers first.

You said you are the president and you believe

Teresa is the vice president?

A.   Yes.

Q.   And also the treasurer?

A.   Yes.

Q.   Does the corporation have a secretary,

to your knowledge?

A.   Yes.

Q.   Who is that?

Margaret Moratto.


Margaret Maratto passed away a couple of weeks ago


Q.   I saw her name in some of the answers to

interrogatories and whatnot, but I wasn't clear on

whether she was a secretary in the sense that she

was an employee who did secretarial functions or

whether she was a corporate officer secretary?

A.   She is just a corporate officer.  We

don't have any employees.

Q.   And what are her job -- or what are her

responsibilities, rather, as a corporate


A.   She just stays in the office.  She

answers the phones.  She helps with the mail.  She

takes the minutes in special meetings that we

have, like secretaries do.

Q.   Does she maintain official corporate

records such as minutes of annual meetings,

resolutions, that sort of thing?

A.   Yes.

Q.   How long has Margaret Moratto been in

the position of secretary?

A.   20 years, at least.

Q.   And since she became secretary, has

anyone else functioned in that office?

A.   No.

Q.   Have you always been the president of

the corporation?

A.   Yes.

Q.   And has Teresa always been the vice


A.   Yes.

Q.   Are there any other corporate officers

aside from -- we will talk about the board of

directors in a minute.

A.   Just the board.

Q.   Let's talk about the board of directors.

Who is the chairman of the board?

A.   Chris Gingrich.

Q.   Can you spell his last name?

A.   G-r-i-n-r-i-c-k (sic).

MR. CHAPLIN:  Say it one more time.

THE WITNESS:  Chris Gingrich,

G-r-i-n-r-i-c-k (sic).

Q.   I have seen the name Brother

Christopher.  Is that the same person?

A.   No.

Q.   How long has Chris Gingrich been the

chairman of the board?

A.   Ever since we started.

Q.   And he resides where?

He resides over in Bamberg County.

Q.   Who are the other members of the board?

A.   Dave Moratto, Timothy Jones, Rick Bell.

I have to think for a minute.  That is four.

Christopher is not on that, right?


Q.   Are you a member?

A.   Yeah.  I'm a member, and my wife is a

member, and the secretary is a member.

Q.   Margaret?

A.   Yes.

MR. CHAPLIN:  Moratto.

Q.   Is Dave Moratto Margaret's husband?

A.   Yes.

Q.   That is seven.  Is that everybody?

A.   I can't think of any more right now.

Q.   Is there anyone who has ever been a

member of the board who is no longer a member of

the board?

A.   Not that I know of, no.

Q.   Have all of the current members of the

board always been members of the board since --

A.   Yes, yes.

Q.   -- the fellowship was founded?

A.   Well, no.  Some of them came -- when we

first started we didn't have a full board.  And

then as time went on we got the board membership.

Under the original charter it was just me and my

wife, but then we got the board later on as we


Q.   I understand.  What is the function of

the board of directors?

A.   We report to them on what we are doing,

why we are doing it, and what our purpose of the

ministry is all about.

Q.   And other than receiving these reports,

does the board of directors do anything with

respect to the Faith Cathedral Fellowship?

A.   Whatever needs to be done.

Q.   Give me an example.

A.   Well, right now I don't know what answer

you are looking for because the board, they can

discipline me, which they did.  They have

disciplined me in the past, or they question me.

I have to give an account of what I'm doing.  They

know how we operate and what our functions are.

Q.   Help me understand the structure of

Faith Cathedral Fellowship.  I mean, I understand

that you have the officers that we have just

discussed and the board of directors.

And, again, this is a question of total

ignorance as far as how this church is organized.

I can have a preconceived notion because of the

church I have always attended is set up one way

and yours is probably different, so I don't know

how to compare them.

Are there employees at all?

A.   No.

Q.   No employees.  Is there a church

discipline, or is there some structure within the

church as far as who is the head of the church?

A.   We have the bylaws, the church bylaws

that have been incorporated, and we function by

the bylaws.

Q.   Are those the corporate bylaws or are

they different?

A.   Corporate bylaws.

Q.   Other than that, is there any sort of

text which deals with how the church is organized

and operated?

A.   Only according to the Bible.  We use the

scriptures through our discipline.

Q.   So the head of the church under your

bylaws is whom?  And I'm not talking about God.  I

am just saying the head of it.

A.   I am the president of the corporation.

Q.   And how does that translate into terms

of your role as minister or pastor, if at all?

A.   I just pastor, preach.

MR. CHAPLIN:  Do you understand the


THE WITNESS:  Not quite, no.  I mean, I

am the head of the organization.

MR. CHAPLIN:  Let him rephrase it.

Q.   I understand the corporate organization

and your role as president, but I also

understand -- and we haven't really talked about

it -- but I also understand that you preach?

A.   Well, in the religious source you have

spiritual leaders, too.  You have men who are

elders in the church.

Q.   Well, that is the structure that I'm --

A.   Well, most of those men are elders just

like they are the board of directors.  They are

our leaders of the church.  They are what we call

the governing body.

Of course, that is in the spiritual

realm.  We recognize them as what they are, and we

use their advice and we call them in for judgments

and decisions.

Q.   Is that the same as the board of

directors, or are there different people that

comprise the --

A.   Well, some are the board of directors.

There are others who are not.  Like Christopher,

who you are going to see this afternoon, he's not

on the board of directors, but he is definitely

one of our elders.

Q.   Okay.  Well, that is what I am trying to

drive at.

A.   We have -- all the men on the board are

what we call also spiritual leaders, and they help

make the judgments that need to be done in the


Q.   The spiritual leaders, is that the same

as elders?

A.   Elders are deacons.  Most churches have

elders or deacons.  But we don't give those

offices, but we just recognize them as men who are

spiritual in that position.

Q.   So if I use the term spiritual leaders,

that would be that category of people -- I want to

use the right term.  You used the term elders, and

I didn't know if you were just using it in the

colloquial sense or whether it's specific to your


A.   First of all, we don't have a membership

type of anything, so our men are recognized among

us by virtue of being there.  These are men that

have been around who put their life into it, for

instance Chris Gingrich, for 30 years.

Q.   Are they elected to these positions?

A.   No.  We don't elect them.

Q.   How does someone become a spiritual


A.   By recognition, by being faithful.  You

just abide by the --

Q.   Who are the spiritual leaders?

A.   I mentioned them to you.  Most of them

are the board of directors.

Q.   But are there others?  You said, for

instance --

A.   I just mentioned also Christopher

Landry.  He's a spiritual leader.

Q.   That is Brother Christopher?

A.   Yes.

Q.   What is his last name?

A.   Landry.

Q.   Anyone else?

MR. CHAPLIN:  Excuse me.  Can you find a

breaking point?  I want to try to call Judge James

Mack at some point.

MR. UTSEY:  Sure.  Let me just get this


Q.   Is there anyone else who is among this

group of spiritual leaders whose names we haven't

already discussed as the board of directors?

A.   Yes.

Q.   Who else?

A.   Joe Klein would be one of them.  Of

course we have Pastor Timothy already.  How many

do I have up there?  Jonathan Keiser would be one

of them.  Al, I don't know his last name.

MR. CHAPLIN:  Do the best you can.

A.   Dennis Larivee would be one of them.

Q.   Can you spell his last name?

A.   L-a-r-v-i-e (sic).

Q.   Are there others?

A.   We have a community up here with about

70 some people, 70 some.  Let me see.  And we

honor each other as brothers and give each other

credibility as they live among us.  I guess you

could call them all spiritual leaders if you

wanted to.

Q.   Right.  I am not calling anybody

anything.  You used the term spiritual leaders, so

I was trying to make sure I understood who you

were talking about.

A.   We don't operate in a realm of picking

out somebody and saying -- if you are a man and he

works and he's faithful and he's a brother, we

respect his opinion, we respect his judgment, and

we respect his -- they have all put their life

into this, just like I put mine into it, and they

all have an accountability to each other.

MR. UTSEY:  We will take a break so you

can make your call.

MR. CHAPLIN:  Thank you.

(A recess was taken.)

Q.   Again, this is probably me trying to put

a square peg in a round hole, so to speak, because

I'm trying to understand the structure of your

church, using as a backdrop my understanding of

how the churches I have been affiliated with are

structured, but it may not be a good comparison.

Does your church have one or more

pastors or ministers or priests, or whatever title

they are supplied?

A.   Yeah.  We have at least three pastors,

and we have men who operate -- I don't know how

you would call it.

Q.   What do you call them?

A.   They get up and preach.  Well, one is an

evangelist, two are pastors, one is a teacher.

And I'm more recognized as the prophet, which most

of your churches won't recognize.

Q.   Right.

A.   But we recognize the prophet ministry.

We have teachers.  We have pastors who operate --

and that's in the spiritual sense.  That comes

form a spiritual extent.  That is not something

you go to school and learn.  It's a spiritual gift

that God gives people, which is mentioned in the

Bible, pastors, evangelists, teachers and

governments, and even some who minister with the

Ministry of Health.

Q.   Help me with names for each of those

people.  You are the prophet, is that correct?

A.   Yes.

Q.   And there are pastors?

A.   Pastor Timothy Jones is one.  I would

say that Al -- I can't think of Al's last name.

MR. CHAPLIN:  We can get it to him.  Go


A.   Dave Moratto is an evangelist.  Jonathan

Keiser is a teacher.  And then we have many other

men who preach.  I don't know.  I mean, I can't

give you a whole list of all the men who preach.

I mean, many that come in and preach are from

outside, inside.

Q.   I got you.

A.   In fact, one of those fellows right

there used to preach.

Q.   What fellow right where?

A.   Tim Butler.

Q.   Oh, one of the plaintiffs?

A.   Yes.

Q.   Are any of these official titles that

are documented somewhere in church documents?

A.   No.

Q.   It's just the way things are developed

and people go into where their talents lead them?

A.   Right.

Q.   Now, does Faith Cathedral Fellowship

have meetings, formal meetings other than worship


A.   What kind of meetings are you talking


Q.   Church business meetings, for example.

A.   If we need them, we call them.

Q.   And when you have those type meetings,

who attends?

A.   Anybody that wants to that belongs to --

that lives on the grounds.

Q.   Are there documents generated --

A.   We haven't had any yet.

Q.   Oh, you haven't?

A.   No.  We don't have to have them because

there is no need for them.

Q.   Why not?

A.   Because we just have services.  We

don't -- business is taken care of with the board

if we have it and that's it.

Q.   That is what I was trying to understand.

So the board is really the business -- I know you

are not operating as a traditional business, so

I'm not trying to add some connotation to this

that is not there.  But the business end of things

is the board?  Is that fair to say?

A.   They understand and know what is going

on, yes.

Q.   Now, you mentioned --

A.   Of course, we are very open, I can tell

you that.  Everything that goes on up there

everybody knows.

Q.   You mentioned that the board has a

disciplinary function and that it has disciplined

you in the past.  Explain that to me.

A.   Yeah.  A few years ago I committed

adultery and they disciplined me, and I'm still

under discipline.  I'm not allowed to go anywhere

by myself.  And, of course, you know about that.

Q.   Well, you may be assuming more than is


A.   No.  You know about the case.

Q.   Now, tell me about that.  You said a few

years ago.  When was this?

A.   Four years ago, about four years.

Q.   About four years ago.  Is this the only

time that the board has disciplined you?

A.   Yes.

Q.   What was the nature of the discipline

other than you can't go anywhere alone?

A.   Well, I wasn't supposed to -- I had to

be more careful about how I dealt with each

individual, you know, to be careful about my life.

That was all.

Q.   Now, how was this disciplinary decision

reached?  Was it at a formal board meeting or


A.   Sure.  We had a church meeting and then

we had a board meeting.


They did not have a board meeting


Q.   What is a church meeting?

A.   Well, when that came down, we called

everybody together and --

MR. CHAPLIN:  Excuse me one second.

Skip, in light of the fact that the matter that we

are talking about is on a 40J status, I am going

to object to this line of questioning.  I think

that this has been put on hold until the case is


MR. UTSEY:  I think it's -- it's still


MR. CHAPLIN:  Okay.  If you want to go

forward with it, that's fine.  I just wanted to

put that objection on the table because I think

that the focus of the cases that are -- for the

purpose of the depo today, none of them have to do

with where you are at right now.

MR. UTSEY:  I understand that, but I

think under the rules of discovery, unless it's

privileged, I have a right to ask him about it.

MR. CHAPLIN:  And I think that the 40J

matter suggests that that is off the docket and

probably not the purpose of today's meeting.

MR. UTSEY:  Your objection is on the



Q.   There was a church meeting, you said,

with respect to this issue?

A.   Yes.

Q.   When was that held?

A.   Sir, I don't have those dates in my


Q.   Approximately when was it?

A.   It was about four years ago.

Q.   And when you say a church meeting, you

mean what?  Who attended?

A.   Every person on the land at that time

attended except the children.  And what took place

was I made the confession of what I had done, and

from then the board took care of it and we made

some stipulations.

