1-25-11transcript Canadian Reference Case On Polygamy - Day26 Testimony & Cross Examination of Witness # 2

1
Preliminary matters
1 January 25, 2011

2 Vancouver, B.C.
3
4 (DAY 26)
5 (PROCEEDINGS COMMENCED AT 10:00 A.M.)
6
7 THE CLERK: Order in court. In the Supreme Court of
8 British Columbia at Vancouver, this 25th day of
9 January 2011. Calling the matter concerning the
10 constitutionality of section 293 of the Criminal
11 Code, My Lord.
12 MR. WICKETT: My Lord, I believe my learned friend
13 Mr. Jones wants to address a couple of matters
14 before we commence with evidence.
15 THE COURT: Yes. Thank you. Is everything working in
16 55, Mr. Jones?
17 MR. JONES: I beg your pardon, My Lord.
18 THE COURT: Is everything working in courtroom 55?
19 MR. JONES: It does seem to be, My Lord. The only
20 difficulty is when we speak over one another and I
21 think we can avoid that.
22 THE COURT: Okay.
23 MR. JONES: I just wanted to address quickly two
24 housekeeping matters. One, there's been a lot of
25 back and forth among counsel regarding schedule
26 for this week and Your Lordship hasn't been privy
27 to that so I thought I would, subject to your
28 direction, tell you what we've decided.
29 We have four days this week. It's anticipated
30 that the two -- sorry, the three anonymous
31 witnesses will go into tomorrow and possibly
32 consume those two days. On Thursday we have plans
33 to make submissions and argument regarding several
34 affidavits that have not yet been admitted. There
35 are several outstanding. My friends have
36 indicated that they don't object to some and they
37 do object to others. So we would propose to argue
38 that at that time.
39 One of the affidavits, or two of the
40 affidavits in dispute are the education affidavits
41 of Mr. Munro and Mr. Vanderboom. And we have made
42 both of those witnesses available for
43 cross-examination by my friend, if they need to,
44 on the Friday following the argument, assuming
45 that their affidavits are admitted.
46 There's one other matter that arises from that
47 and that is my friends have asked us to provide
2
Preliminary matters
1 the raw data from the education authorities that

2 underlies those affidavits, and we're certainly
3 willing to do so and it's technically possible to
4 do it in plenty of time, but because of FOIPA we
5 seek the Court's direction that we do so. So we
6 seek a direction that the Attorney General of
7 British Columbia provide the raw data underlying
8 the affidavits of Mr. Munro and Mr. Vanderboom to
9 counsel for the FLDS to counsel -- or the amicus
10 and to any other counsel that has signed on to
11 cross-examine these two gentlemen.
12 THE COURT: So is the information aggregated?
13 MR. JONES: It's -- it's in the form of a database,
14 My Lord, and in the form that it's been requested,
15 they have requested it redacted of names which is
16 good because that's the way we have it, but with
17 what's called a personal education numbers, the
18 PENs, which is the method by which a student's
19 progress, if I can put it that way, is tracked
20 through. So this would be confidential
21 information or private information within the
22 terms of FOIPA.
23 Obviously we are allowed to submit it for the
24 purposes of litigation, but we're just more
25 comfortable doing so with the direction from the
26 Court because we're releasing in the sense of
27 advance of it being used in advance of the
28 litigation being used in this case.
29 THE COURT: Okay. Mr. Wickett, did you have something?
30 MR. WICKETT: No, Mr. Jones has fairly put the case
31 forward. We have sought this information with
32 respect to cross-examination if the affidavits are
33 admitted, and so long as the names of the students
34 frankly are omitted I believe that that is
35 sufficient for privacy purposes and for protecting
36 these students.
37 THE COURT: Okay. Any other submissions on that? Then
38 I'll make the requested direction.
39 MR. JONES: Thank you, My Lord.
40 THE COURT: Anything else?
41 MR. JONES: Just one other thing, My Lord, with respect
42 to counsel introductions. We have signed and
43 given to the sheriff the usual sign-in sheet and
44 we propose just to have any counsel who speaks
45 identify themselves before they do so.
46 THE COURT: Thank you. Okay. Then are we prepared to
47 proceed with the witness?
3
Witness No. 2 (for FLDS)
In chief by Mr. Wickett
1 MR. WICKETT: Yes, My Lord, we are.

2
3 WITNESS NO. 2, a witness,
4 called by the FLDS, sworn.
5
6 EXAMINATION IN CHIEF BY MR. WICKETT:
7 Q I will try to avoid calling you Witness No. 2,
8 which sounds rather formal, but you have sworn an
9 affidavit in this proceeding?
10 A I have.
11 Q And it's before you?
12 A Yes.
13 Q And on the fourth page is a signature that says
14 Witness No. 2?
15 A Yes.
16 Q Is that your signature?
17 A It is.
18 MR. WICKETT: And, My Lord, this is Exhibit number 79.
19 THE COURT: Yes, thank you.
20 MR. WICKETT:
21 Q You are currently in your early 40s?
22 A Yes, I am.
23 Q And where were you born?
24 A In Creston, BC.
25 Q And you're a member of the FLDS church?
26 A I am.
27 Q And you were born into it?
28 A Yes.
29 Q Were you raised in a family that practised plural
30 marriage?
31 A Yes.
32 Q When you grew up how many wives did your father
33 have?
34 A He had five.
35 Q And when you grew up were all of them in the
36 house?
37 A There were three in the home I lived in.
38 Q And when you grew up how many children were
39 residing in the family home?
40 A At the time I was there approximately 30.
41 Q And roughly how many -- or how many children did
42 your mother have -- how many children are
43 biologically the children of your mother?
44 A 15.
45 Q Now, have some of your siblings left the FLDS
46 community?
47 A Yes. Three have.
4
1 Q With respect to those that have stayed within the

2 community, do you continue to maintain a
3 relationship with those people?
4 A Yes, I do.
5 Q Has there been any difficulty in maintaining
6 relationships with the three that have left the
7 community?
8 A I -- yes, in some ways. I don't seek them out. I
9 have in conversations with them tried to show them
10 that I respect their choice and I hope they
11 respect mine, but as far as -- the values that
12 they have embraced aren't the same as mine.
13 Q In your -- in your family growing up was education
14 treated as something that was important?
15 A Yes, it was. Very -- very much so. My mother
16 encouraged me to finish high school. She
17 encouraged me. She was probably one of my main
18 support in going to college and she was -- she
19 encouraged all of her children to do that.
20 Q Well, let's just deal with that for a moment.
21 Where did you attend school?
22 A In Bountiful.
23 Q What level did you achieve there?
24 A I achieved Grade 12.
25 Q Can we stop for just a moment, please.
26 THE COURT: Is there a problem?
27 MR. JONES: Sorry, in what respect? It seems to be
28 working perfectly on this end, My Lord.
29 THE COURT: Okay. We thought someone was trying to get
30 our attention.
31 MR. WICKETT: Yes. We can hear people speaking so we
32 weren't sure if somebody couldn't hear us or was
33 objecting.
34 MR. JONES: I'm not sure there was speaking on this
35 end, but we apologize if any sotto voce stuff got
36 too loud.
37 THE COURT: Thank you.
38 MR. WICKETT: Thank you.
39 Q I'm sorry, we had just asked you what school you
40 attended.
41 A Yes.
42 Q And you said the Bountiful school?
43 A Yes.
44 Q And you achieved what level there?
45 A Grade 12.
46 Q And after high school did you attend college?
47 A I attended six years of post secondary education.
5
1 Q And after those six years did you achieve a

2 diploma?
3 A Yes.
4 Q All right. Now, have you worked outside the home
5 since you received your education?
6 A Yes, I've worked for 19 years.
7 Q And is your job a job that is within or without
8 the Bountiful community?
9 A I worked both. I worked within and without.
10 Q Okay. Now, are you married?
11 A Yes, I am.
12 Q And how old were you when you were married?
13 A I was 16.
14 Q Do you currently live now in a plural
15 relationship?
16 A I do.
17 Q How many people are in that relationship?
18 A My husband has two wives. That includes me.
19 Q Okay. Speaking obviously only for yourself, can
20 you describe the role or the importance of plural
21 marriage your religious belief?
22 A I believe in the teachings of the prophet Joseph
23 Smith, who was the founder of the Mormon church
24 back in the 1800s, and his description of living
25 plural marriage was that it was required to attain
26 the highest degree in the celestial kingdom.
27 Q Is it your belief that plural marriage is for
28 everyone within the FLDS?
29 A No.
30 Q Why is that?
31 A Because it takes a considerable amount of faith
32 and determination to live it the right way.
33 Q Perhaps you could explain to His Lordship --
34 perhaps you could explain to His Lordship how the
35 marriage process worked in your situation. What
36 happened?
37 A Okay. When I was 16 years of age I was very much
38 interested in attending college and so when I was
39 talking about this to my parents they suggested
40 that in order to help me and support me through
41 the college that marriage would be a good idea.
42 And so I thought about that for awhile and I
43 decided that I did want to get married, and so
44 they went and spoke with our prophet at the time.
45 My father came back and we had a discussion about
46 it. He mentioned a name of one of the elders in
47 our church at the time. Although I did not know
6
1 him well I knew he was in good standing with the

2 church. And he told me, he said, this man has no
3 idea that his name has been placed here and you do
4 not have to marry him if you do not want to. He
5 will never know whether you have said yes or no.
6 And I felt good about him and I married him.
7 Q How long after this discussion did -- were you
8 married?
9 A I was married three months later after a period
10 of -- three months later.
11 Q Okay. And during that three months, were you
12 introduced or did you spend any time with your
13 future husband?
14 A Yes, I did. We met every weekend.
15 Q And I can see that you're -- you might need a
16 little glass of water. Go ahead and take a little
17 sip if you like.
18 I understand that you are the second of your
19 husband's two wives?
20 A Yes.
21 Q Can you describe your relationship with your
22 sister wife.
23 A My sister wife and I have lived -- have lived at
24 times in the same home. We've lived in different
25 homes. We are now living again in the same home.
26 I feel that we are both very committed in having a
27 good relationship with each other, and conflict
28 arises, yes, but I feel like that we can deal with
29 it in a reasonable manner.
30 Q Well, since you've raised that subject.
31 A Yes.
32 Q How are conflicts dealt with in your family?
33 A Well, with discussion and negotiation and
34 conciliation.
35 Q Looking back now, on your life with the benefit of
36 some hindsight, do you feel you made the right
37 decision for yourself and your own life?
38 A Yes, I do. I feel like that my husband really
39 supported me through my years of education, and he
40 really has been a lifelong friend to me as well as
41 watched my children while I went to school. As
42 far as having children right away when I was that
43 young I wouldn't -- looking back I would have
44 waited longer to have children.
45 Q Why is that?
46 A It's very difficult to be away from your children
47 as much as I had to be. Just they were young at
7
1 the time.
2 Q And the reason you were away was because?
3 A Going to school.
4 Q I see.
5 A In nearby towns.
6 Q Now, are you aware of whether there is a current
7 policy within the FLDS church with respect to the
8 age of marriage?
9 A I am aware.
10 Q What is the policy to your understanding?
11 A The policy is that there will be no marriages
12 performed or condoned within the community with
13 anyone under the age of 18. Or that's lawful in
14 the area, which is 18.
15 Q From your standpoint do you agree with that
16 policy?
17 A I do.
18 Q Do you have children?
19 A I do.
20 Q How many children do you have?
21 A I have nine.
22 Q What can you tell His Lordship about what you
23 taught your children about the choices that they
24 will have with respect to marriage in the FLDS?
25 A I have told them that they have the right to
26 choose. If someone has suggested to them they can
27 definitely say no and I encourage them to. I
28 encourage them if they do not want to be in a
29 plural situation not to.
30 Q Of your children I understand that -- well, let me
31 ask. How many your children are over the age of
32 18?
33 A I have four.
34 Q And of those how many are married?
35 A One.
36 Q And that was a daughter?
37 A Yes.
38 Q How old was she when she was married?
39 A She was 15.
40 Q Can you explain the circumstances to His Lordship,
41 please, within which that marriage occurred.
42 A At 15 years of age she was becoming very friendly
43 and liked a certain boy. He was also a teen. And
44 she was -- really wanted to get into a
45 relationship. She spoke to me and her father and
46 I strongly encouraged her that this was not a good
47 idea. But she again petitioned us to follow
8
1 through and made a request to the prophet which

2 was accepted and she was married.
3 Q How old was the fellow that she was married to?
4 A He was 19.
5 Q Can you tell His Lordship what has happened to
6 them subsequently?
7 A The first two years she stayed within the
8 community and I was able to be a strong support to
9 her. She left after that. She's no longer a
10 member of FLDS and she lives in a nearby -- about
11 an hour from us, and she is in a -- she has a good
12 relationship with her husband.
13 Q They're still married?
14 A They are.
15 Q And is that a monogamous or a plural relationship?
16 A Monogamous.
17 Q Do they have children?
18 A Yes, I do.
19 Q How many children do they have?
20 A They have two.
21 Q And how old is she now?
22 A She's 26.
23 Q Do you maintain a relationship with your daughter?
24 A I do.
25 Q How often do you see her?
26 A I probably see her about once a month. I text her
27 on my phone and call her on the phone. I'm
28 really -- I've been really -- encouraged her to
29 continue her education and she is doing that now.
30 Q And do you get a chance to go see her?
31 A Yes, I do.
32 Q How often would you see her?
33 A I would see her probably once a month.
34 Q Now, we've heard stories in this case and evidence
35 in this case, which I've told you about, about
36 girls being married -- young girls being married
37 to much older men without consent. Without their
38 consent, that is. If one of your daughters was
39 faced with that demand by the prophet what would
40 be your advice to her as a mother?
41 A My advice would be that she should not do it. I
42 would not allow her to.
43 Q And would there be consequences to that?
44 A No.
45 Q That evidence raises the subject of the prophet's
46 authority or decisions. Do you believe that the
47 decisions made by the prophet must always be
9
1 followed?
2 A No.
3 Q Why not?
4 A Because I believe that, like Joseph Smith was
5 corrected and condemned in his time at different
6 times, that it could happen to anyone.
7 Q Other than your daughter, have any of your other
8 children or stepchildren left the FLDS community?
9 A Yes, I have a stepson.
10 Q And do you have any kind of relationship with him?
11 A I do.
12 Q Can you explain the circumstances within which he
13 left the community.
14 A He was working about an hour and a half from our
15 town and he was living in a place where he was
16 influenced by his peers to drink alcohol and use
17 drugs. And he was given many opportunities to --
18 and assistance to try and stop those addictions
19 but he wasn't able to, and in the end he decided
20 to leave.
21 Q How are -- the issue of taking drugs and alcohol,
22 how was that treated within the FLDS in your
23 community?
24 A Basically we -- our values are that we don't use
25 drugs and alcohol.
26 Q And are people permitted to do that within the
27 community?
28 A No.
29 Q With respect to the same stepson, has there --
30 have you or your husband had contact with him
31 since he's left?
32 A Yes, I have.
33 Q And have you helped him in any way financially or
34 otherwise?
35 A Yes, my husband has helped him when he has
36 needed -- with finances, but he makes a lot of
37 money. He works in -- he supports himself pretty
38 well financially.
39 Q Has he ever expressed an interest in returning?
40 A He has. He -- it was probably about a year ago.
41 He said he wanted nothing more in his life than to
42 be able to return to the faith and the community,
43 and he moved closer to home. This is because he
44 was working and living about six hours ago -- away
45 before then. He moved close and he was visited
46 often and counselled, but he couldn't give up
47 drugs. And so he decided then to move about oh,
10
1 three or four months ago and stay with my

