1 26 11 Transcript Day27 Canadian Reference Case On Polygamy

1
Witness No. 4 (for FLDS)

In chief by Mr. Wickett
1 January 26, 2011

2 Vancouver, B.C.
3
4 (DAY 27)
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 26th day of
9 January, 2011, calling the matter concerning the
10 constitutionality of section 293 of the Criminal
11 Code, My Lord.
12 THE COURT: Thank you. Mr. Wickett.
13 MR. WICKETT: Yes, My Lord, the next witness is Witness
14 No. 4. If she could perhaps be sworn, please.
15
16 WITNESS NO. 4, a witness,
17 called by the FLDS, sworn.
18
19 EXAMINATION IN CHIEF BY MR. WICKETT:
20 Q I'll ask you, witness 4, to keep your voice up,
21 please, so we can all hear you.
22 A Okay.
23 Q You are currently age 24?
24 A Yes.
25 Q You were born in the town of Hildale in Utah to an
26 FLDS family but you grew up in a community other
27 than Hildale; correct?
28 A Yes.
29 Q And you moved to the Bountiful community near
30 Creston when you married a person in that
31 community; is that correct?
32 A Yes.
33 Q How old were you when you were married?
34 A 17.
35 Q Do you have any children?
36 A Yes, I have one child.
37 Q And how old is your child?
38 A 5.
39 Q Could you explain to His Lordship, please, your
40 understanding of the covenant in marriage in the
41 FLDS?
42 A I believe that a man and wife are sealed together
43 for time and all eternity.
44 Q And what, if any, role does plural marriage play
45 in that covenant?
46 A Plural marriage -- celestial and plural marriage
47 is something that I have to enter and abide to
2
1 gain my highest degree in the celestial kingdom.

2 Q In your case, and I'm speaking of your own
3 marriage, can you explain to His Lordship, please,
4 how that came about, what the process was.
5 A Yes. I was 17 years old and I wanted to be
6 married. I was praying about it to heavenly
7 father. One night I had a dream. In this dream I
8 stood up like I was married to someone and I saw
9 their face. I went to my father later and I asked
10 him if I could be married. He asked me if I felt
11 like I was ready, and I did. I felt like I was
12 prepared. He said, well, keep praying about it
13 and we'll see what happens. So I did and awhile
14 later he took me to the prophet and the prophet
15 asked me if I had anyone in mind. I told him I
16 didn't. Then later -- a week later I went back
17 and he said you're to be placed and he told me the
18 person I was to be placed by. It happened to be
19 the same person that I had seen in this dream but
20 I hadn't told him about the dream that I had. So
21 I felt like my marriage was a revelation from God
22 because it happened to be the same person I had
23 seen in the dream. And I accept that.
24 Q Thereafter you were married?
25 A Yes.
26 Q And you moved to Canada?
27 A Yes.
28 Q Your current immigration status in Canada, you're
29 on a student visa, I understand it?
30 A Yes.
31 Q And if that visa expires and your immigration --
32 you don't obtain permanent residency or other
33 lawful immigration status what will you be doing?
34 A I would be going back down to the States.
35 Q When you moved to Canada did you attend school?
36 A Yes, I did. I graduated from Bountiful Elementary
37 with grade 12.
38 Q And have you continued your schooling after
39 Grade 12?
40 A Yes, this is my third year in college in
41 Cranbrook. I am attending their business
42 administration program. Accounting major.
43 Q Okay. And that's a diploma program?
44 A Yes.
45 Q Why are you doing that?
46 A Because I want to go on and be an accountant and
47 have my own business eventually.
3
1 Q How did you come upon this plan? What made you
2 think of that?
3 A I just always wanted to be a bookkeeper, like,
4 work in an accounting office or have my own.
5 Q And what is your plan for the future in terms of
6 work?
7 A I am hoping to be done with my education by April
8 and then get a job in an office, like if they will
9 give me my work visa, get a job in an accounting
10 firm until I can break off on my own and start my
11 own business.
12 Q And is it your plan to work in your own business
13 in the Bountiful community or outside?
14 A Inside, like there's quite a few businesses I
15 could do their bookkeeping for them, their
16 year-end taxes.
17 Q Now, was this a plan that you formulated yourself
18 or did somebody tell you that you should do it?
19 A No, myself. I have always wanted to be a
20 bookkeeper, and after graduating from Bountiful
21 then I wanted to go on to college and obtain my
22 diploma degree in the accounting field.
23 Q I want to return to the subject of marriage for a
24 moment. You live in a plural marriage?
25 A I do.
26 Q You say in your affidavit at paragraph 5, I
27 believe, and I should pause there to say, My Lord,
28 I don't know that I dealt with the affidavit so
29 perhaps I should do that. Just pause for a
30 moment, Witness 4. You've sworn an affidavit in
31 this proceeding?
32 A Yes, I have.
33 Q Do you have that in front of you?
34 A Yes.
35 MR. WICKETT: And it, My Lord, is Exhibit.
36 THE COURT: 81.
37 MR. WICKETT: 81, thank you.
38 Q And signature on the third page of the affidavit
39 is your signature?
40 A Yes.
41 Q All right. Returning to the affidavit for a
42 moment. You say in paragraph 5 of your affidavit
43 that you believe that your marriage was made in
44 heaven. What do you mean by that and why did you
45 say that?
46 A I believe that before we come to earth we made
47 covenants as man and wife to be man and wife here
4
1 on earth as well as in the next life in eternity.