And I was told to be careful who I

talked to, where I went, and make sure I always

had somebody with me.

Q.   Other than your confession, did the

church meeting consist of anyone else saying or

doing anything?

A.   Saying or doing anything?

Q.   Presumably, when you say you gave a

confession, you stood up and confessed to what you

had done wrong?

A.   Correct.

Q.   Other than that, did anyone else say --

for instance, did people that were in attendance

say here is what I think about it or --

A.   Sure, some of them did at that point in


Q.   Was the church meeting recorded in any

way, whether minutes were prepared or --

A.   No.

Q.   -- audio recordings or anything?

A.   No.

Q.   Any documentation that relates to that

church meeting?

A.   No.

Q.   Is there a list of who attended that


A.   No.

Q.   What was it that you said in your

confession there?

A.   I told them what sin I committed.

Q.   Right.  And that was it?

A.   That was it.

Q.   So I committed adultery?

A.   Yes.

Q.   Did you discuss details?

Not very much, no..

Q.   And then you said the board dealt with

it from there.  Was there a separate board


A.   Yes.  We had several board meetings

after that.

Q.   Were minutes prepared with respect to

those board meetings?

A.   Not those specific ones, no.

Q.   Why not?

A.   Because they were church issues.  We

weren't dealing with the organizational structure.

We were dealing with church issues, religious


Q.   With respect to your discipline from the

board, are there any documents of which you are

aware that relate to that?

A.   No.

Q.   All of it was oral?

A.   Yes.

Q.   Were there any recordings made of any of


A.   No.

Q.   And you say you are still under

discipline.  What do you mean by that?

A.   Well, we set up a rule at that time that

nobody would go off the grounds or anywhere by

themself, we would always have somebody with us.

And we all still abide by that.  We all abide by


It's just to be a little safer.  We are

watching for each other's soul and each other's

way.  So whenever anyone goes off the ground or

does anything, they have someone with them.

Q.   And that applies to everyone there?

A.   Just about, yes.  I don't know of

anybody that goes off the ground -- in fact,

nobody is ever told to go off the ground without

somebody else with them.

Q.   I understand.  Well, then is there

anything in addition to that that you are subject

to, individually, that you would call discipline?


Q.   Now, tell me about the instance of

adultery.  Who was the person?

A.   I don't want to answer that.

Q.   I understand you don't want to, but, I

mean, I have a job to do and --

A.   Right.  It has nothing to do with this


Q.   I understand that, but you still have to

tell me.

A.   Tell you what?

Q.   The name of the person with whom you

committed adultery.

MR. CHAPLIN:  Skip, I think that the --

the objection I raised states that the two cases,

or the name would be the plaintiff in that matter

that we brought 40J.

MR. UTSEY:  I understand that.  But the

rules say that the only way the witness can

refrain from answering the question is if it's the

subject of attorney-client privilege, and it's not

of a privileged matter, so I have a right to ask

about it even though it may or may not be

admissible at trial later on.

Q.   So, anyway, back to the question.

THE WITNESS:  Do I have to answer that?

MR. CHAPLIN:  Yeah.  Just give him the

answer.  If it continues we are just going

to --

THE WITNESS:  What answer am I supposed

to answer?

MR. CHAPLIN:  Give him the name.  And if

this continues we are going to have to take a

stronger stance.  Go ahead.

Q.   With whom did you commit adultery?

A.   Stacey was one of them, Stacey Belford.

Q.   And there were others?

A.   Yes.  There was one more.

Q.   Who was that?

Laquiela Jones, at that time.

Q.   With Ms. Belford, was this a

consensual --

MR. CHAPLIN:  Skip, I'm sorry.  We are

going to have to --

MR. UTSEY:  Well, if you are going to

file a motion for protective order, then we can

file a motion for protective order and deal with


MR. CHAPLIN:  Okay, then we have to deal

with it.  Because I thought we were coming here

today to talk about the cases that were on the

docket that we needed to address.  And right now

what I feel like is you are pulling a fast one.  I

don't think that this is appropriate.

We should not be talking about cases

that are not on the docket at this present time.

They are not even of consideration.

MR. UTSEY:  Well, but it's discovery,

and this could lead to discoverable material and

it's a credibility issue.

MR. CHAPLIN:  When I prepared him for

his deposition I told him the cases that we would

be discussing, and I did not tell him we would be

discussing the cases where the adultery was an

issue.  And, I mean, because I didn't -- because

they are on 40J.  They are a 40J motion that we

both agreed to.

MR. UTSEY:  I understand that.  But, for

the record, I think anything that might tend to

lead to discoverable evidence with respect to

these cases, including issues of credibility and

matters of where he has been disciplined by the

church of which he's a member, are clearly

relevant to those issues.

MR. CHAPLIN:  However, and you --

MR. UTSEY:  Here is what needs to

happen.  If you are going to instruct him not to

answer any further questions on this, then the

rules are pretty clear about your obligation to

file a motion with the Court seeking a protective

order and then we can have this discussion with a

judge and deal with it down the road.

MR. CHAPLIN:  That's fine, and I think

we should.

MR. UTSEY:  If that's what we are going

to do, at least we can move on to another subject,

if that is your intention.

MR. CHAPLIN:  Okay.  My intention is to

file a motion for protective order.

MR. UTSEY:  Okay.  So you are going to

instruct him not to answer any further questions

on this topic?

MR. CHAPLIN:  That's correct.

MR. UTSEY:  Then reserving all rights,

we will move on to another topic.

Q.   Other than that episode of being

disciplined by the board, have you ever been

disciplined by the board or any other authority

within the Faith Cathedral Fellowship?

A.   No.

MR. CHAPLIN:  And, Skip, can we make

clear what the topic is that I'm instructing him

not to answer questions on?  Not on disciplinary

action, but based on the 40J -- cases that are on


MR. UTSEY:  If you are instructing him

not to answer, I think you need to make it clear.

MR. CHAPLIN:  Okay.  I just want to make

sure you and I understand.

MR. UTSEY:  What are you instructing him

not to answer?

MR. CHAPLIN:  Cases with regards to

plaintiffs whose cases have been placed on a 40J


MR. UTSEY:  Okay.

MR. CHAPLIN:  Which we did not come here

today to discuss.  We are not preparing for trial

for those.  Those are on the back burner, so to


Q.   Who is the custodian of corporate

records with Faith Cathedral Fellowship?

A.   Custodian?

Q.   Is there one person that maintains the

corporate records?  If I wanted to get them, who

would be the best person to go to to get them?

A.   Probably me.

Q.   Does that include minutes of the board

of directors meetings?

A.   Yes.

Q.   Does it include financial records?

A.   Yes.  I would be the one to authorize


Q.   And does that include corporate records,

things that you filed with the state, that sort of


A.   We don't file with the state.

Q.   Well, to obtain the corporation status.

You had to have had a --

A.   I have all of those records, yes.

Q.   Now, you said something about

authorizing what, financial expenditures?

A.   I didn't say anything about that, that I

know of.

Q.   Oh, okay.  I said something about does

that include financial records, and you said, yes,

because I would have authorized it, or I may have

misunderstood you.

A.   Yeah.  I am the one that authorizes what

is spent and what is not spent, yes.

Q.   Is there anyone else in Faith Cathedral

Fellowship that has the authority to dictate what

is spent and what is not spent?

They all do, if they want to.

Q.   Does anyone else exercise that


A.   No.  They trust me.

Q.   Does the board have to approve your

decisions with respect to expenditures?

A.   No.

Q.   Does it, in fact, do that?

A.   No.  They could if they wanted to, but

they don't need to.

Q.   So in terms of what money Faith

Cathedral Fellowship spends, you are the one

making those decisions?

A.   Basically, yes.

Q.   Well, basically suggests that is not a

yes, or not a complete yes.

A.   Yes.

Q.   It is a yes?

A.   Yes.

Q.   Okay.  Have you ever been arrested?

A.   Here?

Q.   What I'm seeking to find out is any time

you have ever been arrested anywhere, I want to

know about it.  You were arrested in Colleton


A.   Yes.

Q.   And charged with what?

THE WITNESS:  We are going back at this


MR. CHAPLIN:  Right.  Uhm --

MR. UTSEY:  Well, this is different,

though.  This is clearly, under the rules, related

to questions of witness credibility.

I am asking him about the charge.  I am

not asking about the details of what happened.  I

am asking what he's been arrested for and charged


MR. CHAPLIN:  And I would object to that

as asked and answered because I think that you

have that information already.  In the discovery,

I think we provided that.

MR. UTSEY:  Well, I still have the right

to ask him about it.

MR. CHAPLIN:  Well, to your best

knowledge answer the question.

A.   I was arrested in Colleton County, two

charges of second-degree sexual assault, which had

to do with the adultery, and one that has to do

with breach of trust, and one that has to do

with --

THE WITNESS:  What was that burial


MR. CHAPLIN:  Just that's your

testimony.  Just go ahead and describe it that


Q.   The fourth charge dealt with a burial?

A.   Yes.  We had to bury a child.  And I

don't know what they called it, unlawful burial,

whatever it was.  And they have all been disposed

of, which you already know, don't you?

Q.   I have some knowledge of it, but I may

not have full knowledge, and that is why I'm going

to ask you --

A.   I am sure the court can give you a

record on it.

Q.   And you can, too.  But, see, I don't get

to testify at trial, and that is why I need to ask

what you understand about this.

What was the disposition of the two

charges for second-degree sexual assault?

A.   They were dismissed or put away with or

thrown out.  I don't know what word is used.

MR. CHAPLIN:  I think you were

appropriate when you said dismissed.

Q.   Did you plead guilty or not guilty to

those charges?

A.   I didn't plead either way.

MR. CHAPLIN:  They were dismissed.

Q.   What was the disposition of the breach

of trust charge?

A.   Same thing.

Q.   What was the disposition of the burial


A.   Same thing.

Q.   Did you reach any type of plea agreement

with respect to any of the charges that were

pending in Colleton County?

A.   Yeah.  They had me agree to a simple


Q.   And did you plead guilty to that?

A.   I sure did.

Q.   Was that one or two charges?

A.   Let me see.  That was --

MR. CHAPLIN:  If you don't recall, just

say you don't recall.

A.   I don't recall.

MR. UTSEY:  At a certain point -- the

rules are pretty clear that you are not supposed

to be coaching him.  I haven't objected to that up

until now.

MR. CHAPLIN:  Okay.  Objection noted.

Q.   You pled guilty to simple assault.  And

who was the victim of that simple assault?

A.   The two young ladies.

Q.   Belford and Jones?

A.   Yes.

Q.   Did you plead guilty to anything else?

A.   No.

Q.   Have you ever been arrested at any other

time in your life?

A.   I was arrested in Savannah many years

ago for bill of trover.  That's what they used to

call it.

Q.   And what did you understand that related


A.   I bought an organ.

Q.   A what?

A.   An organ, and it wasn't any good, and I

didn't pay for it, and until I returned the organ

they arrested me.  They either wanted the organ or

the money or me.  So they arrested me until I

returned the organ.  And I had to go get the

organ, and when the organ was returned the judge

was satisfied.

Q.   Was that a civil action?

A.   I don't really know.  I just know the

sheriff came out.

Q.   Do you know whether you ended up

pleading guilty or not guilty?

A.   I didn't plead nothing.  When the organ

was returned, they just turned me loose.

Q.   And were all charges dismissed?

A.   If there were any charges at all.

Q.   So, in other words, you didn't have to

satisfy any criminal penalty, whether it be

incarceration or fine or anything like that?

A.   No.

Q.   What year was that, approximately?

A.   I don't recall.  I can't --

Q.   When were you in Savannah?

A.   It all was around 25 years ago.  It

might have been 30 years ago, somewhere along in

there.  That was even before I even moved to

Savannah, so it might have been 32 years ago.

Q.   Have you ever been arrested at any other

times in your life?

A.   Yes.  I was arrested one time in


Q.   What was that all about?

A.   What did they charge me with?  Do you

know what they -- I don't know what --

(Telephone rang.)

MR. CHAPLIN:  Can I take it in your


MR. UTSEY:  Yes.

(A recess was taken.)

Q.   I was asking you about the arrest in


A.   Yes.

Q.   Do you remember what the charge was?

A.   I was thinking -- I think they called it

outrage and public decency.

Q.   And did you understand what the

circumstances were that led to that charge?

A.   Yes.

Q.   What was that?

A.   A little girl said I made a gesture at


Q.   And what happened with that charge?

A.   They were dismissed.

Q.   Did you plead guilty, not guilty?

A.   It didn't even go to court.

Q.   But did you ever have to file a plea?

A.   No.

Q.   Did you pay a fine or anything like


A.   No, just dismissed and told me it was


Q.   And where was that in Oklahoma?

A.   Muskogee.

Q.   And how long ago did that happen,


A.   45 years.

Q.   Oh, okay.  It's been a long time?

MR. CHAPLIN:  How many years?  I'm

sorry.  I didn't hear that.