2 daughter.
3 Q He's currently staying with your daughter?
4 A Yes.
5 Q The daughter that has left?
6 A Yes.
7 Q We've heard some evidence in this case about the
8 doctrine of free agency and Mormonism. Have you
9 heard that before?
10 A Oh, yes.
11 Q What does it mean to you?
12 A What it means is that I will practice my faith and
13 I respect -- I respect others to believe that
14 that's not for them and I can appreciate that.
15 And I can also -- it also means to me that I have
16 the choice to do what I decide to do.
17 Q You're aware that polygamy is illegal in Canada?
18 A Yes, I am.
19 Q And if this criminal law is removed from the
20 books, that is, if polygamy is decriminalized, do
21 you think that that would have any impact upon
22 your life and upon your community?
23 A Yes, I do. I believe that there's so many people
24 in mainstream society that believe -- make so many
25 assumptions about us that we are treated with bias
26 and prejudice, and that affects my every-day life.
27 If I wanted to go somewhere and get any sort of
28 counselling with mainstream society then I feel
29 like I would not be accepted that way. Also, ever
30 since Joseph Smith's time we have had to pay so
31 much money to try and stay out of jail, but it's
32 hard to come up with the money that we need.
33 Q And that financial relief would have some impact
34 on your community?
35 A Oh, yes. For me personally.
36 MR. WICKETT: Thank you. Please answer any questions
37 my learned friends may have for you.
38 THE COURT: Thank you. Could I have a list of those
39 cross-examining.
40 MS. GREATHEAD: My Lord, it's Leah Greathead. I will
41 be cross-examining for the Attorney General of BC.
43 MR. REIMER: Yes, My Lord, it's Keith Reimer for the
44 Attorney General of Canada. I may also be
45 cross-examining depending on what comes out of the
46 AG BC's examination.
47 THE COURT: Thank you, Mr. Reimer.
11
Cross-exam by Ms. Greathead
1 MS. GAFFAR: My Lord, it's Deanne Gaffar for the West

2 Coast Legal. I may also be cross-examining.
3 THE COURT: And I missed who it was again, sorry.
4 MS. GAFFAR: My Lord, can you see me now? Sorry. Only
5 the Crown --
6 THE COURT: Oh, yes.
7 MS. GAFFAR: Can you see me now, My Lord?
8 THE COURT: Ms. Gaffar. Yes, thank you. Okay.
9 Ms. Greathead is first then.
10 MS. GREATHEAD: Yes, My Lord.
11 THE COURT: Thank you. Go ahead.
12 MS. GREATHEAD: Just as a housekeeping matter, My Lord.
13 There should be a sealed envelope in relation to
14 Witness No. 2. I am not sure if it was given to
15 Madam Clerk or what has happened with it.
16 MR. WICKETT: It was given to the clerk. She has it.
17 Do you wish that opened and be given to her?
18 MS. GREATHEAD: There are a number of documents in
19 there, My Lord, that I will be putting to the
20 Witness No. 2.
21 THE COURT: Okay. So we are to open the envelope?
22 MS. GREATHEAD: Yeah. I mean, it can be opened now and
23 I can -- I can have the clerk take the documents
24 out as they're needed. We don't need them all
25 right now.
26 THE COURT: Okay, Ms. Greathead. Thank you.
27 MS. GREATHEAD: Thank you, My Lord.
28
29 CROSS-EXAMINATION BY MS. GREATHEAD:
30 Q Now, Witness 2, as I mentioned my name is Leah
31 Greathead and I'm going to be asking you a few
32 questions on behalf of the Attorney General of
33 British Columbia. Can you hear me?
34 A Yes.
35 Q Now, you've told us that you're a member of the
36 Fundamentalist Church of Jesus Christ of
37 Latter-day Saints?
38 A Yes.
39 Q And the short name for that is the FLDS?
40 A Yes.
41 Q Now, you mentioned in your affidavit and I believe
42 that you testified you were born in the rural
43 district of Lister?
44 A Yes.
45 Q Is that correct?
46 A Yes.
47 Q Sorry. And that you now live with your husband in
12
1 the community of Bountiful; is that correct?

2 A Yes, it is.
3 Q And Lister is a small community about
4 16 kilometres or ten miles outside of Creston?
5 A It is.
6 MS. GREATHEAD: And if I could have -- there is a map
7 in the package of documents that were opened up,
8 and if this map could be given to the witness I
9 would appreciate that.
10 THE COURT: And sorry, give a copy to Mr. Wickett as
11 well. Are there three copies of everything,
12 Ms. Greathead?
13 MS. GREATHEAD: I believe there are four copies of
14 everything there, My Lord.
15 THE COURT: Thank you. We all have it, thank you.
16 MS. GREATHEAD:
17 Q Now, Witness No. 2, you have a copy of the map?
18 A Yes, I do.
19 Q And do you see the red circle on the map?
20 A Yes, I do.
21 Q And you see that it is basically circling the
22 intersection of 12th Street and Lyons Road and
23 those roads around that area?
24 A Yes.
25 Q And is that the area of Bountiful? Is that where
26 Bountiful, British Columbia is?
27 A Yes, it is. I'm not really sure that I could --
28 yes.
29 Q Sorry, your answer is yes?
30 A I don't know if it's actually been registered as
31 Bountiful. We call it Bountiful. But that's what
32 I'm saying. I don't know if it's been registered
33 as Bountiful.
34 Q Okay. But that's the area that you call
35 Bountiful?
36 A Yes.
37 Q We've got the right --
38 A Yes.
39 Q The right area -- sorry. I'll just make sure. We
40 were kind of speaking over each other there. But
41 we have the right area circled; is that correct?
42 A Yes.
43 Q For Bountiful?
44 A M'mm-hmm.
45 Q Now, Bountiful is a community where members of the
46 FLDS reside?
47 A Yes.
13
1 Q And there is no one living in Bountiful that is

2 not a member of the FLDS or a member of Winston
3 Blackmore's group; is that correct?
4 A I wouldn't know that for sure. I couldn't say for
5 sure one way or the other. But as far as I know
6 most of the people would be probably FLDS or a
7 member of Winston's group.
8 Q Do you know anyone who is not?
9 A I don't know, but that doesn't mean they couldn't
10 be there.
11 Q No, but you don't personally know any?
12 A No, I don't personally, no.
13 Q Now, is it your understanding that this area was
14 named Bountiful in the 1980s after Winston
15 Blackmore became the bishop?
16 A Yes.
17 Q And that's Bountiful, after Bountiful in the book
18 of Mormon?
19 A I couldn't say that for any certainty. As far as
20 I know it was similar to the Bountiful in Salt
21 Lake City, the Bountiful area that Brigham Young
22 named Bountiful.
23 Q And would you describe Bountiful as a small
24 community?
25 A Oh, yes.
26 Q And do you know most of the people that live in
27 Bountiful?
28 A Yes. Most of them, yes.
29 Q Would you say that you know all of the people?
30 A No.
31 Q And the -- everybody -- other people -- everybody
32 generally knows everybody else in the community?
33 A I would say, yes, they generally -- they generally
34 do. In the last while, as far as Winston's group
35 is concerned, there's lots of people I don't know.
36 Q Prior to the split between Mr. Blackmore's group
37 and the group that you belong to would you have
38 known everybody in the Bountiful community?
39 A I think so.
40 Q So it's only after the split that you're unsure
41 whether you know everyone?
42 A That's right.
43 Q Because there may be people that have joined
44 Mr. Blackmore's group that you don't know?
45 A That's right.
46 Q And you don't know those people because there's
47 no -- you don't have dealings with the people in
14
1 Mr. Blackmore's group; is that right?

2 A To a large extent, yes. But I do communicate with
3 the ones that are my friends.
4 Q And is that -- is that communication done with the
5 blessing of your prophet?
6 A I don't know that.
7 Q Have you been told to restrict your communications
8 with the people in Mr. Blackmore's group?
9 A We have been told, yes, that we should stick with
10 people that have the same values.
11 Q And the people in Mr. Blackmore's group no longer
12 share your values; is that correct?
13 A I couldn't say. I couldn't answer that for
14 certain in all areas. But yes, there are some
15 areas that we don't share the same values.
16 Q And which areas are they?
17 A Well, I guess number one would be who the prophet
18 is.
19 Q And who is your prophet?
20 A At this time it's Warren Jeffs.
21 Q And Mr. Blackmore's group does not see Mr. Jeffs
22 as the prophet? Is that your understanding?
23 A That is my understanding, although I -- I don't
24 know how each individual person feels.
25 Q Now, we've heard and you've mentioned both the
26 names Bountiful and Lister. Are they the same
27 place?
28 A No, they're not. Lister encompasses quite an
29 area. It's actually now been officially changed
30 to Creston. Lister no longer actually exists.
31 Q And so when -- do people use the term Lister and
32 Bountiful interchangeably?
33 A Not necessarily. Like I said, it's quite an area,
34 and the area that we live in is quite small
35 compared to all of Lister.
36 Q So Lister would include Bountiful?
37 A Yes.
38 Q And are there members of the FLDS that also live
39 in Canyon, BC?
40 A Yes, there are.
41 Q And where is Canyon?
42 A Well, on your map there you can see Canyon Lister
43 Road, and so you follow that Canyon Lister Road
44 and it's probably about eight or nine kilometres
45 from Bountiful.
46 Q So you see that the map goes up to -- at the very
47 top of it there's an intersection between 24th
15
1 Street and Canyon Lister Road?

2 A M'mm-hmm.
3 Q And so would Canyon be -- if the map extended it
4 would be further up the page at about 46th Street;
5 is that correct?
6 A Yes.
7 MS. GREATHEAD: My Lord, I didn't have this map marked
8 as an exhibit earlier but I'm wondering if I might
9 have it marked as an exhibit now.
10 THE COURT: Yes. Exhibit.
11 THE CLERK: Exhibit 134, My Lord.
12 THE COURT: 134, thank you.
13
14 EXHIBIT 134: Map of the Bountiful, British
15 Columbia area
16
17 MS. GREATHEAD:
18 Q And there's a house in Canyon known as the "big
19 house"; is that correct?
20 A Yes.
21 Q And we heard evidence from Truman Oler, a former
22 member of the FLDS, that he lived in the big
23 house. Is that where -- do you know Truman?
24 A Yes.
25 Q And that's where he grew up?
26 A Yes, for the most part, yes.
27 Q Now, in addition to Bountiful and Canyon there are
28 other neighbouring communities where members of
29 the FLDS may reside. Neighbouring communities in
30 British Columbia; is that correct?
31 A Yes.
32 Q And would that include Arrow Creek?
33 A Yes.
34 Q And where is Arrow Creek?
35 A Arrow Creek is probably another 8 kilometres from
36 Canyon, 46th Street Canyon.
37 Q And are there any members in Cranbrook, members of
38 the FLDS in Cranbrook?
39 A I know at times there have been and I think there
40 actually is right now, but as far as where people
41 are moving I'm not positive about that.
42 Q But at times there have been?
43 A Yes, there has.
44 Q And women of the FLDS faith may have given birth
45 to their children in Cranbrook; is that accurate?
46 A Yes.
47 Q And what about Creston? Are there times when
16
1 members of the FLDS community lived in Creston as

2 well?
3 A Not really, to my recollection. But there -- I'm
4 sure there could have been. I might not have
5 known that.
6 Q All right. But Creston would be a place where
7 women of the FLDS faith gave birth to their
8 children?
9 A Yes.
10 Q And what about Kitchener, British Columbia?
11 A Yes.
12 Q Is that a place where members of the FLDS have
13 resided?
14 A Yes.
15 Q And where is Kitchener?
16 A It's 15 minutes out of Creston.
17 Q In which direction?
18 A South. No, sorry, north.
19 Q And you've mentioned Lister, so Lister also would
20 be a name that members of the FLDS community might
21 use to describe where they're from?
22 A Yes.
23 Q What about Yahk, British Columbia, is that also a
24 place where the members of the FLDS have resided?
25 A Yes.
26 Q So we've talked about Arrow Creek, Cranbrook,
27 Creston, Kitchener, Lister and Yahk. Is there any
28 other nearby or not so nearby communities in
29 British Columbia where people from the FLDS live?
30 A I can't think of any other.
31 Q And on that list again, Arrow Creek, Cranbrook,
32 Creston, Kitchener, Lister and Yahk, are there any
33 other communities where women from the FLDS may
34 have had their children?
35 A We've had children -- we've had -- to my knowledge
36 people go to Calgary or we might have had some go
37 to Vancouver to deliver a baby.
38 Q Is that when there's been special circumstances?
39 A Yes.
40 Q Now, I understand that there are also members of
41 the FLDS either living in or have lived in Idaho.
42 Do you understand that to be true as well?
43 A I -- in the past, yes.
44 Q And that would have included Bonners Ferry, Idaho?
45 A I couldn't say exactly where they lived.
46 Q Do you know -- you don't know whether they lived
47 in Bonners Ferry?
17
1 A I don't know that, no.

2 Q You know they lived in Idaho, you just don't know
3 the names of the places?
4 A No, I don't know.
5 Q Sorry, to be clear you do know that they lived in
6 Idaho at one point --
7 A Yes.
8 Q -- is that right?
9 A Yes.
10 Q Now -- and we've heard mention in these court
11 proceedings already about Short Creek. Do you
12 know the place called Short Creek?
13 A I do.
14 Q And Short Creek is made up of Hildale Utah, and
15 Colorado City, Arizona; is that right?
16 A Yes.
17 Q And Hildale, Utah and Colorado City, Arizona is an
18 FLDS community; is that accurate?
19 A I -- I could not comment on that city in terms of
20 what their beliefs are. I think -- I know there
21 are some, but I wouldn't be able to comment
22 further than that.
23 Q Have you been to Short Creek?
24 A I have.
25 Q And you went to -- did you go for the April
26 conference? Is that why you went to Short Creek?
27 A I didn't. I didn't go to April conference.
28 Q You've never been to the April conference in Short
29 Creek?
30 A Yes, I have. But I guess I meant in the last time
31 I was there.
32 Q Oh, okay. But you have been to the April
33 conference in Short Creek?
34 A Yes, I have.
35 Q And the April conference is something that you
36 partake in as a member of the FLDS church?
37 A Yes.
38 Q And you were doing that with other FLDS members
39 down in Short Creek?
40 A Yes.
41 Q And when you were there you understood that
42 members of the FLDS lived in Short Creek?
43 A Yes, I was aware that some of them did.
44 Q Now, how many times have you been to Short Creek?
45 A I would not be able to give you an exact number,
46 but I could guess maybe eight or nine times in my
47 lifetime.
18
1 Q And you -- you mentioned the last time you went

