IN THE COURT OF COMMON PLEAS

FOR THE STATE OF SOUTH CAROLINA

COLLETON COUNTY

DEPOSITION OF RALPH GORDON STAIR

GLENDON ALLABY, KATHRYN ALLABY, CORA PFUND, ERIC

PFUND, GREG LINDSEY, LARRY HARTLEY, MICHAEL DUVAL,

KATHLEEN DUVAL, PEARL BUTLER, TIMOTHY BUTLER and

KEVIN NEVIN,

Plaintiffs,

vs. CASE NO. 04-CP-15-382

R.G. STAIR and FAITH CATHEDRAL FELLOWSHIP, INC.,

a/k/a OVERCOMER MINISTRIES,

Defendants.

____________________________________________________

DEPONENT: RALPH GORDON STAIR

DATE: December 4, 2006

TIME: 9:00 a.m.

LOCATION: PETERS MURDAUGH PARKER ELTZROTH &

DETRICK, PA

123 Walter Street

Walterboro, SC 29488

REPORTED BY: NANCY ENNIS TIERNEY, CSR (IL)

CLARK & ASSOCIATES

P.O. Box 73129

North Charleston, SC 29415

(843) 762-6294

A P P E A R A N C E S

FOR THE PLAINTIFFS:

PETERS, MURDAUGH, PARKER, ELTZROTH

& DETRICK, P.A. SMITH

BY: BERT GLENN UTSEY, III

123 Walter Street

Walterboro, SC 29488

(843) 549-9544

FOR THE DEFENDANTS:

LAW OFFICES OF MATHIAS G. CHAPLIN, P.A.

BY: MATHIAS G. CHAPLIN

206 E. Washington Street

Walterboro, SC 29488

(843) 549-9330

I N D E X

Page

Witness Sworn 4

EXAMINATION

By Mr. Utsey 4

By Mr. Chaplin 225

By Mr. Utsey 229

Certificate of Reporter 250

Deponent Correction Sheet 251

E X H I B I T S

Page

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.

EXAMINATION

BY MR. UTSEY:

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

perspective.

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

example.

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

transcribed.

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

question.

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

today.

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

name.

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

that?

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

to.

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

County?

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

pastor.

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

areas.

Q. Do you have folks who live on the

grounds?

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

donated?

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