THE WITNESS:  45.  At least 45, I would


Q.   Other than the arrest in Oklahoma that

we just discussed, Savannah that we previously

discussed and Colleton County that we have

previously discussed, have you ever been arrested?

A.   Huh-huh.

Q.   That is a no?

A.   That's it.

Q.   I am trying to make sure your answer is

clear for the record.

A.   No.  I wasn't arrested anyplace else.

Q.   Other than the one instance of

discipline by the board of Faith Cathedral

Fellowship, have you ever been disciplined by any

other church with which you have been affiliated?

A.   No.

Q.   Have you ever been treated -- these are

standard questions.  Have you ever been treated

for any type of substance abuse?

A.   No.

Q.   Or addiction?

A.   No.

Q.   Have you ever been treated for any sort

of mental or emotional problems?

A.   No.

Q.   Do you have a family doctor?

A.   No.

Q.   Do you get medical treatment at all?

A.   No.

Q.   When is the last time you received

medical treatment?  Never?

A.   No.

Q.   Dental work?

A.   Yes.

Q.   Do you have a dentist locally?

A.   Yes.

Q.   Who is that?

A.   Dr. Rhoades.

Q.   Have you ever seen any other health care

provider other than Dr. Rhoades?

A.   No.

Q.   Have you ever been involuntarily

committed to any type of institution?

A.   No.

Q.   Have you ever been a party to any civil

action other than those initiated by my clients?

A.   Yes.

Q.   Tell me about those.

A.   We had a farm in Alabama, and a fellow

tried to take it from us that was living on it,

and it was resolved.

Q.   Where was that?

A.   Let's see.  What county was that in?  It

was down near Auburn.  I can't think exactly where

it was.

Q.   And you said we had a farm.  Who is


A.   Someone gave the church a farm, and we

let somebody live on it, and he wanted us to sign

it over to him because he thought that we --

Q.   And so --

A.   So he sued us.

Q.   He sued you?

A.   Yes.

Q.   He sued the ministry?

A.   Right.

Q.   And it was resolved how?

A.   The judge made us -- we gave him back

his $25,000 that he gave, and then put him off the

land and we got the farm back.

Q.   So it did end up going to court?

A.   Yes.  It went to court.

Q.   When was this?

A.   I don't remember the dates.

Q.   Approximately?

A.   Five, six, seven, eight years ago.

Q.   Does the church still own that farm?

A.   No.

Q.   What happened to it?

A.   We sold it.

Q.   When was that?

A.   About the same time.

Q.   To the same individual or to someone


A.   No.  We sold it to somebody else.

Q.   Is that the only other time that you

have been involved in a civil lawsuit?

A.   Yes.

Q.   Have you ever been involved in any

litigation in probate court?

A.   No.

Q.   Have you ever been involved in any sort

of quasi-judicial administrative actions?

A.   No.

Q.   How does Overcomer Ministries -- what

income does it have?

A.   I'm not sure if I understand your


Q.   Well, does Overcomer Ministries have

income?  Does it have money that comes into it?

A.   Yes.  People give us offerings.

Q.   Does it have any other sources of


A.   No.

Q.   And, generally speaking -- I have got

some computer printouts that we will talk about in

a moment that your attorney has turned over.

But, generally speaking, what categories

of expenditures does Overcomer Ministries have?

What does it spend its money on?

A.   Radio broadcasting.

Q.   Anything else?

A.   And maintaining of the facilities up

there on the farm.  That's it.

Q.   How long have you been in the radio

broadcasting business?

A.   All my life.

Q.   And so the entire time that Faith

Cathedral Fellowship has been in existence, one of

the expenditures it has had has been radio?

A.   Yeah, the biggest ones, yes.

Q.   And what type of radio?

A.   All kinds.  What is on the radio?  I

mean, what do you mean by that?  I don't

understand the question.

Q.   I mean, is it commercial radio,


A.   No, no.  We are not commercial at all.

Nothing is commercial.

Q.   I understood something about shortwave

radio that I know very little about there.

A.   Shortwave radio is like any other radio.

You buy time on the stations and you pay them for

the time that you broadcast on them, and that is

what we do.

We buy time from stations in America and

we buy shortwave time in different parts of the

world.  We pay for satellites, any forms that get

the signal into the stations, and that is what we

pay for.

Q.   I guess that is what I meant.  When I

said commercial radio, would it be on AM bands or

FM bands?

A.   AM, FM, shortwave, Internet, satellite,

whatever source that they use.  We use all of


Q.   So you said satellite, for example.  I

understand there is like XM radio or Sirius radio?

A.   No.  Satellite sends a signal to other

parts of the world, or any part of the world.  It

uses satellite to send a signal.

Q.   I see.  And so you pay whoever owns the

satellite or manages the satellite?

A.   We pay many stations.  We pay people who

own the satellite.  You have to pay them for it,


Q.   Same with the Internet?

A.   Yes.

Q.   Now, is there documentation related to

what your charges are for that air time?

A.   We have the records of every dime ever

spent, every record to every station anyplace in

the world, yes.

Q.   So, in other words, if you had received

an invoice from Station X for the air time, would

you have that?

A.   We have the invoices, we have the

canceled checks, the payments.  They are all paid.

Q.   I noticed in the -- and I'm sort of

jumping ahead of myself, but these account

printouts that your attorney provided, one of the

line item expenses is radio.  And, as you said,

it's probably the largest expenditure?

A.   Yes.

Q.   Under that line item of radio, is there

anything included other than the air time itself

that you purchase?

A.   Well, there are things that have to do

with the signal satellites and the air time you

purchase and the facilities you use, yes.  It's

all included in the --

Q.   That is what I'm driving at.  What all

is under that heading of radio?

A.   I just explained it to you.  We have

satellite, Internet, and we pay the station for

the time.  We pay the people who provide the

satellites.  We have to pay them.  And we have to

pay for the Internet serving, the T-1 lines and

things like that.

Q.   Are there any other aspects of the radio

broadcast that fall under that expense category on

your bookkeeping?

A.   Not as far as air time, no.

Q.   For example, do you have a studio, or do

you rent a studio or what?

A.   We have a place.  On our farm we have

our own radio facilities.  We have our own


Q.   And when you purchased that equipment,

how is that expenditure handled?

A.   It's probably listed down some way.

Either computer or radio or some way it's listed.

Q.   That is what I'm trying to figure out.

I am trying to break down these categories on your

expense list, and I'm wondering if radio includes,

for example, any equipment?

A.   We could go into radio and we could tell

where every dime went, whether it went for the

computers in the radio room or whether it went for

the printing of -- yes, we could.

Q.   How would you do that?

A.   How do we do what?

Q.   How would you go into it to find that


A.   Well, the computer has the categories.

The bookkeeping has categories.  If we spend

$1,000 for radio, and then you went to the

category and say this was spent for the computer

room, and this was spent for the satellite uplink,

and this was spent for the --

MR. UTSEY:  Okay.  Well, let me go ahead

and mark this document as Plaintiffs' Exhibit 1.

(Plaintiffs' Exhibit No. 1 was marked

for identification.)

Q.   For the record, Exhibit 1 is a group of

documents which appear to be computer printouts

which your attorney furnished to me.

The dates appear to range from the year

19 -- it's hard to read some of them because they

were faxed -- 1992, I believe, through 2004.  Can

you identify that?

A.   Sure.

Q.   What is it?

A.   It's our bookkeeping record.

Q.   A printout of the bookkeeping record?

A.   Right.

Q.   Do you know what type of software you

use to maintain these records?

A.   On this one right here we might have

used -- we have changed them often.  We might have

used Money Accounts on this one, and now we have

QuickBooks, I think.  I would have to go back and

check and see which one.

Q.   So that if you were to -- let's don't

talk too much about the printout itself, but let's

talk about what is on the computer.

If you were to pull up a screen to see,

for example --

A.   It would be that.

Q.   January 1 through December 31, 2004,

You would have something that looks like that


A.   That is the report that would come out

from the screen.

Q.   And then if I wanted to see an

itemization under an expense category --

A.   No problem.

Q.   -- what would you do, click on that


A.   Yeah, click on it and print it out.

Q.   Are those itemizations per category

contained within Exhibit 1?

A.   This is the report.  I don't know what

you are asking me on that one.

Q.   Let's look at the top page, which is

January 1 through December 31, 2004.

A.   Right.

Q.   The first expense item on that list is


A.   Right.  That has to do with the farm.

We could tell you what we spent for the animals.

That is expense.  That is what we pay for the

animals, or feed or something like that.

Q.   Right.  So let's say -- and I'm just

using this one as an example to help understand

how this is formatted in the computer.

I see that for the total year $12,100

was spent on animals, correct?

A.   Right.

Q.   And if I wanted to know, well, was that

purchasing feed or was that --

A.   Yes.

Q.   -- veterinary care, or whatever the

expenditures might have been, what would I do from

this page to find that out?

A.   You would punch up animals and we would

search out the categories.  It would tell you what

was spent for it.

Q.   Can you generate a printout or a report

of that category?

A.   Yes, I'm pretty sure.

Q.   Does Exhibit 1 contain that type of

printout, or is it just the overall printout of

each category?

A.   This is the report that we asked for.

We could ask for a report on something else and

get a report on it.

Q.   So if, for example --

A.   For instance, I have right here some

reports that she pulled out this morning that have

to do with certain things.  In fact, every one of

those people right there, I have a report of

what -- of their records right there.

Q.   You have them with you?

A.   Yeah, but I am not going to give them to

you right now.

Q.   Well, why not?

A.   Because they are for my benefit.  If the

time comes and we need them, we can give you that


Q.   Okay.  The time will probably come

either today or later.  I don't know.

A.   Good.

Q.   When we started this discussion I was

asking you about radio.  What you are telling me

is that if we needed to see where each penny was

spent on --

A.   Every dime, every check.

Q.   You could generate reports for that?

A.   Absolutely.

Q.   Okay, good.  Who is the individual that

maintains the documentation in the computer

program?  Is that Teresa?


MR. UTSEY:  Are those notes or are

those --

MR. CHAPLIN:  No.  You know what, you

can have these.

MR. UTSEY:  -- actual printouts?

MR. CHAPLIN:  No.  These are notes,

personal notes.  And, I mean, we could call this

privileged, but it's nothing that we are going to

try to hide.


MR. UTSEY:  We will get to it in a


MR. CHAPLIN:  Okay, fine.  There is no

problem with that.

THE WITNESS:  She just wanted to inform

me on that.

MR. CHAPLIN:  I understand.  That is

going to come up anyway, and I think we should be

forthright with that.  Thanks for bringing that.

Q.   Does Faith Cathedral Fellowship have a

policy with respect to the return of any offerings

or donations?

A.   No.

Q.   In the past, has Faith Cathedral

Fellowship ever returned some or all of anyone's

donations or offerings?

A.   Yes.

Q.   How were the decisions made to do that?

A.   I make the decision.

Q.   And on how many occasions have you done


A.   Oh, eight or ten.

Q.   Did any of them involve individuals

other than people who have brought these lawsuits

and the man in Alabama who the judge told you to

return his $25,000?

A.   I sent money back to a lot of people,

and I've refused a lot of offerings at times.

Q.   Under what circumstances have you

returned some or all of the person's offerings?

A.   When I felt like they weren't really

giving it.

Q.   What do you mean?

A.   Well, they would give you some money,

and I felt like they weren't giving an offering,

they were trying to buy a service or something,

and I don't sell any service.  I wouldn't receive

their offering.

Q.   Are there any other reasons that you

have ever returned an offering?

A.   No.  The only time I have returned an

offering is when people who came and lived with us

and then they left.  I would never send anybody

away empty.  I would always make sure they had


Some came with nothing and I sent them

away with some offering.  Because I felt like if

they no longer wanted to live under our status,

and they were going back out there, I wouldn't

send them out without some money, and I didn't do


Q.   In any of those instances have your

decisions been approved by or otherwise reviewed

by the board of directors or anyone else?

A.   Sure, every one of them.

Q.   So would there be board meeting minutes?

A.   No.  We just -- like I say, we are very

open up there.  We discuss all the things all the

time, and they all know what goes on and what

happens and how it happens.

Q.   So that would be more of an informal

discussion than a meeting?

A.   Yes.

Q.   I notice that in some years you have got

a net income and some years you have a net loss.

In those years where you have a net loss, how do

you make up for the shortcoming?

A.   It's what was left over from the

previous year.

Q.   Just used as retained earnings?

A.   Sure.

Q.   And so in those years where you have net

income, you just retained those earnings to offset

any future losses?

A.   All the offerings come in and go into an

account.  Some years you took in more than others

and other years you didn't take any.  It's just

like a monthly thing.

Some months you take in more than you

paid out, and other months you don't take as much

in as you pay out.

Q.   So it balances out in the long run?

A.   Right.

Q.   When you say it comes into one account,

is that a bank account?