2 was not for the April conference. Why did you go
3 on your last visit to Short Creek?
4 A I was sharing some education.
5 Q Sharing some education. What do you mean by that?
6 A Well, I have friends down there with common
7 interests and we were doing some workshops
8 together.
9 Q And your friends with common interests are members
10 of the FLDS church?
11 A Yes.
12 Q And the common interests you had to -- you were
13 sharing had to do with your religion?
14 A With my -- with my career.
15 Q With your career?
16 A Yes.
17 Q As a midwife?
18 THE COURT: Well--
19 MR. WICKETT: My Lord, I very purposefully stayed away
20 from asking this and I'm going to stay away from
21 asking it with respect to the other anonymous
22 witnesses because job titles and that sort of
23 thing are matters that potentially trench into the
24 anonymity order. I don't know where my friend is
25 going with the particular form of questions but I
26 would submit, My Lord, that the cross-examination
27 ought to stay away from attempting to identify
28 particular careers.
29 THE COURT: Ms. Greathead?
30 MS. GREATHEAD: Well, My Lord, the witness does at
31 paragraph 5 of her affidavit indicate that she has
32 completed the elderly care program, the RN program
33 and the registered midwifery program, and in my
34 submission she has by what she has put forward in
35 her affidavit opened the door to questions about
36 midwifery.
37 MR. WICKETT: She certainly opened the door to
38 questions about her training, no question about
39 that. But if my friend is going to move beyond
40 that into what function -- what job she serves
41 within the community, to that I object.
42 THE COURT: And I'll sustain that objection. The
43 concern being that while there was some reference
44 to the educational background of the witness
45 further inquiries as to her occupation today may
46 tend to identify her contrary to the spirit of the
47 order I've made.
19
1 MS. GREATHEAD:
2 Q Now, Witness No. 2, have you ever been to
3 Mesquite, Nevada?
4 A No.
5 Q Now, back to some questions about Bountiful. I
6 understand that Bountiful was established in the
7 1940s by a handful of families from Alberta. Is
8 that your understanding as well?
9 A Yes, it is my understanding. The exact dates I
10 was never really aware of. 40s.
11 Q And who do you understand the founding families to
12 include?
13 A I don't know if I want to mention names.
14 Q Well, maybe I'll put the names to you. Would
15 Harold Blackmore's family be one of the founding
16 families?
17 A Yes.
18 Q And Ray Blackmore?
19 A Yes.
20 Q And Dalmon Oler?
21 A Yes.
22 Q And were there any others that you know of?
23 A No.
24 Q Now, the population of Bountiful today -- and when
25 I talk about Bountiful I'm talking both about
26 those who see their prophet as Mr. Warren Jeffs
27 and the Winston Blackmore group. Do you agree
28 that the population of Bountiful is about 1,000
29 people?
30 A Yes.
31 Q And that the community has been split essentially
32 in half, so about 500 of those people follow --
33 Warren Jeffs and 500 of those people follow
34 Winston Blackmore?
35 A That's probably pretty accurate.
36 Q And within your group how many children would you
37 say there are?
38 A I would not be able to make any speculation on
39 that. I'm sorry.
40 Q Well, over half of the 500 people?
41 A A child being of what age?
42 Q 18 and under?
43 A Probably, roughly.
44 Q So somewhere over half?
45 A Yes.
46 Q Would it be two-thirds?
47 A Maybe not quite that many, but that's a reasonable
20
1 guess.
2 Q Now, I'm going to put some what I understand to be
3 popular surnames from the Bountiful community to
4 you, and I just want you to tell me whether you
5 agree that the name I'm giving you is a popular
6 surname in the community. Blackmore?
7 A Am I required to give names?
8 Q No, I'm just asking you to tell me whether the
9 name that I've come to learn to be a popular
10 surname --
11 A Yes.
12 Q -- in the Bountiful community whether or not it is
13 indeed one that you recognize as a Bountiful name.
14 A Yes, I do recognize that. With all due respect I
15 do not want to reveal anyone's identity.
16 Q No, I'm not asking to you reveal anybody's
17 identity. I'm just asking you to confirm whether
18 this is a popular surname within the Bountiful
19 community. So Blackmore?
20 A Yes.
21 Q Cooke, and that's C-o-o-k-e?
22 A No.
23 Q Fischer, F-i-s-c-h-e-r?
24 A No.
25 Q Do you know anyone by the name of Fischer in the
26 community?
27 A I don't. But there may have been someone as a
28 maiden name Fischer, but I don't know.
29 Q What about Cooke? Do you know anybody in the
30 community with the name Cooke?
31 A I know of one.
32 Q And so I guess here what -- I'm going to revise my
33 question and just ask if you know of anyone in the
34 community with the name that I present to you.
35 A Oh, okay.
36 Q So Johnson?
37 A Yes.
38 Q Keate, and that's K-e-a-t-e?
39 A No.
40 Q Oler?
41 A Yes.
42 Q Palmer?
43 A Yes.
44 Q Quinton?
45 A Yes.
46 Q Steed, which is S-t-e-e-d?
47 A Yes.
21
1 Q Chatwin, C-h-a-t-w-i-n?
2 A Yes.
3 Q Jessop?
4 A Yes.
5 Q Lane?
6 A Yes.
7 Q Emack.
8 A Actually --
9 THE COURT: Sorry, give me that name again.
10 MS. GREATHEAD:
11 Q Emack?
12 A Emack, yes. But I'm just trying to think of Lane
13 again because I don't think so. I don't think on
14 Lane.
15 Q Was there ever a person named Lane in the
16 community?
17 A There may have been. As far as FLDS go I don't
18 know.
19 Q So in these proceedings a woman named Ruth Lane
20 provided a video deposition. Did you watch
21 Ms. Lane's deposition, or video affidavit?
22 A A very small piece of it.
23 Q And do you know Ms. Lane?
24 A I know of her, yes.
25 Q And she was a member of the FLDS community, wasn't
26 she?
27 A Yes.
28 Q And then I was on the name Emack. That's
29 E-m-a-c-k. And I believe you said that you do
30 know people in the community with that last name?
31 A Yes.
32 Q Roundy. R-o-u-n-d-y?
33 A Are you asking have they ever been a member? Yes.
34 Q Yes.
35 A Yes.
36 Q And Barlow?
37 A Yes.
38 Q B-a-r-l-o -- sorry, I'll spell it for the record.
39 B-a-r-l-o-w?
40 A Yes.
41 Q And now, there are -- I'm going to put to you some
42 other names and ask you whether you recognize
43 these names as connected with the FLDS. They may
44 not be names of people in the Bountiful community,
45 but what I'm wondering is whether you know these
46 names as part of the larger FLDS community
47 including the people of Short Creek and FLDS
22
1 members in the United States. That was rather

2 longwinded. Do you understand what I'm going to
3 be asking you?
4 A So you're asking me if I have ever known of them
5 to be at one time FLDS members?
6 Q Oh, I'm -- well, maybe I'll ask it more directly.
7 Do you know the name Jeffs as associated with the
8 FLDS?
9 A Yes.
10 Q And Holm, H-o-l-m?
11 A Yes.
12 Q And Allred, A-l-l-r-e-d?
13 A Yes.
14 Q Now, you have lived all your life in the general
15 Creston/Lister area; is that right?
16 A Yes.
17 Q And you've worked in the Creston area?
18 A Yes.
19 Q And you -- do you know of anyone -- any of these
20 surnames that we have gone through, both the long
21 list and the shorter list, whether there's anyone
22 who lives in the Creston area with these surnames
23 who was not -- who is not or was not at one time a
24 member of the Bountiful community?
25 A In the greater area of Creston? I --
26 Q Yes?
27 MR. WICKETT: My Lord, I understand what the purpose of
28 the question is, but I don't know how the witness
29 could possibly answer that question.
30 THE COURT: Well, can you answer the question?
31 THE WITNESS: I don't see how I could either.
32 MS. GREATHEAD:
33 Q Well, do you know of anyone who lives in the
34 greater Creston area that has one of those
35 surnames that is or was -- that is not presently
36 or was not at one time a member of the FLDS?
37 A As I said, because -- no, I don't, but there are
38 many surnames within the area so I have no idea.
39 Q I'm going to ask you a few questions about what I
40 understand to be distinctive given names for boys
41 in the FLDS community, and I would like you to
42 tell me whether you agree that the name I put --
43 whether or not you agree the name I put forward is
44 a distinctive name given to boys, either as a
45 first name or a middle name, within the FLDS
46 community. And I'm going to -- I may not
47 pronounce a name correctly, and please correct me
23
1 if I don't. And I will spell it in case my

2 pronunciation is off.
3 A Excuse me --
4 THE COURT: Just a second, Ms. Greathead.
5 THE WITNESS: As far as the question is concerned,
6 distinctive according to who?
7 MS. GREATHEAD:
8 Q Well, according to you whether you have heard this
9 name used within your community.
10 A As a boy's first name?
11 Q Or a second name.
12 A Okay.
13 Q The first name is Moroni. M-o-r-o-n-i.
14 A Sure. Yes, it sounds distinctive.
15 Q Nephi, N-e-p-h-i?
16 A Yes.
17 Q Ephrain, E-p-h-r-a-i-n?
18 A No.
19 Q Hyrum, H-y-r-u-m?
20 A Yes.
21 Q Lorin, L-o-r-i-n?
22 A No.
23 Q Mordecii, M-o-r-d-e-c-i-i?
24 A No.
25 Q Leroy, L-e-r-o-y?
26 A No.
27 Q Rulon, R-u-l-o-n?
28 A No.
29 Q So do you know -- you've not heard of boys named
30 Leroy in your community?
31 A I have heard of boys named, but I didn't -- that
32 wasn't the question.
33 Q Okay. So let me go back then and re-ask the
34 question. I'm sorry. I haven't been clear.
35 Can you tell me whether these are names
36 that -- that you hear in your community selected
37 for a boy, either a first name or a last name --
38 sorry, a first name or a middle name. And I'm
39 going to go back to Ephrain. Is that a name that
40 you've heard used for a boy in your community?
41 A Yes.
42 Q And Hyrum?
43 A I have heard of one, yes.
44 Q And Lorin, L-o-r-i-n?
45 A One as well.
46 Q Mordecii, M-o-r-d-e-c-i-i?
47 A Yes, one.
24
1 Q Leroy?
2 A One.
3 Q Rulon?
4 A Yes, one.
5 Q Heber, H-e-b-e-r?
6 A Yes.
7 Q And LeRon, L-e-R-o-n?
8 A I have heard of the name but it's not particularly
9 to our community. So, no.
10 Q Now, I am going to turn now and ask you a few
11 questions about your religion. You've indicated
12 that you have a prophet and that the current
13 prophet is Warren Jeffs?
14 A Yes.
15 Q And you as -- you believe that your prophet speaks
16 directly to God; is that correct?
17 A We believe that he can receive inspiration from
18 God. I believe.
19 Q And he gets this inspiration directly from God?
20 A That's what I said. He receives inspiration from
21 God.
22 Q And when you were growing up was your prophet
23 Leroy Johnson?
24 A Yes.
25 Q And you called him Uncle Roy?
26 A Yes.
27 Q And after Uncle Roy died the prophet became Rulon
28 Jeffs?
29 A Yes.
30 Q And do you remember when that was?
31 A I think it was around '83, 1983, but I'm not
32 positive.
33 Q And he, like Uncle Roy, was referred to as Uncle
34 Rulon?
35 A No.
36 Q What did you call him?
37 A Uncle Roy?
38 Q No, your prophet Rulon Jeffs.
39 A Uncle Rulon, yes.
40 Q And then after Uncle Rulon the prophet became
41 Warren Jeffs?
42 A Yes.
43 Q Your current prophet?
44 A Yes.
45 Q Now, you're taught in your religion, aren't you,
46 to prepare for the end of the world?
47 A All -- yes, FLDS members are. All LDS members
25
1 are.
2 Q And you're taught that the earth will be destroyed
3 and only the good and righteous people will be
4 saved; is that correct?
5 A The earth will be -- at some point destruction
6 will happen and -- yes, I could say that.
7 Q And to be considered good and righteous you have
8 to prove yourself good and righteous; is that
9 accurate?
10 A I would say not necessarily. You have to improve
11 intent too, I suppose.
12 Q Improve intent to what, sorry?
13 A Well, I -- I believe that -- that there's -- no
14 one is perfect.
15 Q But you strive to be good and righteous?
16 A Yes.
17 Q And that means that at times you have to
18 sacrifice?
19 A Yes, we do have to make some personal sacrifices.
20 I think everyone does.
21 Q And what do you say is involved in striving to be
22 good and righteous?
23 A Trying to live in the present. Trying to forgive
24 the past and, like I said, live in the present.
25 Q And is there anything else involved in being good
26 and righteous?
27 A Well, I certainly -- I would expect that I would
28 want to treat others like I want to be treated.
29 Q And what about the teachings that you received as
30 a child growing up in an FLDS community. What
31 were you taught about striving to be good and
32 righteous?
33 A That very same thing. Treat everyone with respect
34 and the way that you want to be treated.
35 Q What were you taught about your prophet?
36 A Basically what I have said, that we believe that
37 he is our leader and that he can receive
38 inspiration, and -- that's it.
39 Q And you were taught because he does receive
40 inspiration from God that you were to take
41 direction from him; isn't that right?
42 A We -- he does direct areas in our life, yes.
43 Q And you're supposed to follow those directions?
44 A If we deem them right for us.
45 Q And you were taught that following his directions
46 was important?
47 A I wouldn't say that, not necessarily.
26
1 Q Have you ever not followed one of the directions

2 of your prophet?
3 A Yes.
4 Q And did your prophet find out?
5 A I don't think so, but I don't know.
6 Q What was the direction that you didn't follow?
7 A Well, we -- like I said, all of my life I've been
8 taught to treat people with kindness and respect
9 and I get mad sometimes and don't do that.
10 Q So the prophet tells you to treat people with
11 kindness and respect and you've had momentary
12 lapses with respect to that, and you consider that
13 not following the direction of your prophet?
14 A Well, you asked -- that was what you asked, and
15 yes, I mean, because you said, you know, has he
16 ever given a directive in terms of, you know, what
17 I'm supposed to do that I wasn't able to follow
18 through with.
19 Q And you said that you followed the directions of
20 your prophet if you deem them right for
21 yourselves; is that correct?
22 A Yes.
23 Q So what part of that example you just gave us,
24 what part of the profit's direction did you deem
25 not right for yourself?
26 A Well, I don't really believe it wasn't right for
27 myself but I believe that we are all on a path
28 of -- we're all on a journey of living principles
29 that will make us happy. And I believe that
30 learning how to control my anger is probably going
31 to be to my benefit in the long run and so I --
32 even though, I mean, I'm not really saying that it
33 wasn't right for me to not -- to not get angry. I
34 say I'm on a path of learning.
35 MS. GREATHEAD: My Lord, I notice the time. Would this
36 be a good time for the morning break?
37 THE COURT: Yes, thank you. Take a 15-minute break.
38 THE CLERK: Order in court. Court is adjourned for the
39 morning recess.
40
41 (WITNESS STOOD DOWN)
42 (MORNING RECESS)
43
44 THE CLERK: Order in court.
45
46 WITNESS No. 2, a witness
47 for the FLDS, recalled.
27
1
2 THE COURT: Thank you, Ms. Greathead.
3 MS. GREATHEAD: Thank you, My Lord.
4
5 CROSS-EXAMINATION BY MS. GREATHEAD: (Continued)
6 Q Witness 2, before the break we were talking about
7 your prophet, and is it not true that from time to
8 time your prophet would give certain directives
9 aimed at people specifically, for example, who
10 they should be placed in marriage with or maybe
11 that they should attend more prayer meetings or
12 repent, something to that effect?
13 A Can I get you to -- I'll maybe just see if I'm
14 understanding the question. Does he give a
15 directive in a certain part of someone's life?
16 Q Yeah, would he give directives aimed at you in
17 particular or individuals in particular?
18 A Yes, he could.
19 Q And have you ever failed to follow a directive of
20 your prophet aimed at you specifically?
21 A No, I have -- no, I haven't.
22 Q And do you know anyone who is still a member of
23 the FLDS who has ever failed to follow a directive
24 of the prophet aimed specifically at that person?
25 A Yes. Sorry, again the question. Do I know anyone
26 that?
27 Q Is still a member of the FLDS church that has
28 failed to follow a directive aimed specifically --
29 a directive from the prophet aimed specifically at
30 that person.
31 A Yes, I do.
32 Q And what directive was it that they failed to
33 follow?
34 A It was a suggestion of who he thought that they
35 should be placed with in marriage.
36 Q Any others other than that one person?
37 A I know of at least two.
38 Q And what directives were those two people faced
39 with?
40 A The same.
41 Q And that is not marrying who the prophet said they
42 should marry?
43 A That's right.
44 Q And when did that occur?
45 A It was probably -- it would have been -- one that
46 would have been about four years ago and the other
47 one probably a dozen years ago.
28
1 Q And so the one four years ago, the prophet was

2 Warren Jeffs?
3 A M'mm-hmm.
4 Q And a dozen years ago, was that -- who was the
5 prophet then?
6 A I think it probably would have been Rulon Jeffs.
7 Q And did the prophet with these women come up with
8 someone else that they should be placed in
9 marriage with?
10 A Yes.
11 Q And they followed that directive?
12 A Yes. As far as I know. I couldn't speak for
13 them.
14 Q They did get married?
15 A Oh, yes.
16 Q Now, you have told us that to get to the highest
17 level of the celestial kingdom you must live
18 plural marriage; is that right?
19 A Yes.
20 Q And is it accurate to say that for a man, for a
21 man to get to the highest level of the celestial
22 kingdom of heaven he must have at least three
23 wives?
24 A That has never been a teaching that I'm aware of.
25 Q He just have to have more than one?
26 A Yes.
27 Q And the only way for a woman to get to the highest
28 level of the celestial kingdom is through her
29 husband; is that correct?
30 A No. Well, I misunderstood the question. That
31 would be correct.
32 Q That is correct?
33 A Yes.
34 Q And I take it that members of the FLDS church
35 aspire to get to the highest level of the
36 celestial kingdom of heaven?
37 A I can't -- I can't speak for anyone else other
38 than my immediate surroundings, but I think that
39 most people would.
40 Q And it is a teaching of the church, isn't it, that
41 you should as a good and righteous member of the
42 FLDS aspire to get to the highest level of the
43 celestial kingdom of heaven?
44 A I -- I can't really answer -- I can't really think
45 I can answer that precisely as far as -- like I
46 said before, I would -- I would imagine that most
47 people do want to.
29
1 Q And most people, you're talking most people within

2 your faith, within the FLDS?
3 A Yes.
4 Q Well, it is true, isn't it, that the -- that
5 heaven and the highest level of the celestial
6 kingdom of heaven in particular is portrayed as a
7 good place, a positive place to be?
8 A Oh, yes.
9 Q And your leaders do talk about what you have to do
10 in order to earn a spot or to get to this heaven?
11 A Yes.
12 Q And now, you've talked about the prophet. Do you
13 also have a bishop?
14 A Each -- yes, we do.
15 Q And you were going to begin -- you started off
16 "each" and then you didn't finish your thought.
17 Each?
18 A Each area it has been the -- as far as I know, as
19 far as the setting up in Joseph Smith's time, each
20 area would have someone that they would look to
21 for a leader.
22 Q And so prior to the split the bishop in the
23 Bountiful area was Winston Blackmore?
24 A Yes.
25 Q And now for you it's James Oler?
26 A I'm -- I don't really want to disclose anyone's
27 identity.
28 Q I'm not asking you to disclose. I'm just asking
29 you if Mr. Oler is your bishop?
30 A I guess for fear of prosecution that might be a
31 worry for him or anyone else I don't want to pin
32 him to anything.
33 MS. GREATHEAD: My Lord, I submit that the witness
34 should be directed to answer this question.
35 THE COURT: Mr. Wickett?
36 MR. WICKETT: I don't disagree. The question is not
37 objectionable, My Lord.
38 THE COURT: Right. So you're not identifying him as
39 committing any particular crime or anything.
40 You're simply identifying his position to your
41 knowledge in the church today. Go ahead.
42 THE WITNESS: Yes, then.
43 MS. GREATHEAD:
44 Q Sorry, so Mr. James or Jim Oler is the current
45 bishop of your group?
46 A Yes.
47 Q And we've heard this term "priesthood head." Can
30
1 you explain what a priesthood head is.