A.   Yes.

Q.   And what bank would that be?

A.   Right now it's Walterboro bank.

Q.   Bank of Walterboro?

A.   Yes.  There was Enterprise Bank.

Q.   How long have you been with Bank of


A.   Four or five years.

Q.   And the account is listed under what


A.   Faith Cathedral.

Q.   Is your name also on the account?

A.   Yes.

Q.   Individually?

A.   Uh-huh.

Q.   Why is that?

A.   Because I'm the one that exercises the

business.  I am the one authorized by the board

and the corporation to handle the business.

Q.   So you write the checks, or sign the

checks at least?

A.   I sign the checks and my wife signs the


Q.   How many different accounts do you have

with the Bank of Walterboro?

A.   We have a savings accounts, we have a

checking account, we have a CD.

Q.   And do you have accounts, at present,

with any other banks?

A.   Yes.

Q.   What other type accounts?

A.   We have a money market account with

Tidelands Bank.

Q.   Where is that?

A.   It's in Summerville.

Q.   How long have you been doing business

with Tidelands?

A.   Maybe two years.

Q.   Any other accounts with Tidelands?

A.   No.

Q.   Any other accounts with any other banks?

A.   No.

Q.   Do you have any investment accounts?

A.   With those banks.

Q.   Those same banks?

A.   Yes.

Q.   What type of investment accounts?

A.   Tidelands Bank is the money market

account.  We have a CD with Walterboro.  That is

the investments.

Q.   Oh, okay.  I'm sorry.  I meant any type

of investment account where you would invest in

securities or that sort of thing?

A.   No.

Q.   How about you personally?  Do you have

any bank accounts?

A.   No.

Q.   And I think you told me earlier that you

don't draw a salary or any other pay from Faith

Cathedral Fellowship, is that correct?

A.   No.

Q.   Is that correct?

A.   Correct.

Q.   Do you receive income from any other

source personally?


Q.   How do you provide for your day-to-day

needs in terms of a place to live and groceries

and --

A.   The church provides me with a house and

food and clothing.

Q.   Anything else?

A.   That's all I need.  I don't even need

that almost.

Q.   And the house it provides, is it on what

you have been describing as the farm?

A.   Yes.  It's on our farm.  It's an old

house that they tore down and rebuilt me a little


Q.   Just so the record is clear, we have

talked about the farm several times.  Just to make

sure, can you state for the record what you have

been referring to when you talk about the farm?

A.   We have -- our Faith Cathedral

Fellowship runs a community farm where we have

people who live, just like you would in a

monastery, or people have given up their personal

ambitions to live together as Christians, and we

have all things in common, like is spoken of in

the scriptures, and that is what we do.

Q.   And it's located where?

A.   In Canadys.

Q.   How large is the farm?

A.   It's about one hundred and, oh, twenty

to thirty acres.

Q.   And what sort of structures are on the


A.   We have mobile homes.  We have a

tabernacle.  We have a dining hall.  We have farm

barns and equipment.  It's a farm.  It's a regular

organically type farm.  We grow our own food, and

we live together like a regular family, and no one

is compelled to stay or no one is invited to come.
       Q.   Now, other folks who live on the farm --

and I don't say other folks.  I am talking about

your expenses being paid by Faith Cathedral

Fellowship.  How about the expenses of the farm

with --

A.   Everything is paid by the ministry.

Q.   So anyone who lives there, insofar as

their food, their housing or their clothing --

A.   Is all provided by the community.

Q.   -- is paid for by the community?  Now,

are there requirements that if you are going to

live there that you have to give up anything?

A.   No.  This is the way we live.  If they

want to come here, they understand that when they

come they put whatever they have into the


Q.   That is what I'm asking.

A.   Because that is what sustains them,

their time, their work, their effort.

Q.   Let's say that somebody wants to join

that community --

A.   You can't join us.

Q.   When I say join, I guess move to the

community, move to the farm.

A.   We bring them there for a couple of

days, for a week or two and visit, and then see if

they can live with us, that we can live with

them.  We explain to them how we live here.  And

if they agree to it, and they all do, then they

can live with us.

Q.   And if that hypothetical person owns a

house, has a bank account, an automobile, can they

keep those things in their personal name?

A.   Not and live with us, no.

Q.   So if they choose to live with you, what

do they do with those things?

A.   They donate it all to the church, or

somebody else, get rid of it.  I had a lady some

time ago that came in from Arkansas, and another

man just moved in from Augusta, and he had a

house, and he said, well, what should I do.  I

said, give it to -- what do you want to do with

it?  I said, do you have children?  He said, yes.

I said, just give it to the children, so he gave

it to the children.  The woman in Arkansas, she

gave it to her children.

Q.   So, basically, they need to divest

themselves of those possessions to be consistent

with the philosophy of --

A.   If they want to live with us, yes.

Q.   I had asked you a little bit about

returning of donations to anybody a few minutes


Have there ever been instances where

somebody has donated, say, a house or other

property to Faith Cathedral Fellowship and then

decided that they didn't want to continue living

on the farm?

A.   Sure.

Q.   In those instances, have you ever

returned their property to them?

A.   I didn't have their property.  I had

their money, but not their property.

Q.   What happens when someone donates

property to Faith Cathedral Fellowship?

A.   We sell it.

Q.   And you keep the proceeds?

A.   I haven't had too many instances like

that, though.

Q.   Did any of those incidents involve any

of my clients?

A.   That had property?

Q.   Right.

A.   That they bought?

Q.   Or that you sold?

A.   No, not that I know that they had

property that they donated to us, no.

Q.   Did any of them own property that they

sold and then gave the proceeds of the sale to

Faith Cathedral Fellowship?

A.   Yes.  In fact, every one of them you

have there, I am sure they had resources, and when

they came they sold and brought us the money, or

gave us the money.  And some gave us the money

before they even came.

You have one right there.  Mr. Tim

Butler was in debt to the IRS and to the State of

Ohio because he wouldn't pay taxes.  He's a

patriot.  So when he came here, for six months I

took the money from him that he worked and then I

paid his debts for him.  I paid his debt.  He

don't record that, but we paid his debt.

Just like the General, when we paid his

debt, because we don't believe in having debt.

None of our people have debt.  So if they come and

they have debt, we try to get them out of debt and

we help them get out of debt.

And if they are able to work, we let

them work until they -- and then when Tim Butler

left, not only did we pay his debt, we gave him

$30,000 cash.  Plus we gave him a motor that we

paid for, $12,000.

And we gave him -- he backed up his

truck and loaded up a pile of food to take with

him.  So these are things that we gave back, sure,

because -- yes..

Q.   I am going to get to each one of them

individually in a minute, so I don't want you to

have to tell me twice.

But I noticed on Exhibit 1 that one of

the line items is return offering.  What is that?

A.   I mean, sometimes people give us an

offering and then after awhile the situation

develops where I didn't believe that it was an

offering and I return it back to them.

Q.   Does that include circumstances like you

were just describing with Mr. Butler when he --

A.   No.

Q.   Where would those be documented on here?

A.   Where would what be documented?  It

might be under that category.  I would have to go

home and look under the category.

Q.   I am curious about any instances where

an individual has joined your community but then

left and you have given them any portion of their


A.   We have done that, yes.

Q.   And what I'm curious about is, looking

at Exhibit 1, under which of these expense

items --

A.   It might be under return.  Well, that is

not enough.  It would probably be under their own

name or something.

This is the general expense report here.

This is not an individual report.  If you want a

report, we can get a report for each one of those


Q.   Okay.  Well, I do see that their are

some names, for example, on the first page of

Exhibit 1, and maybe that will help explain things

for me.  I see Edward Fernandez children, or


A.   We have child for -- he has a child

support obligation.  We pay child support or give

him the money to pay it.

Q.   And that is consistent with your policy

of not having debt for any of your --

A.   Right.  Anybody who lives with us, if

they have obligations we take care of them.  We

work together.  Just for instance, he takes care

of our dairy farm up there, and so we just -- if

anybody has any debt, we take care of it.

Q.   I understand.  Then I see Mueller is one

person on here.

A.   Who is that?

Q.   M-u-e-l-l-e-r.

A.   He's not with us no more.

Q.   Well, there is a line item --

A.   Yeah, but what happened, he turned in

$12,000 that he had for child support.  That is

what he did.  And we kept the $12,000 and we went

to the state of Michigan and we made a deal to pay

his child support off because he owed them child

support, and we took his money and we paid his

child support.  He turned it in to us and then we

took it and paid the child support.

Q.   So the line item for $13,652 in 2004

would have been the payment of the child support?

A.   Right.

Q.   What is the personal line item on this?

A.   That is probably things that I get for

me personally or my wife, family.

Q.   Which it's not a lot of money,

obviously, but that is like clothing and whatnot?

A.   Yes.

Q.   Anything else that would be under that


A.   No.

Q.   I see there is a line item for Vernelle


A.   Sister Bush used to live there with us.

She is dead now.  She just died.

Q.   Why would --

A.   We have certain people who live with us

that they have an income, and we keep a separate

record for every person's income that they turn

in, and she was one of them.

Q.   When you say income, what do you mean?

A.   They got checks, Social Security checks,

retirement checks, people who got income.  There

are some people that come there that are retired

and they turn in their income.

Q.   So that's why you would be getting, for

example, $914 for several months from Vernelle

Bush?  I imagine it's Social Security.

A.   Her Social Security every month was

right around $900 for a long time, yes.

Q.   Why would there be an expense for

Vernelle Bush?

A.   Because she might want something.  She

might want something and we buy it for her.

Q.   How about -- I see under the income side

Chris Gingrich?

A.   Yes.  He's been on the farm for 30


Q.   And what income --

A.   He gives his retirement funds.

Q.   How about Lois Anderson?

A.   She gives her Social Security check.

Q.   Peter Scott?

A.   Peter Scott, he doesn't work anymore,

but when he did work he turned in his money.

Q.   He worked outside of the community?

A.   Yes.  We have people who work sometimes

out of the community.

Q.   This says Rios Tony, or maybe it's Tony


A.   He's not with us anymore.

Q.   What income did you have from him?

A.   He had support for children that was

given to him.

Q.   Larivee Dennis?

A.   Dennis Larivee.

Q.   Dennis Larivee.  I'm sorry.  What income

did -- actually, it's a negative income.

A.   He doesn't have any income anymore.  He

used to, but he doesn't anymore.

Q.   WQIZ is listed as an income?

A.   Yes.  We used to own WQIZ radio.

Q.   And the income would be what?

A.   We didn't get no income from WQIZ, that

I know of.

Q.   I am looking at the second page of

Exhibit 1.  It reflects in June of 2003 $199,660.

A.   Oh, we sold the station.  We sold the


Q.   That is what I meant.

A.   Yeah, the income.

Q.   That was the proceeds of the sale?

A.   Right.

Q.   There is a line item under the income

portion that says outside work.  Is that the

people who work outside of the farm?

A.   Yes.

Q.   And their income is accounted there, is

that correct?

A.   Right.  In other words, they work

outside, and they bring their paychecks back home

and they give it to the church.

Q.   Do you remember a gentleman named Geoff

Steeby, S-t-e-e-b-y?

A.   Yes.  He used to live with us for quite

awhile and he moved back to Michigan.

Q.   What expenditures would have been

incurred on his behalf?

A.   I would have to go check the records.

Q.   You can't tell from looking at Exhibit


A.   No.  He -- how much?  It couldn't have

been too much.

Q.   A couple of hundred dollars a month for

several months.  I'm looking at Page 32, which is

2002. I see his name on it.

A.   I would have to go back.  Geoff has been

gone for quite awhile in Houston.  I don't think

we paid child support for him.

Q.   I see it also in 2001.

A.   He has been gone for about four years,

so --

Q.   And in 2000.  How about Gary Hinton?

A.   Gary Hinton was a young man who came

here.  He was in debt.  And, again, our brothers

went out with the work and we took our money and

paid him out of debt.  That was one of the fellows

that came with nothing and went away with $6,000.

Q.   Terry Peters?

A.   Gary Peters?

Q.   Terry Peters.

A.   Oh, Terry Peters.  He still is with us.

Q.   What expenditures would you be incurring

on him?

A.   Whatever he needs.  It might have been

some money we sent to his wife, for his family.

I'm not sure exactly of the expense.

Q.   Now, looking at the income portion of

these reports, there is one line item for

offerings, and then just beside that is one for

mail.  What does that mean?

A.   That is offerings, too.

Q.   That is what I was wondering.

A.   Well, we have offerings that come in

through the mail and offerings that people just

give to us, like you do with contributions.

Q.   So mail would be mail receipts of


A.   Yes.

Q.   There is a line item for checks

returned.  What does that mean?

A.   Checks returned?  I can't tell you.  I

am sure it might be something we sent back to

people, or refused or whatever.

Q.   An offering you refused?

A.   Yes.  Or sometimes they give us a check

and it would bounce, so we would have to send it

back.  And so you show in the record that it's not

in the income anymore.

Q.   One item, I'm looking here specifically

at the 2001 summary report, it says left


A.   Yes, people that left the community, we

would give them some money.

Q.   And that would go under that line item?

A.   Yes.  I'm pretty sure you could find it

under that line item.