2 A For example, my husband is considered my
3 priesthood head because he is the head of the
4 household.
5 Q So it's the man at the head of the household?
6 A Yes.
7 Q And as a child then your priesthood head would be
8 your father?
9 A Yes.
10 Q And I take it that the other women in your
11 community are the same as you in the sense that --
12 the other married women in any event, are the same
13 as you in that their priesthood head would be
14 their husbands; is that right?
15 A Yes.
16 Q And what's the significance -- what are you taught
17 as part of your religion about the priesthood
18 head?
19 A I've been taught that priesthood to mean it -- to
20 mean someone of a godly nature, so taught that as
21 far as my father or my husband, you know, growing
22 up my father now my husband is concerned, that as
23 long as he is acting in a Christ-like way then I
24 would want to -- I'm trying to think of the
25 correct word here. I would also want to support
26 him in his efforts.
27 Q So when you say that you would also want to
28 support him in his efforts, I take it that's his
29 efforts to act in a Christ-like way?
30 A Yes.
31 Q And that would include then following the
32 direction of your husband?
33 A As far as my relationship with my husband, like I
34 said, if -- we are working together as parents in
35 a family to raise our children and we have the
36 same values and goals to raise them also in a
37 Christ-like manner.
38 Q And some of those values and goals includes
39 complying with the wishes of God?
40 A As we believe them. Yes.
41 Q And complying with the wishes of those who speak
42 for God, like your prophet?
43 A As we see them -- as we would believe them right
44 for us.
45 Q And you have been taught to believe that your
46 prophet will act in your best interests?
47 A Oh, yes, we have been taught to believe that he
31
1 will act in our best interests.

2 Q And that you should follow his directions; isn't
3 that right?
4 A As I said, as far as we feel them right for me.
5 As I feel it right for me.
6 Q Now, from a young child isn't it true that you
7 were taught about the value of the obedience?
8 A Obedience is part of a parenting goal that we
9 were -- we were taught natural consequences, and
10 that's what I try to teach my own children. If
11 the light is red then you stop.
12 Q So I'm not sure that I had an answer to my
13 question. As you were growing up isn't it true
14 that you were taught the importance of obedience?
15 A Of obedience as far as it was reasonable, yes.
16 Q And it was seen as reasonable in your religion for
17 children to be obedient to their father?
18 A Yes.
19 Q And wives to their husband? Wives obedient to
20 their husband?
21 A I wouldn't necessarily say wives obedient to their
22 husbands. In my own --
23 Q That wasn't a teaching? I'm sorry. I didn't mean
24 to interrupt. That wasn't a teaching? That
25 wasn't part of the religious training that you
26 received as a child that --
27 A Not me personally.
28 Q For wives to be obedient to their husband?
29 A No, no.
30 Q Now, I might not pronounce this correctly so I'll
31 spell it as well, but I will try my best at the
32 pronunciation, and what I'm wondering what is the
33 Melchizedek priesthood, which is
34 M-e-l-c-h-i-z-e-d-e-k.
35 A The Melchizedek priesthood?
36 Q Yes.
37 A As far as I understand it, as a man becomes of age
38 and expresses an interest in the faith and
39 maintaining the values of our faith then he will
40 be given, the same as the LDS Mormon church, the
41 right to hold the Melchizedek priesthood. And
42 that gives him the power to give blessings and
43 annointings, to assist with -- to assist with the
44 suffering in illness and that sort of thing.
45 Q Is it only open to boys?
46 A Yes.
47 Q Now, what does "to exult" mean?
32
1 A I am not really sure if I could give a good

2 explanation for that.
3 Q You've heard the term?
4 A I'm just trying -- I haven't really heard it taken
5 out of context.
6 Q Can you provide some context for us, please.
7 A Well, I suppose the way I've heard it is if you --
8 I guess if you are exulted that would mean that
9 you were -- received a promotion.
10 Q And when it's used in the context of a man being
11 able to exult his wife, what does that mean?
12 A So that they would be able to live together as man
13 and wife for all eternity.
14 Q So in the afterlife as well?
15 A Yes.
16 Q So a woman counting on getting into the highest
17 level of the celestial kingdom must be exulted by
18 her husband; is that a fair statement?
19 A Yeah. Yes.
20 Q And it's -- you would agree with me, wouldn't you,
21 that it is difficult to be righteous all of the
22 time?
23 A Oh, yes.
24 Q And that both men and women would have difficulty
25 with it?
26 A Yes.
27 Q And that there are instances when a man has --
28 proves himself no longer righteous and he's no
29 longer able to exult his wife? That happens,
30 doesn't it?
31 A Yes.
32 Q And in these instances you're aware, aren't you,
33 that the prophet must reassign the wives to
34 another man so that they have an opportunity to go
35 to heaven; is that correct?
36 A If they so choose.
37 Q And if they don't choose they can't go to heaven;
38 isn't that right?
39 A No.
40 Q So if they do not have a man that they have
41 been -- if there's no longer a man that can exult
42 them, there's no longer a man that they're sealed
43 to in life and all eternity, isn't it correct that
44 there's no possibility for them to go to heaven?
45 A No, that's not correct.
46 Q How do they get to heaven?
47 A There are many degrees in the heavens.
33
1 Q Oh.
2 A That's what we believe anyways.
3 Q Sorry. So that to get to the highest level of the
4 celestial kingdom though they must -- they must
5 choose to be reassigned to another man; isn't that
6 true?
7 A Yes. But like I said, as was set up by Joseph
8 Smith, there are different degrees in the heavens.
9 Q The highest level is the best though; right?
10 A Well, it depends on who you are.
11 Q Now, as you were growing up you were taught as a
12 girl not to interact with the boys; isn't that
13 right?
14 A No, we had -- I played sports with them. Like, as
15 interact in terms of having a boyfriend and sexual
16 interaction, yes.
17 Q So no sexual interaction. But isn't it true that
18 you were taught as a young girl to treat the boys
19 as if they were snakes?
20 A The statement has come up to mean that if you were
21 to see a snake along the road you're not going to
22 go and bother it, you're going to walk around it.
23 Q You're taught to walk around the boys?
24 A Not to engage in any close contact.
25 Q So you were never to be alone in a room with a
26 boy?
27 A I was not taught that, what you said, never to be
28 alone in a room with a boy.
29 Q It was okay to be alone in a room with a boy?
30 A It can happen. It would definitely depend on the
31 circumstances. If I was walking in the hall at
32 school as a girl and there was -- or I mean
33 everything is in context.
34 Q And so the context of you alone in a room with a
35 boy, was that something you were taught not to do?
36 A No. I was --
37 Q You were taught --
38 A Sorry. I was never told you should never be alone
39 in a room with a boy.
40 Q Were you taught that that was fine, it was okay
41 that you could be alone in a room with a boy?
42 A I wasn't really taught anything about that
43 particular situation.
44 Q What about talking with boys on your own? Were
45 you -- were you allowed to talk to a boy?
46 A Yes, I was.
47 Q On your own, just the two of you?
34
1 A I did as a young girl. I don't know -- I can't

2 speak for anyone else.
3 Q Sorry, so you may have talked to the boys but they
4 might not have talked back to you. Is that what
5 you're saying there?
6 A Well, in everyday life you're going to be
7 respectful to someone. If you see them you're
8 going to say hi.
9 Q And that's the kind of communication when you said
10 you could talk with boys, the everyday life, kind
11 of hi comment?
12 A That was my experience.
13 Q Now, the people in your group believe that -- I'm
14 moving to new area now, about dress. The people
15 in your community believe that it's important to
16 cover your body; is that correct?
17 A Yes.
18 Q And you wear clothes that are different from the
19 people outside of your community?
20 A Yes.
21 Q You are required to wear long underwear?
22 A It has been a suggestion to us. Not everyone
23 does.
24 Q And the men wear shirts and pants that cover their
25 body?
26 A Yes.
27 Q And the women don't wear pants; is that right?
28 A For the most part, no.
29 Q They wear long dresses with long sleeves?
30 A Yes.
31 Q And have you ever been swimming in the creek?
32 A Yes. Yes, I have.
33 Q And some of your brothers and sisters swam in the
34 creek as well?
35 A Yes.
36 Q And when you same in the creek were you required
37 to swim with all of your clothes on?
38 A We do swim with our clothes on, yes.
39 Q Now, I want to talk a little -- ask you a few
40 questions about marriage in particular. I take it
41 that marriage has a very sacred and special place
42 in your religion?
43 A Yes.
44 Q Is that right?
45 A Yes.
46 Q And as -- part of your teachings you were taught
47 to want to marry; is that fair?
35
1 A I don't -- I don't think that -- I wasn't really

2 taught anything particularly. I think it was the
3 assumption that most people would marry.
4 Q And, in fact, it was something that you wanted,
5 wasn't it?
6 A Yes.
7 Q And part of your teachings were that it was
8 important to have as many righteous children as
9 possible?
10 A No.
11 Q Children, though, do have an important place in
12 your religion?
13 A Very much so.
14 Q And you tend to have large families?
15 A Yes.
16 Q But it wasn't part of your religious teachings
17 that it was important to have many children?
18 A No. As far as how many children the teachings
19 that we've been given is have children -- the
20 amount of children that you can take care of.
21 Q And now, you've talked a little bit about
22 placement marriage in that the -- essentially the
23 prophet has a revelation from God about who you
24 should be placed in marriage with; isn't that
25 correct?
26 A I think that he can definitely be inspired and he
27 will make that suggestion to you.
28 Q And does that typically run by the prophet telling
29 your father who you should be placed in marriage
30 with and then your father passing that information
31 on to you?
32 A No, that would -- it would be in a meeting with
33 you and your parents.
34 Q So when you were placed in marriage you heard
35 directly from the prophet?
36 A No, because we lived quite a ways away.
37 Q So in your case the prophet told your father and
38 your father --
39 A Yes.
40 Q -- told you?
41 A Yes.
42 Q And as a child did you daydream about who the
43 prophet might place you with?
44 A Yes.
45 Q Did you discuss possible placements with your
46 girlfriends?
47 A Some -- I know that some of the my girlfriends
36
1 definitely did that. I particularly -- I don't

2 remember doing that, no.
3 Q You looked forward to getting married?
4 A Yes.
5 Q And you've told us that you were married at 16; is
6 that right?
7 A Yes.
8 Q And I take it that you never viewed your marriage
9 at 16 as a form of child abuse?
10 A No.
11 Q Now, this court has heard about cases where sister
12 wives are also biological sisters. Are you and
13 your sister wife biological sisters?
14 A Yes.
15 Q Now, if God tells the prophet that a particular
16 girl is to marry a particular boy and the prophet
17 tells the girl and boy that that is what God
18 wants, what should they do?
19 A I've never heard of a case where he said, God
20 wants you to do this, so I don't know.
21 Q Isn't he getting his inspiration from God?
22 A Yes, he can. But inspiration isn't a commandment
23 or he has -- he to my knowledge has not said this
24 is the person that you must marry, or try to force
25 anyone to.
26 Q So -- but if the prophet does get an inspiration
27 from God?
28 A Yes.
29 Q -- as to where -- and I have a complete question.
30 So if the prophet does get an inspiration from God
31 as to where to place a woman in marriage and that
32 woman says no to the placement isn't she saying no
33 to God?
34 A No, she isn't, because it has not come as this is
35 the person that you must marry. It's brought to
36 her as a suggestion.
37 Q Yeah. That would be a suggestion from God?
38 A No.
39 Q So I'm a bit confused. The prophet is not taking
40 inspiration from God?
41 A Because a girl or woman that wanted to be married,
42 because she presents herself to the prophet she is
43 speaking with a man, not God.
44 Q But you do believe that your prophet communicates
45 with God; right?
46 A I said I believe that he can be inspired.
47 Q Is that not a form of communication?
37
1 A It could -- I suppose it could be considered by

2 some. I'm not sure the exact definition.
3 Q So one of the affiants in these proceedings -- you
4 filed an anonymous affidavit and you realize that
5 there are other people that have also filed
6 anonymous affidavits in these proceedings; is that
7 right?
8 A Yes.
9 Q Now, I'm just going to read to you part of what
10 Witness No. 4 has said, and it's in paragraph 5
11 and I will read it. It's just a short part. I
12 don't think that you need to have the affidavit in
13 front of you. But it says:
14
15 When we come to earth our channel with the
16 heavens and heavenly father is our prophet.
17 He is the one who talks with the heavenly
18 father and receives revelation concerning who
19 we belong to according to the covenants.
20
21 So do you agree with that statement?
22 A I don't discredit her experience, but as far as my
23 experience I -- so you said -- the question was
24 again, do I disagree with that?
25 Q She says that the prophet, he is the one who talks
26 with the heavenly father and seeks revelation. Do
27 you agree with that statement that your prophet
28 talks with the heavenly father?
29 A No.
30 Q And this is a witness, anonymous Witness No. 3.
31 She states at paragraph 9, "I believe that God
32 speaks to our prophet." Do you agree with that
33 statement?
34 A I believe that our prophet can be inspired and he
35 would speak -- every human on earth -- I believe
36 can through prayer speak to their higher power.
37 Q He goes on to say "I believe" -- this is Witness
38 No. 3. So the -- I'll read the whole clause:
39
40 I believe that God speaks to our prophet.
41 Therefore I believe that it is my loving
42 heavenly father who determines who will be
43 the right person for me to marry.
44
45 Do you agree with that statement?
46 A Yes.
47 Q Now, Witness No. 2, you told us your daughter
38
1 married at 15; is that correct?