Q.   I notice that there are legal expenses

that are incurred periodically.  For what would

the Faith Cathedral Fellowship be incurring legal


A.   The only legal expense we have is when

we hired Mathias Chaplin and -- our friend right


Q.   Right.  And for what purpose, this


A.   Yes.  No, not this one.  We had the

previous lawsuit, the criminal charges.

Q.   The criminal charges as well?

A.   Yes.

Q.   And they are not large amounts.  But

going back in time, we have legal from time to

time as a recurring expense, and it might only be

a couple of hundred dollars here and there, and

I'm just curious what type of legal work that

Faith Cathedral Fellowship would be needing?

A.   We had the lawyer over in Alabama and we

had Paul, but Paul didn't get much.  There can't

be too much legal expense because we didn't have

any other legal expense, that I know of.  We had

to pay the lawyer in Alabama, and I think it was

$2,000 and that was it.

Q.   Did Faith Cathedral Fellowship pay for

the expense of defending you in the criminal


A.   Yes.

Q.   What year was that?

A.   That was four years ago.

Q.   Well, I see in the year 2001 that there

were legal expenses incurred of over $130,000.

A.   That is when we started the criminal


Q.   And then in 2002 you had legal expenses

of over $340,000?

A.   Because we had to put up the bond.

Q.   For?

A.   For the same charge.  You have to put up

a bond.

Q.   Did they get reimbursed to you at some


A.   Yes.

Q.   And that would be reflected on the

income side?

A.   Yes.

Q.   How much was the bond, do you recall?

A.   Had a cash bond of $200,000 and we had

a -- what do you call it, a surety bond?

Q.   Surety bond?

A.   Yeah, surety bond.  The total bond was


Q.   And do you know where that would be

represented on the income side of the balance

sheet here?  Would that be under reimbursements?

A.   I don't really know.

Q.   Now, with respect to my clients, I know

from the discovery responses I received from your

attorney that, at least insofar as Butler, Duval,

Hartley and Lindsey, you have stated that you have

given them some money when they left the


A.   Sure.

Q.   Are those payments reflected on any of

the documents that make up Exhibit 1 right there?

A.   I am sure they are someplace in here

that they were given out.  That is where we got

the records from right there.  There is somewhere

that we could produce the record of each one of

those persons, the money given back to them.

Q.   We are just not positive, sitting here

today, which one of the expense categories those

would fit under?

A.   No.  I'm not sure.  Probably return

funds somewhere.

Q.   Like, you know, we have left community

is one item.  Return offering is another item.

A.   I will tell you this, that if you need

those records, we can get them for each

individual.  We can print out a record for each

one of them.

Q.   Okay.  Now, let's talk individually

about some of these clients, the Allabys.

A.   The Allabys never lived here with us.

Q.   Okay.  I just want to talk generally

about each one of them.  We will take them one at

a time and your relationship with them.

When did you first become acquainted

with them?

A.   As far as dates, I can't give you a

date.  The Allabys go way back maybe seven, eight,

ten years ago.

Q.   Tell me that story, as you recall.

A.   The story was they moved to a community

in Canada that had a fellowship with us, or

affiliated with us.  I never owned it.  I had

nothing to do with it.  It was just a satellite

group that had a fellowship with us.



And they moved out there, and they put

their money out there, and then they left.  And

when they left those people up there, whoever the

two men up there who handled it, they never gave

me the money.  It wasn't given to us and they

never lived here with us.

Q.   Did Faith Cathedral Fellowship ever

receive any of the money that the Allabys donated?

A.   Yeah, before they moved to the

community, yes.  They used to send money here like

hundreds of people do.  We have -- people send

money all the time.

Q.   So they donate through the mail?

A.   Yes.

Q.   And do you have any idea how much they


A.   The Allabys gave, between 1995 and 1999,


Q.   What were the dates again?

A.   The dates were between 1995 and 1999.

That is what they gave to us here.  What they gave

up there, I have no idea.

Q.   Do you know whether that is U.S. dollars

or Canadian dollars?

A.   That was U.S. dollars.

Q.   I had a document that you-all produced

that broke it down between Canadian and U.S.  I

think I have an extra copy, actually.

MR. UTSEY:  Make this Exhibit 2.

(Plaintiffs' Exhibit No. 2 was marked

for identification.)

MR. CHAPLIN:  May I see that?

MR. UTSEY:  Yes.

MR. CHAPLIN:  Yeah.  You have some

Canadian money there, too.

A.   When we got Canadian money we put it in

the bank.  We bank deposited it and they send us

how much it is in U.S. currency.  After they run

it through, they send back to us what it's worth

in U.S. currency.  That is what we do.

Q.   That is what I want you to clarify.

This Exhibit 2 here, which is a document I

received from your attorneys, has both Canadian

and U.S. dollars.

It's your belief that once you convert

that all to U.S. dollars the amount is $3,976?

A.   Yes.

Q.   Now, have you ever seen this document,

Exhibit 2, before?

A.   No, I don't think so.

Q.   Do you know anything about who prepared


A.   Probably Sister Margaret.

Q.   Moratto?

A.   Yeah.  She might have done that because

she could have went in and got the records.

Q.   Is there any reason for to you believe

that that is anything other than accurate?

A.   No, no.  When it comes in, Margaret will

write them down and then she will deposit it, and

then the bank tells us what it's worth in U.S.

dollars and then we put that into our records.

Q.   Now, there is no indication on Exhibit 2

that any money was ever refunded to or returned

to --

A.   Not from us, no.

Q.   I mean, is that correct?

A.   Correct.

Q.    Faith Cathedral Fellowship did not give

the Allabys any money?

A.   No.

Q.   Now, do you know whether the Allabys

liquidated any assets and donated any money when

they --

A.   Not to me.

Q.   Hang on a minute.  I am not trying to be

rude, but it's going to make her job really hard

if we are both talking at the same time.

Do you know if the Allabys liquidated

any assets and donated any money from the sale of

those assets when they moved into the Canadian


A.   I don't know.

Q.   With respect to that Canadian community,

what was it called?

A.   Oh, I don't know if they had a special

name at all.

Q.   What did you refer to it as, the

Canadian community?

A.   Yes.

Q.   Where was it located?

A.   Saskatchewan.  It's still there.  As far

as I know the men still have the farm.

Q.   Who are the men that have that


A.   The two men that -- we bought the farm,

I can tell you that much.  But those two men, the

Canadian government would not let a U.S. citizen

own the land, and these two men were supposed to

be our friends, so we put them on and -- I can't

think of their names right now.

Q.   So the purchase price for the farm was

actually paid by Faith Cathedral Fellowship?

A.   Yes.

Q.   How much was it?

A.   $15,000, I believe it was, or


Q.   And you said that that community had a

fellowship with --

A.   Just a fellowship with us.

Q.   What does that mean?

A.   That means they believe what we believe

and supported us and we supported them.

Q.   Were the expenses --

A.   No.  They took care of everything up


MR. CHAPLIN:  Ssshhh.  Let him finish

his question.

THE WITNESS:  I'm sorry.

MR. CHAPLIN:  Sorry about that.  I

didn't mean to ssshhh you like a child.  I am just

trying to make the statement and finish up because

I'm ready for lunch.

Q.   Were any of the expenses of the Canadian

community reflected on the books of Faith

Cathedral Fellowship?


Q.   And was any of the income from the

Canadian community on the books?

A.   There was none.

Q.   There was no income?

A.   No.

Q.   How many people resided up there?

A.   Off and on there might have been three

or four, five or six.

Q.   Now, in respect to the farm here in

South Carolina, or the community here, are there

times that in your broadcast, for example, or your

written word that you encourage people to become

members of the community?

A.   Absolutely not, no.

Q.   How do people learn that you have this


A.   They can go on our Internet site.  I

talk about the farm.  I talk about our community.

People come by and see us.  People come by to


Q.   When you talk about it, what do you say?

A.   I just tell them we are at the farm,

that we live here.  I use the scriptural approach

where we live like the scriptures did in the Book

of Acts.  You-all have all things common.  Nobody

owes anybody anything.

I like to tell them about the effect of

living without debt.  And that is something that

you can say to somebody, 75 people live here and

nobody owes anybody money.  We are all out of

debt.  That is an unusual situation.

Q.   Do you explain that people are welcome

to join the community?

A.   No, no.  There is nothing to join.  I

tell them straight out, you can't join this


Q.   Well, join not in a membership sense,

but join as in a physical sense?

A.   No.  I never invite anybody to do that.

Q.   How do people determine that they can

give up things and move to the community?

A.   They may come for a visit.  They may say

can I come and visit you, or they come to

service.  Then they will say to me, well, how can

I be here?  And I say, well, you really can't.  I

say, we just don't have -- we have nothing to


And then if they persist they would like

to live like that, then I will let them come for a

visit.  Two or three times they come, and if then

they determine they want to abide by the

situation, if they want to do what they want to

do, give up everything, then they do it, and they

come with that understanding.

Q.   So you have some conversation at that

stage of what would be necessary for them to move


A.   Yeah.  If they keep implying that they

would like to live with us I say, do you

understand how we live here?  This is how we live.

Do you want to do that?

Q.   Now, at your website, or anything else

that you publish, whether it's broadcast-wise or

written-wise or anything, have you ever described

the farm in Saskatchewan?

A.   No.  I did when we were affiliated with

them, when they had a fellowship with us, yes.

Q.   Oh, you no longer have a fellowship with


A.   No.  They pulled away from us about four

or five years ago.

Q.   What were the circumstances of that?

A.   I guess the criminal case.  Tim Butler

can probably tell you more about that.

Q.   Was there anything written by them or

by --

A.   We had no legal ties whatsoever.

Q.   I understand.  But, I mean, did somebody

write you a letter, for example, saying we would

like to sever our fellowship?

A.   Yeah.  One of the gentlemen up there

just called me one day and said we are not going

to have anything more to do with you, and that was

the last I heard from him.

Q.   And you are thinking that was about four

years ago?

A.   Yes.

Q.   Prior to that, how long had they been in

fellowship with Faith Cathedral?

A.   Two or three years.

Q.   During that two- or three-year period,

is that when you would have talked about that farm

and your Internet broadcast?

A.   I talk about different communities that

fellowship with us, even now, in different parts.

We have one group of people up there in North

Carolina who are pastors.  We have a group of

people over there in Kentucky.  We have a group of

people out in Oklahoma.

And just like a church.  I would say we

have fellowship over there.  If you want to attend

church there, you may do that.  It's just like you

advertise services in different locations around

the world.

Q.   Right.  But I began this discussion when

we started talking about the Allabys and the fact

that they moved to the farm in Saskatchewan.

A.   That was their desire.

Q.   But during the period when they moved

there, were Faith Cathedral Fellowship and that

farm in fellowship together?

A.   Sure.

Q.   And during that period was Faith

Cathedral Fellowship discussing the farm in

Saskatchewan on its website and in another --

A.   We have mentioned that we have a

fellowship up in Saskatchewan, sure.  That is how

they found out about it.

Q.   And did you describe what the farm was

like up there and what the principles were behind


A.   No.

Q.   You didn't say, like you did here, that

people give up everything to live here and --

A.   No.

Q.   What did you say?

A.   I just told them if they want to visit,

they can go visit.  That is what the Allabys did,

as far as I know.  They went out there to visit

and decided they wanted to live out there.

Q.   Do you know how long they stayed there?

A.   Maybe a year, year and a half.  I don't

know.  One day they left and they were gone.

Q.   Do you know why they left?

A.   I guess they didn't want to live there

any longer.

Q.   But did you know anything more about

their decision?

A.   They probably didn't like the situation.

Q.   What situation?

A.   Whatever situation, how we were living

there, the situation with the people.

Q.   I understand.  But I am not asking you

to speculate.

A.   There was no specific thing that I know

of, no.

Q.   That is what I'm asking, whether you

knew of any specific reason.

A.   No.

Q.   Do you know whether the individuals who

were running the farm in Saskatchewan returned any

money to the Allabys?

A.   I have no idea.

Q.   Have you had any contact with the

Allabys since they severed their ties with that


A.   No.

Q.   Have you ever offered to reimburse or

return any money to the Allabys?

A.   No.

Q.   Have they ever asked you to?

A.   No.

Q.   So it's just never been something you

had to decide whether to do or not to do?  Is that

fair to say?

A.   When they left, they left.

(Plaintiffs' Exhibit No. 3 was marked

for identification.)

Q.   Let's talk about the Butlers now.

MR. CHAPLIN:  Can I interrupt one


MR. UTSEY:  Yes.

MR. CHAPLIN:  When do you think we are

going to have lunch?  Because I have quite a few

questions that I want to follow up with as well.

MR. UTSEY:  Well, we have to go through

all the plaintiffs, so it's going to be a little

while.  I didn't know if you wanted to push

through and then take a lunch break, or go ahead

and take a lunch break and -- I don't care one way

or the other.

MR. CHAPLIN:  Well, can we just think

about it and kind of set something up?  I need to

return a few messages.  I would like to have some

lunch.  But I just wanted to work with you.  I

don't want to break your flow here.

MR. UTSEY:  It doesn't matter to me.  I

mean, if you want to take a lunch break now, we

can take a lunch break now and then resume until

we finish, or we can keep going for a little while

and then take a lunch break.  I'm flexible.

MR. CHAPLIN:  Because the depositions we

have after him, they are on standby.  They know

they need to be here today.

MR. UTSEY:  Right.

MR. CHAPLIN:  So if we could take a

break now, that would be great.  Until when?  I

mean, since you are at a different climate, or a

different person.  You are getting ready to move

to a different person now, right?

MR. UTSEY:  Yes.  It's a good time.  We

will take a break and go off the record.

(Lunch recess taken.)

Q.   I told you I was going to ask about what

you did at lunch and who you saw.  I want you to

tell me.

A.   I saw my wife and I saw Mr. Landry.

Q.   Did you have any conversations with

anyone concerning the deposition?

A.   Yeah.  We talked a little bit about the

bookkeeping situation.

Q.   Who did you discuss that with?

A.   My wife.

Q.   Did you learn any additional information

aside from what you and I have already discussed?

A.   Only that we can get you all the records

that you need, that has to be done.

Q.   Did you determine what type of software

program is used for that?

A.   Money Count.

Q.   Money Count?

A.   No, QuickBooks.

Q.   Okay.

MR. CHAPLIN:  She is in the lobby now,

by the way.

MR. UTSEY:  Yeah.  I met her a minute


MR. CHAPLIN:  Okay.  So we don't have

any lag time.

MR. UTSEY:  Okay, good.

Q.   Did you learn any other information in

your conversation with her?

A.   No.

Q.   Did anyone give you any suggestions

about how to answer any questions for the

remainder of your deposition?

A.   No.  I guess that would have been me

giving them suggestions.

Q.   Well, I can ask them about that.

A.   Yeah, sure.

Q.   Okay.  We have talked about the Allabys,

and I think we were getting ready to discuss --

A.   I explained that to you, if you remember

that.  That is Canadian funds.

Q.   Right.  We have already finished --

A.   When you break that thing down, it's

about $1,500 less than that in U.S. currency.

Q.   Which is about the number you gave me?

A.   Right.

MR. CHAPLIN:  So you had that confirmed

while you were at lunch?


Q.   You did confirm that?

A.   Yes.

Q.   All right.  Now we know where the

numbers go.  Let's get this one out of the way.

Unless you need these, I am just going to move

them so they don't confuse you.

A.   I don't need them.

Q.   Tell me about -- I want to talk to you

now about the Butlers.  How did you first become

acquainted with them?

A.   On the radio.

Q.   Pardon?

A.   They heard me on the radio.

Q.   When did you first speak with them?

A.   I don't know dates.  I can't give you


Q.   Do you know approximately when that

would have been?

A.   Well, it was somewhere around '97, '98,

somewhere along in there.

Q.   How did you first have contact with

them, by telephone, in person, what?

A.   Yes.  They started to support us, and

they started to call, and then they wanted to come

for a visit and they came for a visit.

Q.   When you talked to them on the

telephone, do you remember any of the

conversations you had with them?

A.   Not particular, no.  There was nothing

particular about it, except maybe just the

ministry, what I preach and what I talk about.

Q.   Do you remember specific comments that

you made to them or they made to you in those


A.   Not on the phone, no.

Q.   So you-all arranged for them to visit

the community here?

A.   They wanted to come for a visit, so we

let them come for a visit.

Q.   And that would have been the farm here

in Colleton County?

A.   Yes.

Q.   And do you remember when that was?

A.   No, I don't remember the dates.  I'm

sorry.  I just don't remember dates.

Q.   And that's all right.  And you

understand I need to ask, because until I ask I

won't know what you do know.

A.   I can find approximate dates, but I

don't remember them.

Q.   Tell me the circumstances of their


A.   When people come for a visit we give

them a place to stay, and they live with us like

we live here.  They go out and we start working,

what we do on the farm, and they talk to the other

people and they find out how we live.  This is how

we do it.  We all work together.

We produce our own food.  We grow our

own crops.  We very seldom have to go buy anything

because we produce everything.  We have our own

ability to farm.  We have our own ability to

repair cars.  We have our own carpenters.  We have

electricians.  We are a self-sufficient


And we don't need any money outside.  We

have people on that farm that haven't gone off the

farm in 15 years.  Don't have to.  I don't go off

it.  Mag (phonetic) said to me this morning, wow,

we haven't seen you in awhile.  I stay on the


Q.   Right.

A.   And they come and they live and they see

what we do, and then they go back.  That is the

procedure we have always used.

Q.   How long was the Butlers' visit?

A.   A week or two.  You mean to live?

Q.   No, no, when they first came.

A.   Oh, about a week.  When I let the

Butlers come I broke my rules.  I don't mind

telling you.

Q.   What do you mean?

A.   Because I let them come with debt.  They

were in debt.  He owed the IRS $60,000 and he owes

the state of Ohio $30,000, or something in that

area.  Because he wouldn't pay -- he was a

patriot.  Do you understand what I mean when I say

a patriot?

Q.   Someone who claims that they don't have

to pay the government?

A.   Pay taxes, right.  And that is what he

was, and he didn't pay taxes.  He didn't do it.

When he came to me I said, wait a minute, we pay

taxes.  We don't do that.  We are not going to

play that kind of deal.

So I initiated a contact with the IRS

and with the State of Ohio and we worked out a

settlement plan on how to pay his debt, which was

a great savings, to tell you the truth.


I did the initiating at the suggestion of Mr. Stair. I owed the IRS 42,000 and Ohio 5,000 and we was able to get the IRS reduced to 11,700 I believe.


But when you do that, when you make a

deal with a federal agency like that, if they

agree to a certain amount they will say you have

ten days.  That's the reason why he couldn't pay

his debt, because he couldn't come up with that

kind of money, but because he was part of the

community and we took the responsibility, we took

the money and we paid his debt.

And so then whatever he earned, he

contributed just like everybody else did.  But we

paid that particular debt because one of our rules

is no debt.

Q.   Now, you had some note cards with you a

minute ago.

A.   I don't -- oh, I wish I knew -- did I

leave them here?  Because I don't know what

happened to them.  I thought I left them here.

Q.   Well, I was just going to ask you about

these amounts because you said them so quickly.

A.   We have the amounts.  We have the

amounts.  We gave Tim Butler back in cash.

Q.   I am going to get to that in a minute.

The amounts that you just were saying a moment ago

about his indebtedness --

A.   Yes.  I would have to go home and find

out how much we paid.

MR. CHAPLIN:  Well, what did you say a

minute ago?

Q.   You said something about the State of

Ohio and --

A.   He owed the State of Ohio income tax.

He owned the IRS income tax.

Q.   Do you know how much?

A.   It was around $60,000.  I don't know the

exact figure.

Q.   All total?

A.   The IRS.

MR. CHAPLIN:  I thought you said 90.

You said 60 and 30.

A.   Yeah.  The IRS was around 60 and the

State was about 30, I think it was.  I can't be

exact on that because I don't know, but it was in

that bracket, and we paid both of them off.

Q.   How much did you pay to pay them off?

A.   I think -- like I'm saying, you are

asking me for figures that I can't come up with

right off.

MR. CHAPLIN:  He said ballpark.

A.   I would say about $30,000 for the IRS,

which was reduced from $60,000, and the State


And what I had Tim Butler do -- he was a

truck driver.  And you understand when these

people come to live with us, we pay all of their

living expenses.  They don't have to buy no food,

no clothes, no gasoline for their cars, none of

those things.

The church -- they live with us.  Their

life becomes that way, and that is how we do it.

And whether you give much -- did you see that

young man that stood right at that door there?

Did you see him?

Q.   Yes, sir.

A.   That young man gave $2 million, sir.

He's not asking for it back.

Q.   Well, I am just talking about Mr.


A.   I am trying to tell you what these

people do, whether you come with nothing or

whether you come with everything.  Whatever you

have, you give it, just like me.

For 25 years I have given.  What do you

think a man like me would be worth if I was a CEO

in a large corporation?  Could I make a $100,000

salary?  Patch (phonetic) over here does, why

can't I?  But I don't.

We even pay taxes on the farm up there.

As a church we don't have to, but on a certain

part of it I agreed to pay taxes.

MR. CHAPLIN:  Let's go back to Butler.

That was --

A.   Well, Butler came.  And he was a truck

driver, so I kept him driving the truck so we

could get his money.  I took his money, put it in

the church's account, and then we took it and paid

the debt.

Q.   I am getting a little off track, because

I was kind of going through this chronologically.

I was talking about their first visit, which I

think you said --

A.   The first visit, they worked around on

the farm and then they went home.  They went back

to Ohio.

Q.   During that visit, is that when you

broke your rule and agreed to accept someone with


A.   No, no.  When he first came I wasn't

sure I wanted to have him come live with me

because he had a bunch of young children,

teenagers, and teenagers are trouble, especially

if you bring them in and they are not used to this

kind of -- and his boy became very much


You see, if you bring a teenage son with

you, he comes because you are coming.  He's not

coming because he wants to be there.  Can you

understand that?

Q.   Yeah.  I understand what you are saying.

A.   So when you do that, then after awhile

they don't want to be there and so then they start

causing you trouble.

And at first I said, you have a boy

right here.  I said, you are going to bring him

along and he doesn't want to be here.  And so he

went back home, and later on he conceded that he

would bring his children and he brought them.

They brought the children.  But, like I said, the

boy gave me trouble, gave us trouble.

Q.   During this first visit, did you have

conversations with Mr. or Mrs. Butler about the

prospect of them living there?

A.   They had let me know that they would

like to move there with us, yes.  Anyone that has

ever came on there, after awhile the issue would

come up.

And then I say, well, you want to live

here with us?  Do you see how we live?  Can you

live with us?  You know the rules.  Whatever comes

here -- everybody, everybody, no matter who it is,

you give what you have.  They didn't have to do

it.  They could have kept it.  But they couldn't

keep it and come here.

Q.   Now, are you the person with Overcomer

Ministries that had that conversation with the


A.   Yes, sure.

Q.   Do you know if other people did?

A.   I am sure they talked with the other

people about it.

Q.   Did you explain to them about the rules,

that you give everything up?

A.   Yes.  The rules are written out and the

rules are given to them.  They know the rules.

Every person there knows the rules.

Q.   Where are the rules written?

A.   We even have some papers up there where

they signed.  I don't know whether the Butlers

signed theirs or not.  But we have some people who

would sign, yes, everything, everything they give.

Q.   Now, where the rules are written, what

do you call this document?

A.   It's not a document.  It's just an

understanding that we have amongst each other.

Q.   Is it written?

A.   Not necessarily.  Right now we have some

places where people have signed some documents.

When this thing started to develop, we come up

with a little document.  Now, I would have to go

home and see if the Butlers signed it or not.

Q.   When what thing developed?

A.   This nonsense with these people asking

for their money back, which you don't ever do with

the church.  You give money to a church and you

don't ask for it back.  That is something anybody

does.  Do you give money to a church?

Q.   Since these lawsuits, are you saying

that you developed a document to have people who

live in the community sign?

A.   We wrote a little document so these

people understand fully that they agree to this,

that when you come here that we are not obligated

to give your money back.  You are getting what you

are giving as an offer, just like when you walk

into your church and you lay down your offering.

That is an offering.

Q.   When did you begin having people sign

that document?

A.   I don't really know that either.  I

would have to go back and look at it.

Q.   Who drafted that document?

A.   Probably one of our brothers.  It's just

a little statement that we agree that this is what

we want to do.

Q.   Now, I understood -- and maybe I

misunderstood your testimony a moment ago, where I

thought you said the Butlers had read the rules

because they were in writing?

A.   No.  The Butlers -- nobody reads the

rules.  When they come there I tell them, if you

want to live here, this is what we do, this is

what we believe.

Q.   That is what I'm trying to drive at.  I

want to know what it is --

A.   I explained it to you three or four

times already.  We don't have nobody come with

debt.  You have to be out of debt.  We don't have

debt.  If you have a debt, you can't come.  You

clear out your debt first.  That is a rule.  We

don't buy anything on credit and we don't go in

debt.  Isn't that commendable?  I think it is.

Q.   I am asking you what you told the

Butlers.  Is that --

A.   I told the Butlers what I tell

everybody.  If you want to live here with us -- if

you live here with us, everything you have you

give to the church, everything.  And if there's

anything you need, then we will provide it while

you are here.

And then you work.  You work in the

community.  Whatever needs to be done here, we do

it and we do it together.

And there are certain things we believe

in in the spiritual realm.

We don't run to doctors.  Although, we

do go to doctors if we have to.  If they want to

go, they may go, but most of these people don't

want to go.

Most of them come with their own

opinion, this is what they want to do.  They want

to believe in God.  They want to believe in God

for their healing and for their health and for the


And that is voluntary.  If they want to

go -- they can live any way -- you understand that

I have several hundred people outside of the

community that support us?  And they don't -- they

go to doctors.  They do the things they want to


I don't require them to live like I do,

except if you want to live under our auspices,

this is the way we live here.  That is just the

way we do it.