2 A That is correct.
3 Q And I believe, and correct me if I'm wrong here,
4 but you didn't approve of the marriage at that
5 age, at the age of 15; is that right?
6 A I strongly encouraged her not to marry at 15.
7 Q Did you provide written consent for the marriage?
8 A No.
9 Q So you strongly encouraged her not to marry at 15.
10 Did you take any steps to talk to your prophet
11 about that? About her 15-year-old marriage?
12 A No, I didn't. I spoke to her father.
13 Q Did you speak to your bishop about your concerns
14 with her marrying at 15?
15 A No, but my husband did.
16 Q Did you speak to any outside authorities, like the
17 Ministry of Children and Family Development or the
18 police or any outside authorities about your
19 concerns with your daughter marrying at 15?
20 A No, I'm not really sure why that would -- why I
21 would need to.
22 Q And you mentioned your husband. You didn't speak
23 with your bishop about your daughter marrying at
24 15 but your husband did, and did he talk to you
25 about that? Your husband?
26 A Yes.
27 Q And what was it that your husband spoke to the
28 bishop about?
29 A He -- he told me that he voiced to Winston that he
30 didn't feel good about Melanie -- about my
31 daughter getting married and -- and there was a
32 discussion there and it was ultimately left to her
33 to decide. My daughter.
34 Q So notwithstanding the concerns of your husband
35 that he expressed to the bishop your daughter
36 ultimately got married at 15?
37 A Yes.
38 Q Now, we've heard in the context of marriage in
39 your religion the term being sealed for life and
40 all eternity. Can you explain for the court what
41 it means to be sealed.
42 A It basically means to be married, as far as I
43 understand it.
44 Q And the part about life and all eternity, what
45 does that mean?
46 A It means while you live and then after you live.
47 Q So while you live on this earth and then in the
39
1 afterlife?
2 A Yes.
3 Q And who is it that does the sealing?
4 A It would usually be the prophet.
5 Q And you say "usually." Can the prophet request
6 that someone else do the sealing?
7 A As far as I recollect in the history I think that
8 has happened before, yes.
9 Q And in the marriage ceremony I've heard that there
10 is a special kind of handgrip that is -- that is
11 used. Are you familiar with that handgrip that's
12 used in a celestial marriage ceremony?
13 A Yes.
14 Q How does it work?
15 A As far as I remember, because it's been a few
16 years, you hold hands.
17 Q So does the prophet hold the hand of the man and
18 the woman who are being sealed?
19 A That was not -- to my knowledge, no.
20 Q Who holds hands then?
21 A The two that are getting married.
22 Q And what does the prophet do?
23 A Read the ceremony.
24 Q Have you heard the term the "patriarchal grip"?
25 A I think I have.
26 Q And is it part -- it's part of the wedding
27 ceremony, isn't it?
28 A I think that is what they call the holding of
29 hands.
30 Q If you're the second wife, as you were, is the
31 first wife involved in the marriage ceremony as
32 well?
33 A In my situation she wasn't, but I think in some
34 that they are.
35 Q Is she part of the handgrip part of the ceremony
36 if she is involved in the ceremony, the first
37 wife?
38 A I don't -- I couldn't be certain of that, no.
39 Q Now, you mentioned that usually it's the prophet
40 who presides over the wedding ceremony and
41 sometimes the prophet may direct that someone else
42 conduct the ceremony. So would that someone else
43 be the bishop?
44 A Because I can't remember specifics on it. I -- I
45 suppose it could be. But I -- I've never
46 personally -- witnessed that first-hand.
47 Q Have you been to weddings within your community
40
1 besides your own?

2 A Yes.
3 Q And these were celestial marriage ceremonies
4 conducted within your faith?
5 A Yes.
6 Q And on your wedding ceremony did your mother
7 attend?
8 A Yes.
9 Q And your father?
10 A Yes.
11 Q Did he attend?
12 A Yes.
13 Q And without giving me names were there others --
14 any of your siblings that attended your marriage
15 ceremony?
16 A Yes.
17 Q Now, for your -- we've talked a bit about your
18 15-year-old, your daughter who at 15 got married.
19 Did you attend her wedding ceremony?
20 A Yes, I did.
21 Q And so did you -- you ultimately consent to your
22 daughter's marriage?
23 A Yes, I did.
24 Q And your husband consented as well?
25 A Yes.
26 Q And why did you consent?
27 A Because her partner was 19 years of age. She was
28 not -- it was a monogamous relationship and I felt
29 that I could be close by to her to help her in the
30 event that she had children, which I was able to
31 do. And that's why.
32 Q So would you have not granted your consent if she
33 was entering into a plural marriage situation at
34 15?
35 A I would have not allowed it.
36 Q I take it though that all those that aspire to get
37 to the highest level of the celestial kingdom, so
38 the people that are living monogamously in your
39 community, if they aspire to get to the highest
40 level of the celestial kingdom then they are
41 seeking additional -- seeking to enter into plural
42 marriage. Would that be a fair statement?
43 A I think that some of them are. And I don't know,
44 I couldn't -- I couldn't speak for all of them.
45 Q Who performed your marriage ceremony?
46 MR. WICKETT: That is a question to which I must
47 object, My Lord, for the obvious reason.
41
1 MS. GREATHEAD: Fine, My Lord. I will move on.

3 MS. GREATHEAD:
4 Q Now, Witness No. 2, I would like to ask you a few
5 questions about communicating with your prophet.
6 You told us your prophet is Warren Jeffs, and
7 Mr. Jeffs never lived in Bountiful, did he?
8 A No.
9 Q He had a residence in the United States, in
10 particular in Short Creek; is that your
11 understanding?
12 A Yes.
13 Q And it was the same for Uncle Rulon, wasn't it,
14 that he lived in the United States, didn't he?
15 A Yes.
16 Q And Uncle Roy as well. He lived in the United
17 States?
18 A Yes.
19 Q And I understand that there was a number of ways
20 that your community in Bountiful would communicate
21 with this prophet that lived in the United States.
22 And would one of these ways be sermons from the
23 prophet would be broadcast in church in Bountiful;
24 is that true?
25 A Yes, there was a way to connect up to the meeting
26 in the States.
27 Q And you would hear the sermon as you attended
28 church in Bountiful?
29 A Yes.
30 Q And that at -- that your prophet at times had made
31 tape recordings of his teachings. Did you ever
32 listen to the any of the tapes prepared by your
33 prophet?
34 A Yes.
35 Q And more recently the prophet has used iPod
36 broadcasts. Are you aware of that?
37 A No.
38 Q And you would also write letters to your prophet;
39 isn't that right?
40 A I think some people did.
41 Q Did you ever write a letter to your prophet?
42 A No.
43 Q What about -- did you know of your -- of your
44 children writing to the prophet?
45 A I -- let me -- yes, my children have.
46 Q Your children have written the prophet. And
47 wasn't there a time when you were required to
42
1 write the prophet once a month?

2 A Not to my knowledge.
3 Q Now, the prophet also sometimes came to Bountiful;
4 isn't that right?
5 A Yes.
6 Q And when he came to Bountiful, and this would be
7 whether it was Uncle Roy, Uncle Rulon or Uncle
8 Warren, they would often be involved in Canadian
9 wedding ceremonies?
10 A Yes.
11 Q And there was also -- you mentioned already that
12 you have been to Short Creek. So there was travel
13 between the people in the Bountiful community and
14 the FLDS community in the United States? That's
15 correct, isn't it?
16 A Yes.
17 Q And the leaders, the religious leaders, your
18 bishop would sometimes have meetings with the
19 prophet both in Canada and the United States?
20 A Sorry, can you say that question again. My
21 leaders would have what again?
22 Q The bishop in your community would have meeting
23 with the prophet?
24 A Yes.
25 Q Either in Canada or the United States?
26 A Yes.
27 Q And you could ask to speak to your prophet by
28 telephone?
29 A I guess I never -- the occasion never arose so I
30 don't know.
31 Q You've heard of others speaking to the prophet
32 from British Columbia over the telephone?
33 A Maybe -- maybe once or twice. I can't remember
34 for sure.
35 Q Now, is it also true that -- that your prophet has
36 written -- various prophets have written their
37 teachings down, written them down in writing?
38 A Yes.
39 Q And you've had access to those written works?
40 A Yes, we do.
41 Q And one of those works is the book In Light and
42 Truth?
43 A Yes, it is.
44 Q And that your prophet -- that record -- keeping
45 records of who married who and what was happening
46 with respect to your group is important to the
47 FLDS people?
43
1 A Yes.
2 Q And that the prophet would often write down his
3 thoughts?
4 A In a book or write down his thoughts on paper?
5 Q Yeah. Just on paper.
6 A I -- not really aware of that.
7 MS. GREATHEAD: Now, I'm moving on to another subject
8 area.
9 THE COURT: How much longer are you going to be?
10 MS. GREATHEAD: I do -- I think that I am going to be
11 probably another half-hour, My Lord.
12 THE COURT: Okay. We'll take the luncheon adjournment.
13 MR. JONES: My Lord, perhaps -- sorry, if I might just
14 interject. There was -- during the answers we've
15 been careful to avoid names but there was a slipup
16 on the part of the witness and the name was
17 mentioned and I just wanted to invite Mr. Wickett,
18 if he has a concern over that, that now might be
19 the time to ask for a publication ban.
20 THE COURT: Well --
21 MR. WICKETT: No, I'm not asking for a publication ban.
23 MR. WICKETT: What is said is said.
24 THE COURT: Thank you. We'll take the adjournment.
25 Thank you.
26 THE CLERK: Order in court. Court is adjourned
27 until --
28 THE COURT: Witness, you're under cross-examination so
29 please don't discuss your evidence with anyone.
30 Thank you.
31 THE WITNESS: Okay.
33
35 (NOON RECESS)
36
38
39 WITNESS NO. 2, a witness
41
42 THE COURT: Thank you. Ms. Greathead.
43
44 CROSS-EXAMINATION BY MS. GREATHEAD: (Continued)
45 Q Witness No. 2, you've told that you consented to
46 your 15-year-old daughter marrying monogamously
47 but that you would not have consented to a plural
44
1 marriage. So I'm wondering, is it fair to say

2 then that in your mind a marriage to a man that
3 was about the same age as your daughter and a man
4 that she fancied was preferable to your daughter
5 being placed in a plural marriage, married to a
6 man much older and perhaps sent away to somewhere
7 like Short Creek?
8 A Yes.
9 Q Now, I'm going to ask you some questions about
10 education. Did you attend the Bountiful
11 Elementary and Secondary School?
12 A Yes, I did.
13 Q And you believe that you received an excellent
14 education at that school?
15 A Yes, I felt very well prepared to carry on.
16 Q And can you tell me, has anyone in your community
17 gone on to become a police officer?
18 A Not within the Bountiful community but there has
19 in the States.
20 Q And yeah, I'm talking about the Bountiful
21 community.
22 A No.
23 Q Sorry. So has anyone in your community gone on --
24 your community being the Bountiful community, gone
25 on to become a firefighter?
26 A When I married my husband he was a firefighter at
27 that time.
28 Q A certified general accountant?
29 A Yes.
30 Q And was that one person?
31 A I think -- I'm not exactly sure. I know there's
32 been people with accounting information -- I mean
33 accounting schooling.
34 Q Accounting school. So could that be bookkeeping
35 as opposed --
36 A Yes.
37 Q -- to a university?
38 A Yes.
39 Q So has there been anybody that's got a university
40 degree as a certified general accountant?
41 A Not that I'm aware of.
42 Q What about an officer in the Canadian Armed
43 Forces?
44 A No.
45 Q An enlisted member of the Canadian Armed Forces?
46 A No.
47 Q An engineer?
45
2 Q An architect?
3 A No.
4 Q A university professor?
5 A No.
6 Q A college professor?
8 Q A university-trained scientist of any type?
9 A Not to my knowledge, no.
10 Q A doctor?
11 A No.
12 Q A dentist?
13 A No.
14 Q A psychologist?
15 A No.
16 Q A physiotherapist?
17 A No.
18 Q A veterinarian?
19 A No.
20 Q A pharmacist?
21 A No.
22 Q A banker?
24 Q Someone who has obtained a Masters degree in
25 business?
27 Q A computer technician?
28 A Yes, we have computer technicians. I don't know
29 how far their education went in that area.
30 Q Would they be university trained?
31 A Not to my knowledge. But I don't know that.
32 Q They wouldn't have university degrees?
33 A No.
34 Q A government official of any type?
35 A I don't think so.
36 Q Has anyone in your -- in the Bountiful community
37 gone on to become a lawyer?
38 A No.
39 Q A notary?
40 A No.
41 Q A legal assistant or legal secretary?
42 A No.
43 Q A commercial pilot?
44 A Pilot. Not commercial.
45 Q A journalist?
47 Q A TV reporter or other media professional?
46
1 A No.
2 Q An economist?
4 Q Do you know of anyone in the Bountiful community
5 who has attended the Bountiful Elementary School
6 and Secondary School and then gone on to attend
7 the British Columbia Institute of Technology?
8 A BCIT?
9 Q Yes.
10 A I have taken courses through BCIT.
11 Q Anyone else?
12 A I can't really speak for them. No, I wouldn't
13 know that.
14 Q So do you know anyone from the Bountiful community
15 who has attended the Bountiful
16 Elementary-Secondary school and then gone to
17 attend Capilano University?
18 A Not to my knowledge, no.
19 Q How about the University of British Columbia?
20 A I don't think so. But I -- again, I can't really
21 speak for everyone.
22 Q You don't know of anyone that has though?
23 A Not that I know of, no.
24 Q Do you know of anyone who -- from the Bountiful
25 community who again attended the Bountiful
26 Elementary-Secondary School and then gone on to
27 attend the Kwantlen Polytechnic University?
28 A Again, not to my knowledge.
29 Q Do you know anyone that went on to the Okanagan
30 University College?
31 A No.
32 Q To Emily Carr University?
33 A Yeah, I would not know that but -- not to my
34 knowledge, no.
35 Q To Royal Roads University?
36 A No.
37 Q To Thompson Rivers University?
38 A There may have been someone that has taken courses
39 through Thompson River. I don't know.
40 Q Do you know how many people?
41 A I don't know them. I don't know of them. I've
42 heard of people talking about that particular
43 institution but I don't know if they went on. I
44 don't know.
45 Q What About Trinity Western University?
46 A No.
47 Q Do you know of anyone -- do you know if anyone has
47
1 attended the same school you did and then went on

2 to attend the University of Northern British
3 Columbia?
4 A That's not the northern lights; right? No, then.
5 Q No. What about the University of the Fraser
6 valley?
7 A No.
8 Q University of Victoria?
10 Q And Vancouver Island University?
11 A No.
12 Q Now, so apart from nursing, midwifery or teaching
13 can you think of anyone in the community who has
14 taken on a job for which a university degree is
15 required?
16 A I don't think so, no.
17 Q Now, at paragraph 6 of your affidavit -- do you
18 have a copy of your affidavit in front of you?
19 A I do.
20 Q At paragraph 6 of your affidavit you suggest that
21 the reason -- you suggest that the reason that
22 there aren't more secondary opportunities for
23 Bountiful children is that they do not have the
24 money to pursue higher education because it's all
25 going to defending American church leaders. Is
26 that a fair statement?
27 A I know in regards to myself I believe that for
28 myself.
29 Q Okay. And you agree that recently -- most
30 recently you have had to send money to the United
31 States to defend a number of church leaders; is
32 that right?
33 A I have chosen to send money. I don't have to.
34 Q And this includes sending money with respect to
35 Warren Jeffs' defence?
36 A I wouldn't know in particular where it was going.
37 I know that I have friends in the south that are
38 facing prosecution and I would like to help them.
39 Q So this money you're sending is going to help the
40 church leaders, the current church leaders and men
41 in the church that are facing criminal charges?
42 A As far as I know. I mean, yes, it is.
43 Q And so that includes the men that are facing
44 criminal charges in Texas for child sexual abuse?
45 A It includes the men in -- you said facing charges;
46 right?
47 Q Yes.
48
1 A Yes. The men facing charges. Yes.

2 Q And it also includes the men that have been
3 convicted in Texas of child sexual assault?
4 A Yes.
5 Q Now, so how does it work? How is it that part of
6 your money gets sent to the United States to aid
7 in defending the church leaders?
8 A There is a request made by our bishop usually that
9 would say anyone that has funds that they can put
10 forward to help these -- help pay for lawyer fees
11 we would appreciate it.
12 Q So do part of the church tithings in Canada go to
13 pay for legal defences in the United States?
14 A I wouldn't know that. I couldn't comment on that.
15 Q How much of your family income have you been
16 sending to assist with criminal defences of church
17 people in the United States?
18 A I -- I cannot say. I could make an approximate
19 amount. But it would be anywhere between $500 to
20 $1,000. Sometimes we will pay that a few months
21 in a row and then we don't. If we can't come up
22 with it we can't. So we pay what we can.
23 Q And so you're taking this 500 to $1,000 that you
24 pay from time to time and paying it towards the
25 defence of people -- men from your church that
26 have been charged with a number of criminal
27 offences in the States rather than putting that
28 money into education; that's a fair statement?
29 A Yes, we are choosing to help them out with that
30 money at this time.
31 Q Now, you -- I believe you mention in your
32 affidavit that both you and your sister wife work
33 outside the home?
34 A Yes.
35 Q Is that right?
36 A Yes.
37 Q Do you work full-time?
38 A It's pretty much full-time.
39 Q And what about your sister wife?
40 A She does as well.
41 Q And your husband?
42 A Yes.
43 Q And you yourself have nine children, I believe,
44 aged 7 to 26?
45 A Yes.
46 Q And does your sister wife also have nine children?
47 A She had ten.
49
1 Q So there's 19 children in your family?