Q.   And is that the extent of what you

explained to the Butlers during this first visit?

A.   Sure.

Q.   Was there anything else you talked to

them about?

A.   No.

Q.   Did you talk to them at all about what

their offering to the church would be used for?

A.   Everybody knows what the offering is

used for.  I even get on the radio and do that.  I

tell them.  I spend -- 90 percent of the income

goes for the radio broadcast because that is what

this is all about.  This is a ministry that

reaches the world.

My dear friend, while I'm sitting right

here talking to you I could take this phone and I

could talk to the entire world.  God has blessed

me.  God Almighty, Yahweh, has blessed me to be

able to speak to the entire world, and that is

what I do, and I do it very faithfully.

Q.   And did you have any conversation with

the Butlers about the expenditures other than the

90 percent going to radio?

A.   No.  Why should I?  Every bill --

everything up here gets paid.  People know where

it goes.  We tell the people from time to time

about this, we had to buy that, we do this, we do

that.  People know where the money goes.

Q.   But the Butlers were visitors.  That's

what I'm driving at.

A.   No, no.  The Butlers -- when they came,

they knew where the money went.  They knew.

Q.   And how did they know?  That is what I'm

trying to figure out.

A.   What do you mean how did they know?

Q.   Well, someone had to tell them --

A.   Tell them what?

Q.   -- or they had to get the information


MR. CHAPLIN:  Just --

Q.   I am simply asking you was there any

conversation with the Butlers during their first

visit --

A.   Not any more than anybody else, no.

Q.   I am not asking to compare.  I want to

know specifically what you recall about the

conversation with the Butlers about where the

money they donate, or would donate, would go?

A.   No, not any particular.  Not more than

anybody else, no.

Q.   Well, what would you have done with

anybody else?  That is what I'm driving at.

A.   What I tell you, is that we tell the

people all the time here is what we buy, here is

what we do, here is where the money goes.  The

electric bills are so much.  The gasoline bill is

so much.  I bought $12,000 worth of honey the

other day.  I tell the people where the money

goes, and then I can back it up.

Q.   And you explained all of that to the

Butlers in this initial visit?

A.   Sir, we have a common --

MR. CHAPLIN:  Yes or no.

A.   Yes.  Yes, I explained it to them.  They


Q.   Now, I'm not asking what you think they

understood.  I am asking you what you told them.

You told the Butlers --

A.   I didn't tell them specifically any more

than anybody else, but they did know.  They did


Q.   I don't mean to sound like I'm arguing

with you, but you have to remember I understand

you have had conversations with a bunch of people

like this, so it's easy for you to compare your

conversations with the Butlers with other people,

but I haven't been privy to any of those


A.   What I'm trying to say is we have a

major dining room, a fellowship hall, and we have

a meeting room, and it's in those places where we

discuss everything right out in the open all the


For instance, the other day I went and

bought some honey.  And I got back up in the

dining room and I said, today we just spent

$12,000 to buy some honey.  I said, now, you-all

be careful how you use it.

Or we bought some gas the other day

because it's cheaper.  I can buy it -- and

everybody in the community, you can bring any of

them in here and sit down and they would tell you

they have heard how the money goes, where it goes,

even when it comes in, even when it comes in.

Q.   In the initial visit with the Butlers,

did you go through all of the expense items that

would be reflected in Exhibit 1?

A.   No, no, no.

Q.   Did you go through --

A.   No, no, no.

Q.   -- all of the categories that would be

reflected by Exhibit 1?

A.   No.

Q.   At any point did you go through that

with the Butlers?

A.   No.

Q.   Why not?

A.   Because it's not required.

Q.   For example, when we talked earlier you

explained how some people have child support

obligations that the community will pay?

A.   It's understood that when they come

there that all of their responsibilities -- that

every obligation they might have will be taken

care of.

Q.   Did you explain that to the Butlers?

A.   Yes, sir.

Q.   And did you explain to the Butlers that

you --

A.   I explain it to the general population

that --

MR. CHAPLIN:  You have to let him finish

the question, Brother Stair.  I know this has you

infuriated, but let's hear the question.

Q.   During the Butlers' initial visit, that

one-week approximate visit --

A.   Yes, they understood that.  I'm pretty

sure they did.

Q.   No.  I'm not asking what they

understood.  I'm asking what you told them.

A.   Yes.

Q.   You told them that you were paying child

support for some people?

A.   No.  I didn't tell them we were paying

child support for anybody.  What did -- that had

nothing to do with their situation.

Q.   Did you tell them that you were paying

some people for leaving the community?

A.   No.

Q.   Did you tell them that you were spending

money on legal expenses?

A.   No.

Q.   Did you have any subsequent

conversations with the Butlers after that one-week


A.   Not that I can recall.

Q.   How did you know that they had decided

to join the community?

A.   They let me know they wanted to come.

Q.   Pardon?

A.   They just let me know they wanted to


Q.   Was that a telephone call or a letter or


A.   Either a letter or a phone.  I am not


Q.   And when was it that you made the

decision to permit them to come despite the tax

obligation that he had?

A.   I can't recall.

Q.   How did you communicate that to Mr.


A.   Might have been by letter, or phone, or

he might have came to see me.  I really don't


Q.   Did you explain to him, as I think you

characterized it earlier, that you were breaking

one of your own rules to allow him to do that?

A.   Yes.  He knew that.  I told him that.

Q.   As best you can recall, exactly what did

you tell him?

A.   I told him that I was going to let him

come, and that he was to keep on working, and that

we would take his money and we would clear out

this debt, and that is exactly what we did.

Q.   And you told them that was the first

time you had done anything like that?

A.   Sure.

Q.   And I think you indicated you actually

negotiated with the IRS to reduce the lien from 60

to approximately 30?

A.   Yes.

Q.   And did you negotiate with the State of


A.   Yes.

Q.   You said it was approximately $30,000 he

owed the State.  How much did you negotiate that

down to?

A.   I don't really know.

Q.   Where in Exhibit 1 would the payments to

the IRS and State of Ohio on behalf of Mr. Butler

be found?

A.   I don't know that either.  You would

probably have to go back and look under Mr.

Butler's name, and then we would find out what he

gave and what we gave back in reference to him.

Q.   But it would be an expense payment,

though, that would be reflected somewhere on

Exhibit 1, wouldn't it?

A.   Yes.

Q.   Do you remember approximately when it

was that you paid those two debts?

A.   No.

Q.   Do you remember when approximately the

Butlers moved to the community?

A.   I could get the date, but I don't

remember them.

Q.   Let's look at these documents that

comprise Exhibit 1.  I notice that as of 1998, I

guess as of April of 1998, you begin to reflect

income under the name Tim Butler?

A.   Right.

Q.   That would be his earnings as a truck


A.   Yes.

Q.   Do you think, then, that 1998 would have

been when you paid his taxes?

A.   Yes.  That could be the same time.

Q.   Now, I'm looking again on the 1998 page

of Exhibit 1, and under the expenses it says Tim

Butler, and I have got several entries which total

$17,719.  Do you think that --

A.   I am not sure whether that was for the

IRS or what it was.  I would have to go back and

verify that.  We also bought a motor for him at

that time, I think, that cost quite a bit of

       Q.   In 1999 there is an expense line for Tim

Butler which totals $1,503.  Do you know what that


A.   No.

Q.   And in 2000 there is an expense item

totaling $552 for Tim Butler.  Do you know what

that was for?

A.   It might have been for some tools.

That's how much in tools we bought for him to work

on his truck.

Q.   And in the year of 2001 I see a total of

$32,017 paid for Tim Butler.  Of that, one amount

was rounded off to $30,000 in August of 2001.

A.   That sounds like the IRS situation


Q.   Do you believe -- the remaining $2,017

was for what?

A.   I really couldn't tell you.

Q.   Now, you said something about buying a

motor for Tim Butler.  What was that?

A.   He wanted a new motor for his truck.

Q.   Did he own the truck?

A.   Yeah, he owned the truck.

Q.   I didn't know whether he had donated

that to --

A.   No, he didn't donate the truck.  He

would have if I had taken it, but there was no

need for it.  It was tagged in his name.  It was

titled in his name so he could drive the truck,

and so we just left it that way.

But, like anybody else, the income that

came in from it was donated to the farm, to the


Q.   And then the expense for the truck was

paid by the farm?

A.   Yes.

Q.   And that would be the motor, for


A.   Right.  And we would even give him some

money to make his trips, give him cash money so he

could drive on the road.

Q.   Did you pay for the fuel?

A.   Yes, indirectly.  Like I say, we would

give him some -- he would bring his check home,

and we would let him keep a certain amount of that

for his operating expenses.

What I should have done was take it all

and then make him -- then give it back to him.

That's what I should have done.  I goofed on that


Q.   Now, this is Exhibit 3, a document that

was produced by your attorneys to me.  Do you

recognize that document?

A.   Pretty well.

Q.   Do you know who prepared that document?

A.   That looks like Sister Margaret's work.

Q.   Do you know whether it's accurate?

A.   As accurate as it could be on the

figures that she has, because she writes down what

the people do.

MR. CHAPLIN:  Yes or no.

A.   Yes.

Q.   Tell me what these amounts mean.  $2,850

in 1995, is that just a cash contribution or


A.   I would say so, yes.

Q.   Same for those next three items?

A.   Yes.

Q.   And then there is a line that says

working offerings net of expenses.  What does that


A.   I don't know.  I am sure there are some

expenses that are probably involved in that


Q.   Well, those are documented for 1998

through 2001.  Would this be the income he

generated as a truck driver that was paid to the

ministry, net of the expenses of his generating

that income?

A.   Very possible.

Q.   Do you know whether the net of expenses

includes the expenses that were incurred to pay

off his debt?

A.   No.  Those are probably expenses just to

run his vehicle.

Q.   Do you know that or are you just

assuming that?

A.   That there does not -- those figures

don't match up with the debt that we paid.

Q.   Well, wouldn't you need to know how much

income there was in order to know whether it

matches up?

A.   No.  It would have made no difference

how much income.  It wouldn't have made a bit of

difference how much income.  We are determined to

pay the debt, whether he had any income or not.

We would have paid his debt whether he was making

a dime or not.

Q.   Well, I understand that.  What I'm

saying is if these are net figures --

A.   This is probably operating.  If there is

any expense in that, it's probably operation of

the vehicle.

Q.   But do you know that with 100 percent


A.   No.

Q.   Who would know that, Margaret?

A.   We would have to go back and look in the

book, in the bookkeeping.  It would show up in the

records somewhere.

Q.   Well, this reflects total given of

$67,732.  Again, would that be using the net


A.   Yes, as far as I can tell.

Q.   And it says $30,000 returned 8/2001.

What does that mean?

A.   That is the cash money we gave back to

him when he left.

Q.   A minute ago when we were looking at

Exhibit Number 1 we got to the year 2001.  And

specifically in August of 2001 I asked you about a

$30,000 figure and you said that may have been the


Now that you look at this Exhibit 3, do

you think that was the money you returned to Mr.


A.   It could have been.  The IRS figure

might have been put in another realm.  I would

have to look.

Q.   How is it that -- well, let me ask you

this.  You have said earlier that you were the one

that made the decision on how much money to return

to anybody if you ever did return money, correct?

A.   Sure.

Q.   So you decided the $30,000, that you

would pay the $30,000?

A.   Yes.

Q.   How is it that you came up with that


A.   Well, you see, we calculated -- these

brothers out here calculated that the living out

here is about $15,000 to $20,000, if they were

living out someplace else, providing housing and

everything else for them, it would be about

$20,000 a year.

Q.   Who calculated that?

A.   Brother -- Mr. Duval, who was a very

economic man.  He said, when you live on this

farm -- he said, the way we live, he said, it

would probably cost us $22,000 a year if we lived


Q.   22?

A.   Yeah, 20 or 22.  Oh, come on now.

Q.   No.  I just didn't hear you.  I am

trying to hear what you said.

A.   Yeah, 22.

Q.   So what did that have to do with the

$30,000 amount for Mr. Butler?

A.   I just decided to give Mr. Butler some

money back because he had given quite a bit, and I

decided I wasn't going to let him go out without

any money.

Technically, I didn't have to give him

anything.  He gave to the church.  I don't have to

give money back when people donate to a ministry.

You don't have to do that.  That is not required.

Q.   Okay.  I am just trying to figure out

how you came up with 30,000, and not 25 or not 35

or some other number?

A.   No particular reason.  Larry Hartley I

gave 70.  Another guy I gave $5,000.  Another guy

I gave $3,000.  I gave them what I felt like I

could -- so they could get out there and get

started again.

Q.   Is there any other fact that you

considered in determining that $30,000 would be

the appropriate amount to give him?

A.   No.

Q.   Is this the only money that you returned

to Mr. Butler, the $30,000?

A.   Cash, yes, that's the only money


Q.   What else did you give him?

A.   He took tools.  He took the tools we

bought for him.  He took food out of our

warehouse.  He backed his truck up and loaded it

up with food.  What is the value of that?  I have

no way of valuing that.