2 A Yes.
3 Q So you mention that you live at the poverty level?
4 A I believe we do.
6 A I believe I do. I don't know exactly what it is.
7 You know, in terms of numbers but ...
8 Q And is it possible -- I'm going to put a
9 proposition to you that you live at the poverty
10 level because you've been trying to raise 19
11 children on the family income that you have?
12 A I wouldn't say that is the only reason.
13 Q It's one of the reasons though?
14 A It could be, yes.
15 Q Now, I take it you're aware, aren't you, that
16 there are all kinds of scholarships, bursaries and
17 other financial support for students trying to
18 attend Canadian universities?
19 A Yes.
20 Q You're aware of student loans for universities?
21 A I am.
22 Q Now, do you know of anyone in your community who
23 has applied to a university, been accepted and yet
24 could not go because their application for a
25 student loan or bursary or scholarship was
26 unsuccessful?
27 A You're asking if I know of anyone within the
28 community?
29 Q Yes.
30 A They made application to university, no.
31 Q Now, Witness No. 2, it is mentioned your affidavit
32 that you have a seven-year-old child?
33 A Yes.
34 Q And I take it that you also feel, like with your
35 education, that your seven-year-old is getting a
36 good education at Bountiful Elementary School?
37 A Yes, I do.
38 Q And all of the students that attend Bountiful
39 Elementary-Secondary School are members of your
40 church, aren't they?
41 A Yes.
42 Q And I take it then none of the students ever show
43 up to school dressed in shorts?
44 A No.
45 Q And your seven-year-old, he or she doesn't play on
46 a soccer team in Creston. Does the
47 seven-year-old?
50
1 A No.
2 Q Or on a hockey team or skate with a figure skating
3 club?
4 A No.
5 Q So your seven-year-old is not involved in any kind
6 of organized activities, whether they be sport or
7 art or any other type of activity outside of
8 Bountiful; right?
9 A No.
10 Q Sorry, so the answer is, no, they're not involved
11 in any activities --
12 A No, this particular child isn't. I have children
13 that are.
14 Q And so on the seven-year-old, the only contact
15 then your seven-year-old child has with the world
16 outside of Bountiful, is it fair to say it would
17 be a visit to a doctor or a dentist?
18 A Other than using the facilities in town, for
19 example, at the parks or the library, yes.
20 Q And do you -- well, has your seven-year-old
21 attended doctor visits or visits with the
22 dentist --
23 A Yes.
24 Q -- outside of Bountiful? And do you attend with
25 your child when he or she goes to these visits?
26 A Yes.
27 Q And you also attend when your child goes to the
28 park or the library?
29 A It would be me or another adult.
30 Q And I take it that when you've attended in the
31 doctor's or dentist visits, the doctors or
32 dentists have never told your seven-year-old
33 anything bad about polygamy, have they?
34 A No.
35 Q And these doctors or dentists never taught your
36 seven-year-old to mistrust authority, did they?
37 A I don't think so, no.
38 Q And so when you say in your affidavit that your
39 seven-year-old says, I cried and cried because
40 they were coming to get us, your seven-year-old
41 learned this fear either from you or others in
42 your community, didn't he or she?
43 A He has gotten information about the raid that was
44 done in Texas and our school gets a lot of
45 scrutiny from the government and, yes, he is aware
46 of inspections coming to the school. We tell all
47 the children that the school will be inspected.
51
1 And they were very much aware of the raid in the

2 United States being that it involved a lot of
3 our -- well, some of my relatives and our friends.
4 Q And so it was -- it was you or other members of
5 your community telling your child -- your
6 seven-year-old child about the raid in Texas?
7 A Yes.
8 Q And did you also tell your seven-year-old that as
9 a result of the raid there have been a number of
10 men charged with and now convicted of child sexual
11 abuse?
12 A No, I haven't.
13 Q Now, moving on to a new area. You talk in your
14 affidavit about divorce. I was going to ask you a
15 few questions about that. Now, I take it that you
16 would agree with me that there is only one wife in
17 a plural marriage situation that is legally
18 married to the husband?
19 A Yes.
20 Q And considering that only one wife is able to
21 legally divorce?
22 A Yes.
23 Q And is this generally the first wife?
24 A Generally, but not always.
25 Q And as a legally married wife that wife who wanted
26 to get a divorce and stay within the religion
27 would have to seek permission of the prophet. Is
28 that a fair statement?
29 A I don't think that she would need permission to
30 stay. I can't see why she would need permission
31 to stay. If she wanted to be separated she would
32 separate and stay. If she wanted to.
33 Q Okay. So do you know of any woman who has got a
34 legal divorce from her husband but has not been
35 reassigned to another man and lives in your
36 community?
37 A No.
38 Q Now, you are aware of instances where sometimes a
39 man is found not to be righteous and is kicked out
40 of your community?
41 A No, I am not aware of that.
42 Q Not aware of that ever happening?
43 A I -- I think that there are people that have been
44 asked to -- they're not kicked out of the
45 community. If they have done something that's not
46 agreeable to their wife usually would be the case,
47 then the wife would go and make a request that
52
1 they live separately for awhile.

2 Q Maybe it was a poor choice of words on my part.
3 Are you aware of any men that have been asked to
4 leave the community because of -- for any reason?
5 A Well, asked to live separately, I don't know that
6 it would be -- they haven't been asked to leave
7 the community. They have been asked to live, like
8 I said, in a separate area. It might be still
9 within the community, but it's not with the wife
10 that has the request.
11 Q And there has been a circumstance in your
12 community, hasn't there, where the man was either
13 asked to leave or left the community and his wives
14 were reassigned to another man; isn't that right?
15 A I am not aware of that.
16 MS. GREATHEAD: My Lord, I'm just hesitating because
17 I'm not trying to run afoul of Your Lordship's
18 order about anonymity. I suppose maybe I can ask
19 the question and my friend can object if he so
20 wishes.
21 THE COURT: Okay. So don't -- you don't have to answer
22 until we've had a discussion. Thank you.
23 THE WITNESS: Okay.
24 THE COURT: Go ahead.
25 MS. GREATHEAD: Sorry, so I should ask the question?
26 THE COURT: Ask the question. Tell us what the
27 question is and then we'll discuss it.
28 MS. GREATHEAD: I was going to ask the witness whether
29 she was aware of Marlene Palmer's situation to her
30 former husband Mr. Quinton, and wasn't it true
31 that Mr. Quinton -- I believe it was Quinton, I
32 may be wrong on the name, left the community and
33 his wives were reassigned to another man.
34 MR. WICKETT: Well, I'm trying to conceive of how that
35 question could be dealt with by the witness
36 without violating the second aspect of your order.
37 THE COURT: The second part of the order being what?
38 MR. WICKETT: Being she can't be asked to identify
39 anybody in a criminally polygamous relationship.
40 THE COURT: Sorry, that doesn't necessarily -- the
41 question doesn't necessarily include the fact that
42 Ms. Palmer lives in a polygamous relationship.
43 MR. WICKETT: I suppose. I don't know the facts of the
44 particular case myself and my learned friend said
45 "wives" so I --
46 THE COURT: Okay.
47 MR. WICKETT: I believe she used the plural. I don't
53
1 know the people at all or the names.

2 THE COURT: Okay. Is the question premised on the
3 suggestion that Ms. Palmer lives in a plural
4 marriage?
5 MS. GREATHEAD: I'm sorry, My Lord. I couldn't hear
6 you.
7 THE COURT: Is the question premised on the allegation
8 that Ms. Palmer lives in a plural marriage?
9 MS. GREATHEAD: No, My Lord. And if it assists the
10 court I may first ask the witness whether Marlene
11 Palmer has left the FLDS. Whether she knows
12 whether or not she has left.
13 MR. WICKETT: The issue -- I don't object to that
14 question at all, but the issue is, with respect to
15 criminally polygamous relationships, relates both
16 to her and to her perhaps former husband. I don't
17 know. That's the concern that I've got. The
18 first -- that last question, whether she's left
19 the FLDS and whether she knows her or not, is not
20 objectionable.
21 THE COURT: Okay. So ask those two questions at least.
22 MS. GREATHEAD:
23 Q Witness No. 2, do you know Marlene Palmer?
24 A I do.
25 Q And has she left the FLDS?
26 A She -- as far as -- yes.
27 THE COURT: Did you hear that?
28 MS. GREATHEAD: Yes, My Lord. And now may I ask the
29 next question?
30 THE COURT: What's the next question again?
31 MS. GREATHEAD: The next question was, wasn't Marlene
32 Palmer in a relationship where her husband was
33 asked to leave the church and she was reassigned
34 to another man.
35 THE COURT: I don't hear an allegation of criminal
36 conduct in that question.
37 MR. WICKETT: No, I agree. As I said I don't know the
38 people. I don't know if there's one or two
39 spouses. So long as the question is limited in
40 exactly that way I don't object to it.
41 THE COURT: Okay. Thank you. Witness, if you wouldn't
42 mind.
43 THE WITNESS: To the best of my knowledge with Marlene
44 Palmer, her first partner was not asked to leave
45 the community and she was not assigned per se to
46 anyone. She did ask to be remarried. And she is
47 now no longer married to anyone now.
54
1 MS. GREATHEAD:
2 Q So her first husband left the community?
3 A Yes.
5 A Yes. And she was given -- sorry.
6 Q And she was placed with another man after that?
7 A She requested to be placed, yes.
8 Q Now, what does "apostacy "mean?
9 A As far as I understand when you leave a particular
10 faith and no longer belong to that faith you
11 apostasize from it.
12 Q And you call the people who have left your faith
13 apostates?
14 A That is -- I don't particularly call them anything
15 but I have heard that term used.
16 Q And what is a gentile in your faith?
17 A Basically anyone that belongs -- doesn't belong to
18 my faith, or I suppose any other faith.
19 Q Now, you've told us that you -- that you know
20 Truman Oler. Did you review the affidavit he
21 filed in these proceedings?
22 A I did have -- I did look at it, yes. I don't --
23 well, no, I didn't look at the affidavit. I
24 looked at what was written in the paper.
25 Q So you're aware that he testified?
26 A Yes.
27 Q In these proceedings?
28 A Yes.
29 Q And I take it that -- well, tell me, would it
30 surprise you that he felt that he wasn't welcome
31 back in your community, in the FLDS community?
32 A I think, as I said before, that when someone
33 leaves and they don't share the same values then
34 it's not -- anyone that comes to us is treated
35 with respect, I believe. But, no, it wouldn't
36 surprise me that someone was not welcomed back.
37 Q Would it surprise you that he said his mom said he
38 would have been better off dead than outside the
39 FLDS?
40 MR. WICKETT: Well, My Lord, again lots of latitude in
41 cross-examination but that's crossed the line into
42 an entirely -- in my respectful submission, an
43 improper question. It contains, in the form of
44 the question and the answer that is solicited,
45 double speculation.
46 THE COURT: Yes, I agree with that, Ms. Greathead.
47 MS. GREATHEAD:
55
1 Q You mentioned that your brother had left the

2 community, Witness No. 2. When was the last time
3 you spoke with him?
4 A It was probably about a year ago.
5 Q And before that when did you talk to him?
6 A It was probably six months or so. I can't
7 remember exactly.
8 Q And what did you talk about?
9 A We actually talked about he was going to mechanics
10 school and we talked about that and I was excited
11 for him and that was about it.
12 Q Now, I've read in the press and talked to a number
13 of people myself, former members of the FLDS that
14 have left, and I want to you ask you some
15 questions about people that I understand have left
16 the FLDS.
17 Do you know Wendell Oler?
18 A Yes.
19 Q And is it your understanding that he's left the
20 FLDS?
21 A Yes.
22 Q And he left when he was about 15 years old?
23 A Probably, yes.
24 Q And you know Frank Oler?
25 A Yes, I do.
26 Q And it's your understanding that he left when he
27 was about 14 years old?
28 A Probably. I'm not aware of those date -- that
29 detail.
30 Q You're aware that he left though?
31 A Yes.
32 Q And Adam Oler?
33 A Yes.
34 Q You're aware that he's left?
35 A Yes.
36 Q And Wynn Oler, you're aware that he's left?
37 A Yes.
38 Q And Kenneth Oler?
39 A Yes -- no.
40 Q Rachel's son Kenneth Oler?
41 A I know of a Kenneth.
42 Q That has left?
43 A Yes.
44 Q And Clayton Palmer?
45 A Yes.
46 Q And Leroy Oler?
47 A Yes.
56
1 Q And Terrence Oler?

2 A Yes.
3 Q And Wilton Oler?
4 A Yes.
5 Q And Eric Oler?
6 A Yes.
7 Q And of course we've already heard Truman Oler,
8 he's left and you know him.
9 So of these, you agree that these are all
10 young men that have left the FLDS community?
11 A Yes.
12 Q And do you agree that by far the majority of these
13 young men left without a high school degree?
14 A I would not know their education but because of
15 their age then it probably is likely. I want to
16 go back to the one before a little bit. As far as
17 left FLDS there's probably some of those that are
18 with Winston's group, so I don't know exactly, you
19 know, who or what.
20 Q Well, and there are a number of boys that have
21 left from Winston's side as well, aren't there?
22 A I don't know that. I can't speak for that.
23 Q Now, you've talked about you working, your sister
24 wife working and your husband working. You agree
25 your husband is a hard working man?
26 A Yes.
27 Q And that -- so he -- I take it he works full-time,
28 five days a week; is that right?
29 A Yes.
30 Q And he attends church meetings on the weekends?
31 A Yes.
32 Q And he also gives some of his time to assisting
33 the bishop; is that correct?
34 A I -- he does occasionally but not often.
35 Q Does he spend time alone with you?
36 A Yes.
37 Q And with your sister wife?
38 A Yes.
39 Q And so I take it that after working full-time,
40 attending the church meetings he does attend,
41 spending time alone with you and giving assistance
42 sometimes to the bishop that he doesn't have a lot
43 of time left over for his 19 children; is that
44 right?
45 A It's true there isn't enough hours in the day, but
46 at the present time we don't have 19 children in
47 the home.
57
1 Q Well, is it fair to say that when a man has 19

2 children he's unable to devote as much time to
3 them as when he has two, four or six?
4 A Yes.
5 Q And how many children do you have in the home now?
6 A Counting up here. Eight or nine. My older boys
7 work in Alberta so they come back on weekends.
8 Q Now, you've told us that it was difficult for you
9 to be away from your children while you were away
10 studying?
11 A Yes.
12 Q And were these long periods of time that you were
13 away studying?
14 A I would have to leave sometimes for two or three
15 days at a time, to leave town to go to a college.
16 Q And when you would leave for two or three days at
17 a stretch, during these times was it your older
18 children and your sister wife who were looking
19 after your kids?
20 A Yes.
21 Q And what happened when both -- you mentioned your
22 sister wife works as well, so when both your
23 sister wife and you were away working who looks
24 after the children?
25 A They're all of school age.
26 Q And when they weren't of school age who looked
27 after the children?
28 A My sister wife wasn't working then.
29 Q And after school now when you're away do you hire
30 a nanny?
31 A No.
32 Q Do the older siblings help with looking after the
33 younger children?
34 A They do, but my husband comes home with them after
35 school.
36 Q And was that something you did as a girl growing
37 up too was help raise your siblings?
38 A It was something that I took great pleasure in.
39 Q Now, His Lordship has heard that within plural
40 marriages there's a special love between a mother
41 and her own biological children. Do you agree?
42 A Yes.
43 Q Can you elaborate on that?
44 A I believe there's a special love between, at least
45 I hope there is, between every mother and a child.
46 Q And you indicate in your affidavit that there have
47 been times when the relationship with your sister
58
1 wife was not so good. Can you explain what you

2 mean by that.
3 A I mean that any two or three individuals -- well,
4 I guess any two individuals trying to -- trying to
5 live in the same home there's -- conflicts are
6 going to arise. I don't particularly care who it
7 is. And it happens in -- I believe in everyone's
8 life and you just have to deal with it.
9 Q Now, I take it that you aware of girls other than
10 your daughter who have been placed in marriage as
11 15-year-olds; is that right?
12 A Yes.
13 Q And you're aware of others that have been placed
14 in marriage who are between 15 and 18 years old?
15 A Yes.
16 Q And that you've come across and met many young
17 girls that have been sent from the United States
18 as teenagers to live in Bountiful?
19 A I would not say many. I would say in the course
20 of time that I've been aware of, as far as a teens
21 coming across into Canada, I don't know, roughly
22 nine or ten. I would have to count.
23 Q And that these young girls that come over as
24 teenagers from the United States have been married
25 to Canadian men; is that right?
26 A Yes.
27 Q Now, at paragraph 8 of your affidavit you indicate
28 that your church has now committed that it will
29 not perform underage marriages?
30 A Yes.
31 Q And when did this start from?
32 A I believe it was about a year and a half ago.
33 Q So sometime in 2009?
34 A I am not -- I am not aware of the exact date on
35 that, no. I don't know.
36 Q Could it have been June 2008?
37 A I don't know that. I'm sorry.
38 Q Now, so since this policy has come into place have
39 there been any marriages within your community?
40 A No. Not in Bountiful.
41 Q Not in Bountiful. And so there have been --
42 obviously there's been no marriages, there's been
43 no plural marriages during that timeframe?
44 A No.
45 Q Now, I am going to -- you mentioned that you have
46 read In Light and Truth. Madam Clerk has some
47 copies of In Light and Truth that I would like to
59
1 put to the witness.

2 MS. GREATHEAD: Your Lordship, I have not reproduced
3 the entire version of In Light and Truth but it is
4 attached as an exhibit to the affidavit of
5 Ms. Horsman at Exhibit 12 in these proceedings.
6 Q Now, Witness No. 2, have you been provided with a
7 copy of -- entitled In Light and Truth: Raising
8 Children in the Family Order of Heaven?
9 A In front of me? The piece in front of me?
10 Q Yes.
11 A Okay, yes, I have a copied paper in front of me
12 that says In Light and Truth.
13 Q And are you looking at the first page there?
14 A Yes, I am.
15 Q And you'll see that this particular version is
16 called In Light and Truth: Raising Children in
17 the Family Order of Heaven. The Word of the Lord
18 Through his Servants, the Prophets. It's the
19 second edition and it's published by the president
20 Rulon T. Jeffs; do you see that?
21 A Yes.
22 Q And if you go over the page you will see that the
23 table of contents has been reproduced?
24 A Yes.
25 Q And that topics such as section 1, priesthood
26 marriage, and over the page there, the purpose of
27 celestial marriage, the marriage covenant, proper
28 marriages, those are some of the topics that are
29 covered --
30 A Yes.
31 Q -- in this book? And this is a book that you've
32 read and are familiar with?
33 A I have not read it. I have read little clips from
34 it but I have not read the entire book.
35 Q Do you own a copy of this book?
36 A I do -- my husband owns one.
37 Q You have one in the home and you've read parts of
38 it?
39 A I have.
40 Q Now, I'm going to put some of this to you and just
41 ask you some questions about some of the passages
42 in this book. And the first one, if you could
43 just turn over the page to page 10. And do you
44 see there halfway through the page at page 10,
45 "families taken from the unfaithful."
46 A Yes, I can see that heading.
47 Q And in -- this provision here, I'll just read it
60
1 into the record and then ask you a question about

2 it. It says:
3
4 Now, where a man in this church says I do not
5 want but one wife, I will live my religion
6 with one, he will perhaps be saved in the
7 celestial kingdom but when he gets there he
8 will not find himself in possession of any
9 wife at all. He has had a talent that he has
10 hid up. He will come forward and say here is
11 that which though gavest me. I have not
12 wasted it and here is the one talent. And he
13 will not enjoy it but it will be taken and
14 given to those who have improved the talents
15 they received and he will find himself
16 without any wife and will remain single
17 forever and ever. But if the woman is
18 determined not to enter into a plural
19 marriage, that woman when she becomes forth
20 will have the privilege of living in a single
21 blessedness through all eternity. Well, that
22 is very good, a very nice place to minister
23 to the wants of others.
24
25 Now, this was one of the teachings of your church?
26 A I can see it, it says right there. It says,
27 Brigham Young, August 31st, 1973?
28 Q And it is saying to the women if you don't enter
29 plural marriage as a woman you will spend eternity
30 ministering to the wants of others; is that
31 correct?
32 A I think you can interpret that however way you
33 choose.
34 Q And is that how you interpret it?
35 A No.
36 Q How do you interpret it?
37 A I think -- I mean, my beliefs are that living
38 plural marriage isn't for everyone.
39 Q But it is for everyone who wants to get to the
40 highest level of celestial kingdom, isn't it?
41 A And maybe everyone doesn't want to.
42 Q Now, can you turn over to page 36, and there you
43 see the section sub 2 states:
44
45 There is a covenant of obedience in
46 connection with that and separated from it as
47 it pertains to the man and the woman. She
61
1 covenants to obey her husband and he obeys

2 God.
3
4 Do you see that?
5 A Yes.
6 Q And this obedience by the wife to the husband is a
7 principle that was taught in your religion, isn't
8 it?
9 A Like I said before, obedience and how I interpret
10 that statement you just read is as he is
11 Christ-like.
12 Q Right. And you're told again and again that
13 you -- as a girl growing up in your community that
14 you should be obedient to your father and obedient
15 to your husband; isn't that true?
16 A No.
17 Q You do agree that your church leaders use the word
18 "obedience" and gave their direction about
19 obedience to the churchgoers?
20 A I am aware that they use the word "obedience."
21 Q Okay. In the interests of time I'm going to leave
22 that and just move to one other document that I
23 wanted to put to you.
24 MS. GREATHEAD: And this -- Madam Clerk has two big
25 black columns and the word "8 a.m. R 1 time
26 decision record of president Warren Jeffs."
27 I'm sorry, in the interests of time and
28 getting the second witness on I'm actually not
29 going to take the witness to this second document.
30 I have one final question and then I will -- or
31 one final set of questions and then I will sit
32 down, My Lord
34 MS. GREATHEAD:
35 Q So, Witness No. 2, I take it you would agree with
36 me that in a society where new people aren't
37 entering, and I take it that people aren't being
38 converted to your religion; is that right?
39 A There haven't been any new members in Bountiful
40 recently.
41 Q And that polygamy means some men are going to get
42 more than one wife. That's right, isn't it?
43 A Yes, it is.
44 Q And if you have roughly equal numbers of boys and
45 girls that are born at Bountiful, would that be
46 right?
47 A Yes.
62
Cross-exam by Mr. Reimer
1 Q And so if some of those boys will have more than

2 one wife then other boys are not going to have any
3 wives at all; right?
4 A It has not been my experience that there are boys
5 that go without a wife.
6 Q Well, how is that if there are men that have more
7 than one wife?
8 A Because, at least in Bountiful, we've had a lot
9 more risk-taking youth and we have had young men
10 that have died through different accidents,
11 vehicle accidents, and we have more men -- or more
12 the young boys that get into drugs and alcohol and
13 decide to leave.
14 MS. GREATHEAD: Those are my questions, My Lord.
15 THE COURT: Thank you. Mr. Reimer?
16 MR. REIMER: Sorry, if I might have a moment, My Lord.
17
18 CROSS-EXAMINATION BY MR. REIMER:
19 Q For the record, witness, my name is Keith Reimer,
20 last name spelled R-e-i-m-e-r. I am counsel with
21 the Attorney General of Canada in this matter. I
22 just have a few questions. More a followup from
23 questions you've been answering already today.
24 Just so I'm clear, you yourself were married
25 at 16; is that correct?
26 A Yes.
27 Q And your daughter was married at 15?
28 A Yes.
29 Q And both of those marriages were performed by
30 church leaders?
31 A Yes.
32 Q And how old was your husband when you married him?
33 A 29.
34 Q And if I understood your testimony correctly your
35 sister wife is actually your biological sister; is
36 that correct?
37 A Yes.
38 Q And you're the second wife; right?
39 A Yes.
40 Q And how old was your sister then when she married
41 your husband?
42 A I believe she was 16.
43 Q And how old was your husband when he married your
44 sister?
45 A He would have been around -- about 23.
46 Q So there's a 6-year gap between your husband
47 marrying your sister and your husband marrying
63
1 you; is that right?

2 A It's approximately six years, yes.
3 Q Okay. Now, I think you mentioned, and I might
4 have misheard you just because of the audio, I
5 believe you said that your sister was not present
6 at your wedding to your husband; is that right?
7 A No, she wasn't.
8 Q And why was she not present?
9 A Because I went down to the States and she stayed
10 up in Canada.
11 Q So you were married in the States to your husband?
12 A Yes, I was.
13 Q Now, I understand that you have -- you have nine
14 children; is that correct?
15 A Yes, it is.
16 Q And I think in your affidavit you indicated that
17 four of those are over the age of 18?
18 A Yes.
19 Q And how many of those children that are over the
20 age of 18 are girls?
21 A Two.
22 Q And one of those girls is married?
23 A Yes.
24 Q And how old is the other girl who is not married?
25 A 23.
26 Q And have the boys who are over 18 -- your two boys
27 who are over 18, have they been assigned wives?
28 A No.
29 Q How old were you when you had your first child?
30 A 17.
31 Q And how soon after getting married did you have
32 your first child?
33 A It was about a year and a month.
34 Q And how old were you when you had your second
35 child?
36 A It was about two years later.
37 Q So roughly 19?
38 A Yes.
39 Q And your third child?
40 A You're asking me to do a lot of math here. I
41 don't keep track of those numbers. But it was
42 about a year -- two years again later. So I would
43 have been 20, 21.
44 Q And your fourth child, would it be fair for me to
45 guess that would be another two years later,
46 approximately?
47 A It was about a year and nine months.
64
1 Q And the fifth child?

2 A It was approximately two years.
3 Q Okay. So can I extrapolate from what you've told
4 us that you were having children roughly somewhere
5 between a year and a half to two years apart?
6 A Yes.
7 Q Okay. And that was true for all nine of your
8 children?
9 A No, my last three, they were four years and three
10 years apart.
11 Q Now, your daughter who was married at 15?
12 A Yes.
13 Q She has children?
14 A Yes, she does.
15 Q And how old was she when she had her first child?
16 A 17.
17 Q And did you talk to your daughter about using
18 birth control when she got married at 15?
19 A Not then. I did later, but not right then.
20 Q Why not?
21 A Because by and large how -- birth control is not
22 encouraged in our community.
23 Q Is it discouraged?
24 A I have never heard a discussion about it really so
25 I can't really say. I guess -- growing up, I
26 mean.
27 Q Did you yourself use birth control at all during
28 your marriage?
29 THE COURT: Well, is that --
30 MR. WICKETT: Much of this cross-examination has
31 strayed very far from the issues that concern us
32 in this case, but that question, with respect,
33 My Lord, has crossed into an area of personal
34 questioning which seems to me to be entirely
35 improper given the nature of this evidence and the
36 purpose of this case.
37 THE COURT: Mr. Reimer? Do you have anything to say?
38 MR. REIMER: My Lord, the issue of birth control and
39 its use within the Bountiful community and the
40 views within Bountiful community has been
41 discussed.
42 THE COURT: The topic generally, but asking a highly
43 personal question of an individual hasn't been
44 done before.
45 MR. REIMER: I'm prepared to move on, My Lord.
47 MR. REIMER:
65
1 Q Witness, at paragraph 4 of your affidavit you talk

2 about divorce and you say that everyone can
3 divorce if they so chose?
4 A Yes.
5 Q Now, if you chose to get divorced from your
6 husband, and bearing in mind that you're not
7 legally married to your husband, what would have
8 you to do to divorce him?
9 A Tell him I no longer wanted to live with him.
10 Q And would you need to seek the approval of the
11 church leaders to leave your husband?
12 A No.
13 Q You would simply be able to leave him?
14 A Yes.
15 Q And would you be placed into another marriage if
16 you divorced your husband?
17 A If I so choosed.
18 Q And what would happen to your children if you
19 divorced your husband?
20 A I -- I have never really considered it, but they
21 would come with me. Or perhaps some would stay
22 with him.
23 Q Now, in your affidavit at paragraph 8 you talk
24 about your awareness that the church has committed
25 that it will not perform marriages for persons
26 younger than the age permitted in the jurisdiction
27 where the person lives, and I think you indicated
28 during earlier testimony that was a recent policy
29 in the last year and a half; is that correct?
30 A Yes.
31 Q Do you know at what age a person is permitted by
32 law to get married in British Columbia?
33 A I believe it's 18.
34 Q And this policy that you speak of, is this a local
35 Bountiful community policy or a church -- an FLDS
36 church-wide policy?
37 A It would be a church-wide policy.
38 Q And how was that policy communicated to the
39 members of the Bountiful community?
40 A It was communicated through word of mouth and it's
41 posted on the FLDS website.
42 Q When you got married at the age of 16 did you know
43 other girls who were getting married at the age of
44 16 in the community?
45 A Yes.
46 Q Did you know girls in the community who were
47 getting married younger than that?
66
1 A No.
2 Q Do you know of any boys getting married when
3 they're 16 or younger?
4 A No.
5 Q Do you know who Angela Campbell is?
6 A Yes, I do.
7 Q Have you met Angela Campbell?
8 A I have.
9 Q And who is she?
10 A She's a professor working -- I believe it's out
11 of -- somewhere in Ontario, and she came and
12 interviewed different members of our community.
13 Basically she is a law professor who is interested
14 in polygamy.
15 Q And do you know that she visited the Bountiful
16 community in 2008?
17 A I know that she was out there, yes.
18 Q And did you know that she visited again in 2009?
19 A I don't remember exact times but I know I saw her
20 there once.
21 Q Did you speak to Professor Campbell?
22 A Yes, I did.
23 Q And were you interviewed by Professor Campbell?
24 A Yes, I was.
25 Q Do you know if anyone else from the Oler side of
26 the FLDS side of the Bountiful community was
27 interviewed by Professor Campbell?
28 A I don't know of anyone but I wouldn't necessarily
29 know that.
30 Q When you were preparing your affidavit that was
31 filed in this matter --
32 A Yes.
33 Q Did you speak to your husband about the contents
34 of your affidavit?
35 A He was aware I was writing it. He didn't -- but
36 as far as -- I did discuss it with him.
37 Q And did you speak to any of the church leaders
38 about your affidavit?
39 A I think it was actually the bishop that -- it was
40 the bishop was the one that got a hold of me and
41 wanted me to write it. I can't remember exactly
42 but I think that's how it happened.
43 Q And I think you testified earlier that you knew of
44 women in the Bountiful community who had moved to
45 Canada to marry men up here; is that correct?
46 A Yes.
47 Q And I believe you said you were aware of roughly
67
1 nine to ten?
2 A That I've been in -- in close contact with so that
3 I would know them.
4 MR. REIMER: Sorry, My Lord. We have the unique
5 situation of the phone ringing without a court
6 clerk here.
7 THE COURT: Oh.
8 MR. REIMER:
9 Q And just to come back to -- I believe your earlier
10 testimony was that you knew nine to ten teenage
11 girls who came to Canada from the US to marry; is
12 that correct?
13 A Yes.
14 Q And these teenage girls had come to Canada from
15 the United States?
16 A Yes.
17 Q And they were married to men up here after they
18 arrived in Canada?
19 A Not always. They might have been married before
20 they came.
21 Q But they were marrying men from the Bountiful
22 community?
23 A Yes.
24 Q Or are you saying that they -- so the marriages
25 might have been in the States?
26 A Yes.
27 Q But then both --
28 A Yes.
29 Q -- or the couple would have moved back up to
30 Canada?
31 A Yes.
32 Q And in paragraph 13 of your affidavit you talk
33 about -- you say -- I'll let you get that in front
34 of you. It's a short quote here. In paragraph 13
35 you say "we have an extremely hard time helping
36 women immigrate when they marry as a plural
37 spouse, as it is very hard to get medical
38 insurance." Can I ask you who are referring to
39 when you say "we" there in paragraph 13?
40 MR. WICKETT: I rise only, My Lord, is my learned
41 friend asking -- I'm sorry to ask a question,
42 My Lord, is my learned friend asking for names, or
43 is he referring to people within the community?
44 If he's asking for names I'm objecting to it.
45 MR. REIMER: No, I understand that. I wasn't actually
46 asking for specific names, but perhaps a little
47 more detail than rather than just "we" -- is it
68
1 church leaders, the community.