Can you approximate that value?

A.   No.  How can I approximate?  I mean, I

could guess, but that wouldn't be very well.

Q.   Do you know what the value of the tools


A.   Yeah.  The tools were several hundred

dollars.  I'm sure of that.  Some of those tools

you bought for that truck cost you four or five

hundred apiece.

Q.   Total value of the tools, do you know

approximately what they were worth?

A.   No.

Q.   Did you give him anything else, other

than what you have already told me, when he left?

A.   No.

Q.   What were the circumstances of the

Butlers leaving the community?

A.   Because I committed that sin, and when I

committed that sin I made the confession.  And he

was like some of the others, they thought it was

just terrible that I committed this sin, and it

was.  To commit that sin is a terrible sin, but

it's not any more terrible than anybody else's


But I did commit it, and I got up before

the congregation and I confessed it.  And I have

been willing to walk circumspectly and more

carefully since that time.  And I have not

committed it since then.  Thank God for that.  I

want to stand before God one day and -- I will be

standing before a judge one day, and that is my


Q.   Now, so this was --

A.   You know, Tim Butler was not even in the

open meeting.  He was not even there when I

confessed it.  So you know what happened?  When

Tim Butler came home I called the board together,

and I called Tim Butler in and personally sat

there and told him what I had done.

Q.   What did you tell him?

A.   I told him I committed adultery, just

like I told you.

Q.   What was his reaction?

A.   Well, he didn't like it.

Q.   What did he say?

A.   Well, he tried to throw me out of the

ministry.  He tried to make me quit the ministry.

He wanted to take over the radio work.

.       Q.   What did you think of his reaction?

A.   I just told him you are wrong.  If you

don't like it, that's fine.  I don't think it was

right for him -- man, when you are judging a man

for sin, you have to consider your own sin.  If

he's without sin, let him cast his stone.

Q.   So what was your reaction to his


A.   None whatsoever.  When he decided he

wanted to leave, just leave.  What can I do?

Q.   But when he said that you should leave

the ministry --

A.   It wasn't his place to say that.  We had

other men there.  We have men who have been with

me 30, 40 years that are still there.  Christopher

was there.  There was other men there.  And they

accepted my repentance.  They accepted my

willingness to submit to their judgment, Yulatool


Q.   And when Mr. Butler told you that he

would rather leave the community then --

A.   Leave.

Q.   -- did you say anything else to him at

that time?

A.   I just told him to leave.

Q.   What conversations did you-all have

concerning what he could take with him in terms

of --

A.   None whatsoever.

Q.   Well, you said he left with food and


A.   Yes.  He done that without me even

knowing it.  I didn't even know it.  I just told

him -- I gave him his money.  He went and bought a

car.  The next thing I know he was taking the

tools out of the garage.  He backed up to the

warehouse and took food, and I didn't even notice

that he had done that.  He never discussed that

with me.  He just done it.

Q.   You said you gave him the money.  Did

you have any conversation with him about the


A.   No.  Just gave him the 30,000 and that's


Q.   So he told you he was leaving the

community, and then later you just walked up and

handed him a check for $30,000?

A.   Yeah.  Every person that left, I gave

them some money to leave so that they could go

back out and live.  They had -

Q.   I understand that.  But what I'm trying

to understand is was it a matter of you simply

walked up to him, he didn't say a word, you didn't

say a word, you just handed him a check and --

A.   What are you trying to get out of me,

sir, a specific conversation?  I don't know what

we said.  Here is your money, you leave.

Q.   Was there a conversation?

A.   No, not particularly, except for one

time he didn't want to leave, and I asked him when

he was going to leave, or what was preventing him

from leaving, and he said, what are you going to

do, call the law on me?  I said, no, I'm not going

to do that.  But I said, why hang around?  Just if

you are going to leave, go ahead and leave and

stop --

Q.   What my question is, when you gave him

the $30,000 check --

A.   There was no conversation.

Q.   None at all?

MR. CHAPLIN:  I'm going to object to

asked and answered.

MR. UTSEY:  Okay, that's fine, but that

is not a proper objection.

MR. CHAPLIN:  Why not?

Q.   Was there any statement made by Mr.

Butler at that time or any statement made by you,

or you both just sort of stood there and said

nothing and you handed him a check?

MR. CHAPLIN:  Again, asked and answered.

A.   I don't know what you are asking.

Q.   Did you make a statement to Mr. Butler

about the $30,000 check at any point in time?

A.   No.

Q.   Did Mr. Butler ever --

A.   Not that I know of, no.

Q.   Did Mr. Butler ever make any statement

to you about the check?

A.   No.

Q.   Did Mr. Butler make any statement to you

at any point in time about how much money he would

like to have when he left?

A.   No.  He just said I put thirty -- sixty

thousand in this ministry.  That's what he said,

because he thinks he does, but he really didn't.

He put it in, but he doesn't count what he got

back for putting it in.

Q.   When did this conversation take place?

A.   I have no idea.

Q.   What else happened in that conversation?

A.   Nothing.

Q.   So he simply said that and you didn't


A.   No.

Q.   What else did he say?

A.   I don't know.  I don't know what else.

The decision was made to leave and he left.

Q.   And other than him saying he put $60,000

into the ministry --

A.   He didn't even say that to me.  He

probably -- he said that to somebody else.

Q.   Well, who did he say that to?

A.   I don't know.

Q.   How did you learn of it?

A.   People tell me.  It comes through the


Q.   Who did he tell --

A.   I don't know.

Q.   So you never had that conversation with


A.   No.

Q.   Now, at that time did Mr. Butler still

own his truck?

A.   Yes.  He always owned his truck.

Q.   And he took the truck with him as well?

A.   Yes.

Q.   And he purchased a new car, you said?

A.   After I gave him the money, and he got

ready to leave, the next I know he drove in with a


Q.   Do you know where he got that from?

A.   No.

Q.   Why was Exhibit 3 prepared?  Was it for

this lawsuit?

A.   I'm not sure.

Q.   Have you ever seen a document like this

other than those --

A.   I think when these people started to go,

we went back ourself and started to check exactly

what they did give and what they didn't give.  And

that might have even been one of the reasons why I

made a judgment how much to give them back.  That

is the only thing I can tell you about that.

Q.   So did you have Exhibit 3 prepared

before you gave $30,000 to Mr. Butler?

A.   I don't remember that.

Q.   Well, you said it may have been a basis

for your judgment.  That is what I'm trying to

figure out.  How would we be able to determine if

it was?

A.   It wasn't.

Q.   It was not?

A.   No.  That would have no bearing on what

I gave.  I am a man of God, sir, and if God tells

me to do something, I do it.  And if God said to

me you give him so much money back, even if he

didn't deserve it, I would have done it.

It's just like I said, we would have

paid that man's debt if he never gave a dime into

the place, just like we've done with others, like

I would do with you or anybody else.  If God would

say to me you help that man, I would help you, and

that is a judgment I make.

Q.   I am just trying to understand a comment

you made, so I'm not trying to argue with you.  So

that we are clear, the $30,000 was not a product

of any of the information that --

A.   The $30,000 to Mr. Butler had nothing to

do with him personally or anybody else.  Every

person that came to me, I would make a judgment on

what kind of money I was able to give back to


Remember, I am handling God's money.  I

am handling church money.  So I have to be able to

justify to give it in the spiritual moral sense of

the thing.  And, as a church, I am allowed to

benefit people, allowed to help people.

I was just telling somebody out there --

we were talking about a church in Memphis that

went and bought a house and gave it to somebody

from the Katrina situation.  They just gave them

the house.  They took the church money and they

bought a house and gave it to the people.

See, so that's what -- when these people

got ready to leave us, even though they were

opposing me, I did not send any of them away

empty.  I did not give them all their money back

because their money was offerings, but I didn't

want them to go back out with nothing.

Q.   Well, did the amounts that you gave

these people --

A.   The amount had to do with him because of

the amount he had turned in, yes.  It had to do

with that.

Q.   Was it just generally in reference to

the amount that they had offered, or was it an

equation, you gave them a certain percentage

back?  Or tell me how it had something to do with

what they offered.

A.   It had nothing to do with what they

offered.  I felt certain -- like Larry Hartley or

anyone, I felt like I give them enough money of

what they gave.

Q.   Now, hold on a minute, because you just

said that it had something to do with what they

offered.  Did it or did it not?

A.   It did not.

Q.   So the amounts were selected without any

reference to what they offered?

A.   Right.

Q.   So if you had felt like giving Mr.

Butler $100,000 --

A.   If I felt like giving him nothing, I

would have gave him nothing.

Q.   Or $100,000?

A.   Or $100,000, right.

Q.   And there would be no criteria that you

would use to determine that amount?

A.   None whatsoever.

Q.   Other than what you felt --

A.   None whatsoever.

Q.   -- was appropriate, right?

A.   Yes.

MR. CHAPLIN:  Do you need a break?  Are

you okay?

THE WITNESS:  Yeah, I'm all right.

Q.   Did Mr. Butler complain to you about the


A.   No, not to me.  He might have to

somebody else, but he didn't do it to me.

Q.   All right.  Let's talk about Mr. Duval.

A.   Who?

Q.   Michael Duval.

A.   Oh, okay.

Q.   How did you first become acquainted

with --

A.   All of these people, every last one of

them, sir, heard me on the radio.  I'm a radio

broadcaster.  I cover the nation.  They heard me

on the radio.

MR. CHAPLIN:  But he's talking about

this one specifically, just Duval.

A.   Radio, conversation, came and moved

here.  Moved here to South Carolina on their own.

Q.   Where were they from?

A.   New York State.

Q.   When did you first have a telephone

conversation with Mr. and Mrs. Duval?

A.   I don't know.

Q.   Did you talk to them on the telephone?

A.   Oh, I'm sure.

Q.   Did they come for a visit?

A.   They moved here.  They moved here and

lived in Walterboro for quite awhile.

Q.   You mean not in the community?

A.   They moved here without my -- they

didn't ask me.  They just moved to Walterboro.

And the next thing I knew they were down here and

they started attending the services.

Q.   Was that the first time you met them in

person, when they began attending services?

A.   Yes -- no.  I might have met them one

time when I went up to that area for a meeting.  I

think they told me they came to our meeting in

Syracuse, or something like that.

Q.   Do you know approximately when it was

that they moved to the Walterboro area?

A.   No, I don't.

Q.   Do you know when it was approximately

they began attending services here?

A.   No.

Q.   Did you ever have any conversations with

them about moving to the community?

A.   Sure.

Q.   When did those begin?

A.   I don't know.

Q.   What were the nature of those


A.   Same thing with everybody else.  You

want to live here, you come out here and work with

us, and you find out whether you can live here

with us under our terms, the way we do things, and

whether we can live with you.  It's the same with

anybody anywhere.

Q.   Just like what you described with the


A.   Yes.

(Plaintiffs' Exhibit No. 4 was marked

for identification.)

Q.   Okay.  I am going to hand you now what

has been marked as Exhibit Number 4 and ask you if

you recognize that document.

A.   Uh-huh.

Q.   You do?

A.   I recognize some of it.

Q.   There are several pages there.  It's

just the way it came to me.

A.   Yes.

Q.   What is that document?

A.   Just the money they gave and the money

we gave back.

Q.   Who prepared that?

A.   Either my wife or Margaret.  This looks

like Margaret and that looks like maybe --

Q.   For the record, the handwritten part

looks like Margaret?

A.   Uh-huh.

Q.   That is a yes?

A.   What Margaret would do is we have a

bookkeeper.  The bookkeeper keeps a record.

Margaret has each individual.

Q.   An individual what?

A.   She has a list of people who have

written to us over the years, and she keeps a

record.  She can tell how much money they send and

when they send it and what we send back to them.

And that is probably Margaret right there.

4-9-96, she would tell you that is how

much money they gave.

Q.   For the record, because we have to read

this later, you are pointing at the second page of

Exhibit 4, which is a handwritten page that you

think is the handwritten record that Margaret


A.   Yes.

Q.   Would the same be true for the next

page, the third page, which is handwritten, also?

A.   Yes.  I would say so.

Q.   And insofar as the first page, which is

typed with some handwriting on it --

A.   That might be Margaret, too, making a

summary.  I really don't know.

Q.   Do you know why this first page was

prepared on June 27, 2001?

A.   Yeah, because we started to give them

money back and I wanted to know what we were

giving them back.  So I asked her to give me a

record of it, how much did the people give, how

much did we give them back.

Q.   And it appears that this was signed by

Mr. Duval?

A.   Yes.  I have to have records where I

gave the money to.  See, it's God's money.  It's

not their money.  It's church money.  If I give

you money, sir, I want you to sign a record for

me, or a check for me or sign a receipt for me.

Q.   Well, other than Mr. Duval, did you have

any of these other folks sign something?

A.   We either got a check or they signed a


Q.   Because I don't know that I have

received copies of all of those.  Do you think

they are there, a check or a receipt for all of