2 THE COURT: Okay.
3 THE WITNESS: In response to your question I have just
4 taken a personal interest in immigration and when
5 I say "we" I'm referring to myself and the
6 particular woman I guess, and no -- not church
7 leaders.
8 Q Okay. Do you know how these girls are coming into
9 Canada? In other words, are they flying in or are
10 they driving in? Do you know?
11 A As far as I know driving.
12 Q And do you know what these girls' immigration
13 status is? Do you know what status they are
14 coming into Canada as?
15 A They are coming on initially a visitors permit and
16 then they make a spousal application. You're
17 talking about plural wives.
18 Q I believe in your affidavit you were talking about
19 them coming in as plural wives?
20 A That's right. Correct. Okay. So they -- every
21 incidence is different but they may come in on a
22 visitor record or a student record and once they
23 have established a way to be in Canada legally
24 then they go forward -- they've gone forward with
25 that.
26 Q And I'm just interested in exploring that a bit.
27 You say they come in as visitors, or you suggested
28 students. They're getting married to men up here
29 in Canada; is that correct?
30 A That is the -- yes.
31 Q And these are second or third or fourth wives?
32 These are the plural wives of these men?
33 A Yes.
34 Q And then you say after they've been up here and
35 figure out a way to stay they proceed with that.
36 I'm just curious, are they renewing their visitor
37 status?
38 A When it runs out they do. Or a student status.
39 Q And are these women who are marrying men in Canada
40 as far as you know intending to leave the country?
41 A If they do not get legal status they do.
42 Q And do they, in fact, leave the country?
43 A In fact, what, sorry?
44 Q And sorry, do they, in fact, leave Canada when
45 their visitor status expires?
46 A Yes, they do.
47 Q And where do they go?
69
1 A Into Idaho.
2 Q And do they stay in Idaho?
3 A Until an application is approved.
4 Q Sorry, what sort of application?
5 A A -- for example, if it was a plural wife
6 situation she may legally marry the man if he
7 wasn't legally married to his first wife or get
8 status through completing a course of education.
9 Q Sorry, they come into Canada as students then to
10 complete that course of education?
11 A Yes. Or make an application. Sorry.
12 Q Sorry. Go ahead.
13 A It has been my experience you can make an
14 application as a common law partner as well.
15 Q And are they disclosing in their application that
16 their husband is married to somebody else?
17 A He hasn't been in the case I've been involved in.
18 Q Not legally married but had he been celestially
19 married?
20 A It is my understanding with immigration that you
21 can have previous partners, and so we've told them
22 the truth.
23 Q So -- you say since you've been involved in these
24 you've been telling immigration that --
25 A That yes --
26 Q Or informing immigration that, yes, their husband
27 is actually in another relationship?
28 A Yes. I'm just speaking for one case, the case I'm
29 involved in.
30 Q And in that case has the individual, the woman,
31 the girl involved gotten immigration status here
32 in Canada?
33 A She's working on it.
34 Q How long has that application been outstanding?
35 A It's been about eight months. She's living in the
36 States.
37 Q Sorry. Both of them are or she is?
38 A She is.
39 Q And her husband is up in Bountiful?
40 A Yes.
41 Q Do you think that it would be easier for these
42 women to immigrate legally to Canada if polygamy
43 were decriminalized?
44 A I don't know. I would hope.
45 Q Now, you've been talking about girls coming up to
46 Canada from the United States -- teenage girls
47 coming Canada from the United States to marry men
70
1 up here. Are you aware of any girls from

2 Bountiful going down to the United States to marry
3 men down there?
4 A Yes.
5 Q Approximately how many?
6 A I would not be able to give you a -- I don't know.
7 Let me think. I could count up of approximately
8 the same amount. Maybe eight.
9 Q And again these are teenage girls going down to
10 the United States?
11 A Well, teenage being under 20. I mean anywhere --
12 yes.
13 Q And are you aware of any girls going down to the
14 United States from Bountiful after June of 2008?
15 A No.
16 Q You're clearly aware that polygamy is currently
17 illegal in Canada; is that right?
18 A Yes.
19 Q And how long have you known that polygamy is
20 illegal in Canada?
21 A Probably as long as I can remember.
22 Q And do you know when the last prosecution -- the
23 last criminal prosecution for polygamy in Canada
24 was?
25 A In terms of someone was prosecuted? I don't --
26 Q Yes.
27 A Where they went to jail?
28 Q Well, where charges were laid against them and
29 yes, they were brought to trial.
30 A No, I don't.
31 Q Do you know if there's ever been a prosecution in
32 Canada for polygamy?
33 A I have heard there hasn't been. But I don't know
34 that.
35 Q And if polygamy were being prosecuted regularly in
36 Canada would you still practice polygamy?
37 A I would find it very difficult.
38 MR. REIMER: My Lord, I note the time and I note the
39 witness has been on the stand. Perhaps if we
40 could take a very short break I can confirm that
41 may be it. I suspect it probably is, but if I can
42 have a short break and then we return I appreciate
43 it.
44 THE COURT: Let's take a 10-minute break.
45 THE CLERK: Order in court. Court is adjourned for an
46 afternoon recess.
47
71
Cross-exam by Ms. Gaffar

2 (AFTERNOON RECESS)
3
5
6 WITNESS NO. 2, a witness
8
9 THE COURT: Mr. Reimer.
10 MR. REIMER: Yes, thank you, My Lord. After the break
11 I have no further questions. Thank you.
12 THE COURT: Thank you. Ms. Gaffar.
13 MS. GAFFAR: Thank you, Chief Justice. For the record
14 my name is Deanne Gaffar, G-a-f-f-a-r, on behalf
15 of West Coast LEAF.
16
17 CROSS-EXAMINATION BY MS. GAFFAR:
18 Q Madam, I know that you have been on the stand all
19 day and I can assure you that I will not be very
20 long in my questions.
21 May I ask you, please, to turn to the first
22 page of your affidavit which is Exhibit 79 in
23 these proceedings, paragraph 4. Can you just tell
24 me when you have reached that point.
25 A I'm looking at paragraph 4.
26 Q In the second sentence of paragraph 4 you refer to
27 the church leaders and I just wanted to ask you
28 very quickly about that. You have testified about
29 your prophet bishops and I believe you testified
30 about the priesthood. When you refer to church
31 leaders are you referring to the prophet, bishops
32 and the priesthood?
33 A It would be the bishop and prophet probably more
34 accurately.
35 Q Okay. There are also other figures in your church
36 called elders?
37 A Yes.
38 Q And are they too considered to be church leaders?
39 A I wouldn't say, no.
40 Q The one thing it is fair to say is that a woman
41 could never be a prophet, bishop or part of the
42 priesthood; correct?
43 A Yes.
44 Q In your particular community in Bountiful
45 Mr. James Oler is the bishop; correct?
46 A Yes.
47 Q And are you aware that the duties of a bishop are
72
1 set out the doctrines and covenants as well as

2 holy scripture; correct?
3 A I have never seen the duties of a bishop. I have
4 never studied that.
5 Q It's fair to say that when the prophet is not
6 present or exercising his authority over your
7 community the primary authority is the bishop;
8 correct?
9 A I wouldn't be able to say exactly how that would
10 work. I think there are high council members as
11 well.
12 Q High council members, are they the same as the
13 priesthood?
14 A Not necessarily.
15 Q Is there anyone higher in rank in the community
16 that lives in the community than the bishop?
17 A No.
18 Q From the earliest age when you were growing up you
19 were taught about the doctrine and covenants and
20 holy scriptures at home; correct?
21 A At home and when I attended meetings, church on
22 Sunday.
23 Q Yes, that was my -- yes. That was my next
24 question. You were taught about doctrine,
25 covenants and holy scripture in church?
26 A Yes.
27 Q Each week; correct?
28 A Yes.
29 Q And you testified that recordings or broadcasts by
30 the prophet were played at church; correct?
31 A They have been in the last while but when I was
32 growing up, no.
33 Q The bishop delivers sermons in church; correct?
34 A Yes.
35 Q And you were taught about your faith when you
36 attended school; correct?
37 A We studied church history in school.
38 Q FLDS church history?
39 A The -- yes. The Mormon -- Latter-day Saints --
40 fundamentalist -- yes.
41 Q I know, it's been a long day.
42 While you were attending school there were
43 also daily assemblies at which time the prophet's
44 teachings were either read out or recordings
45 played; correct?
46 A Not while I attended school, no.
47 Q But you learned that that has since been done in
73
1 the schools?
2 A I could not comment on that.
3 Q And there were certainly pictures of the prophets
4 in the entrance foyer area of the school; correct?
5 A Yes.
6 Q So it's fair to say with this extensive teaching
7 and instruction of your faith, both at -- well, at
8 home, church and school, you were expected to know
9 the doctrines and covenants of your faith;
10 correct?
11 A Yes, I -- I know of them.
12 Q Well, you were being taught --
13 A Yes.
14 Q -- those doctrines and covenants?
15 A That's right, yes.
16 Q Expected to know them?
17 A Not off by heart, but know -- we -- they were
18 referred to, yes.
19 Q And you were supposed -- you were expected to live
20 your life according to the doctrines and
21 covenants?
22 A Yes.
23 Q I have read from information provided by your
24 current bishop about something called the law of
25 consecration and stewardship which is also known
26 as the United Order of Heaven. And that is a
27 principle that requires essentially church members
28 to turn over their property to the bishop of the
29 church. You're aware of that doctrine; correct?
30 A I am aware of the doctrine that was preached in
31 Joseph Smith's time about United Effort Plan or
32 united effort. Living United Order. Is that what
33 you said?
34 Q No, I'm talking about the law of consecration and
35 stewardship otherwise known as the United Order of
36 Heaven that was established in 1831 and comprises
37 section 42 of the doctrine and covenants.
38 A That's right. I am aware.
39 Q And that is the doctrine that requires members to
40 turn over their property to the bishop of the
41 church; correct?
42 A It does require them to consecrate, yes.
43 Q In your life have you ever owned any property or
44 house or land in Bountiful?
45 A I own land that -- no, not in Bountiful, no.
46 Q Has your husband?
47 A No.
74
1 Q In Bountiful?
2 A No.
3 Q You worked -- or you work full-time, your sister
4 wife works full-time, your husband works
5 full-time. From the income that you make how much
6 do you turn over to the bishop?
7 A As I said before we turn over -- well, I guess I
8 didn't mention the tithing. We turn over a tenth.
9 Q One-tenth of your income goes to the church --
10 A Yes.
11 Q -- as a tithing?
12 A Yes.
13 Q And this is in addition to the requested monies
14 for assisting the legal defence of individuals
15 charged in the United States?
16 A Yes. That's correct.
17 Q You testified that you were interviewed by Angela
18 Campbell; correct?
19 A Yes. Yes.
20 Q How did you come to speak to Angela Campbell?
21 A I think my name was given by a friend to her and
22 then she called me on the phone.
23 Q Prior to speaking to Angela Campbell did you
24 discuss the prospect of speaking with Angela
25 Campbell with church leaders?
26 A No.
27 Q So when you were interviewed by Angela Campbell
28 are you saying that none of the church leaders in
29 your community knew?
30 A That is correct.
31 Q Did your husband know?
32 A I think I told him after.
33 MS. GAFFAR: Thank you, Chief Justice. Those are my
34 questions.
35 THE COURT: Thank you. Any other cross? No. Any
36 redirect, Mr. Wickett?
37 MR. WICKETT: You'll be glad to hear that I have no
38 redirect.
39 THE COURT: Thank you. Thank you very much, witness,
40 for coming to court.
41 THE WITNESS: You're welcome.
42
43 (WITNESS EXCUSED)
44
45 MR. WICKETT: My Lord, I note the time. I don't think
46 there's any point in starting with the next
47 witness. I wonder whether my friends -- we had
75
Certification
1 thought we were going to get two witnesses done

2 today, particularly since my examination in direct
3 was rather brief. We've managed to go all day. I
4 wonder if my friend Mr. Jones has a sense of how
5 long the cross-examinations for the remaining
6 witnesses might be.
7 MR. JONES: I think I can happily advise that they will
8 be much shorter than today. I explained to my
9 friend Mr. Wickett prior to this hearing that we'd
10 make our efforts to divide the questions so that
11 they tend to be focussed on areas that were
12 discussed by the affiants and to avoid repetition
13 where it's not necessary. So with that in mind I
14 think we front loaded a fair number of the
15 questions today, but we'll have different
16 questions tomorrow. I think we're in good shape
17 to finish both witnesses tomorrow.
18 THE COURT: Good. Okay. Anything else before we
19 break?
20 MR. WICKETT: Nothing, My Lord.
21 THE COURT: Thank you very much. Tomorrow morning.
22 THE CLERK: Order in court. Court is adjourned until
23 January 26th, 2011 at 10 a.m.
24
25 (PROCEEDINGS RECESSED AT 3:55 P.M.)
26
27 I, SPENCER J. CHAREST, OFFICIAL REPORTER
28 IN THE PROVINCE OF BRITISH COLUMBIA, CANADA,
29 DO HEREBY CERTIFY:
30
31 THAT THE PROCEEDINGS WERE TAKEN DOWN BY
32 ME IN SHORTHAND AT THE TIME AND PLACE HEREIN
33 SET FORTH AND THEREAFTER TRANSCRIBED, AND THE
34 SAME IS A TRUE AND CORRECT AND COMPLETE
35 TRANSCRIPT OF SAID PROCEEDINGS TO THE BEST OF
36 MY SKILL AND ABILITY.
37
38 IN WITNESS WHEREOF, I HAVE HEREUNTO
39 SUBSCRIBED MY NAME THIS 17TH DAY OF FEBRUARY
40 2011.
41
42
43
44 ______________________
45 SPENCER J. CHAREST
46 OFFICIAL REPORTER
47

1-25-11transcript Canadian Reference Case On Polygamy - Day26 Testimony & Cross Examination of Witness # 2

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1-25-11transcript Canadian Reference Case On Polygamy - Day26 Testimony & Cross Examination of Witness # 2

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1

1 January 25, 2011

1 the raw data from the education authorities that

1 MR. WICKETT: Yes, My Lord, we are.

1 Q With respect to those that have stayed within the

1 Q And after those six years did you achieve a

1 him well I knew he was in good standing with the

1 through and made a request to the prophet which

1 three or four months ago and stay with my

1 MS. GAFFAR: My Lord, it's Deanne Gaffar for the West

1 the community of Bountiful; is that correct?

1 Q And there is no one living in Bountiful that is

1 Mr. Blackmore's group; is that right?

1 Street and Canyon Lister Road?

1 members of the FLDS community lived in Creston as

1 A I don't know that, no.

1 Q And you -- you mentioned the last time you went

1 members in the United States. That was rather

1 if I don't. And I will spell it in case my

1 Q Have you ever not followed one of the directions

1 Q And so the one four years ago, the prophet was

1 Q And most people, you're talking most people within

1 you explain what a priesthood head is.

1 will act in our best interests.

1 A I am not really sure if I could give a good

1 A I did as a young girl. I don't know -- I can't

1 A I don't -- I don't think that -- I wasn't really

1 definitely did that. I particularly -- I don't

1 A It could -- I suppose it could be considered by

1 married at 15; is that correct?

1 besides your own?

1 MS. GREATHEAD: Fine, My Lord. I will move on.

1 write the prophet once a month?

1 marriage. So I'm wondering, is it fair to say

1 attended the same school you did and then went on

1 A Yes. The men facing charges. Yes.

1 Q So there's 19 children in your family?

1 And they were very much aware of the raid in the

1 they live separately for awhile.

1 know the people at all or the names.

1 Q You mentioned that your brother had left the

1 Q And Terrence Oler?

1 Q Well, is it fair to say that when a man has 19

1 wife was not so good. Can you explain what you

1 put to the witness.

1 into the record and then ask you a question about

1 covenants to obey her husband and he obeys

1 Q And so if some of those boys will have more than

1 you; is that right?

1 Q And the fifth child?

1 Q Witness, at paragraph 4 of your affidavit you talk

1 church leaders, the community.

1 up here. Are you aware of any girls from

1 (WITNESS STOOD DOWN)

1 set out the doctrines and covenants as well as

1 thought we were going to get two witnesses done

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