2 Q Looking back now -- you're 24 years old, looking
3 back on your decision did you make the right
4 decision for yourself?
5 A I do. I do feel like I have made the right
6 decision. I am happy where my station is in life.
7 Q Within your family arrangement how many children
8 are living in the household?
9 A There's 24.
10 Q How are the child care issues dealt with?
11 A I'm gone to college all week but I'm home on the
12 weekends, so I try to on the weekends to tend a
13 group of boys and a group of girls for two hours
14 in the weekend.
15 Q While you're away at college is someone looking
16 after your child?
17 A Yes, my sister wife.
18 Q How are your relationships -- how would you
19 describe your relationships with your -- let's
20 call them step children?
21 A Quite well. I really try to reach out to those
22 children and make them feel like that I love them
23 and I try to involve them with what I'm doing with
24 my own child.
25 Q There must from time to time be disagreements that
26 arise between the adults in your family?
27 A Yes.
28 Q How are those dealt with?
29 A Depending on what the situation is. You deal with
30 it. Like for myself, I really like to look to
31 myself if there's a problem or a disagreement in
32 the family. Is it something that I need to do
33 better, that I need to change. Do I need to go
34 off by myself for awhile and pray about it and try
35 to get the peace within me to overcome the
36 situation, or I approach someone else and talk to
37 them and see where I can help them out or what we
38 need to do to correct the situation and make it
39 better.
40 Q And to your knowledge do your sister wives share
41 that approach?
42 A As far as I know.
43 Q I shouldn't be asking you to speak for them.
44 Speaking about children for a moment, what is
45 the -- what is the approach with respect to
46 discipline of children in your household?
47 A Depending on what has happened. For myself, I try
5
1 get down and talk to the child. Maybe they didn't

2 understand what I asked. Or removal of a
3 privilege works. I really try to deal with them
4 with a sweet peace and maintain heavenly father
5 spirit with me all the time in dealing with that
6 child that I can be inspired.
7 Q Is physical violence or discipline used in your
8 household?
9 A No. Sometimes I'll get a hold of the child by the
10 hand and say, come on now, this is what I've
11 asked, but I don't ever physically strike them,
12 thump them, pull their hair. Whatever.
13 Q Now, I can imagine with so many people in your
14 household that there are some unique challenges
15 that arise in a plural marriage with a lot of
16 children. What is your approach generally to
17 dealing with problems that might be expected to
18 arise in a household with so many people?
19 A You always are going to be bumping shoulders, like
20 you want to rub off the sharp edges. Learn to get
21 along with someone. Learn -- see where you can
22 actually sacrifice of your own selfish wills and
23 feelings to help someone else out. I really find
24 a peace in myself when I'm blessing and helping
25 someone in the family and helping us to get along.
26 Q Now, other than the Bountiful area -- immediate
27 area around Bountiful and Utah, have you visited
28 any other communities in British Columbia?
29 A I have. I've been to Vancouver. I have been to
30 Sundre in Alberta. Calgary. I've been as far as
31 Dawson Creek.
32 Q And in the United States, have you visited any
33 other places there other than in Utah?
34 A Yes. I've been to California. San Diego, Los
35 Angeles, down there. Lancaster. I have been to
36 Seattle, Washington. I have been in Colorado.
37 Q What were you doing on those visits?
38 A We went to San Diego, like to the beach. I've
39 been down there. I've been to the Space Needle
40 Seattle, like ridden that Space Needle. In
41 Colorado I went over there to visit a farm and see
42 how they have grown some of their crops over
43 there.
44 Q And what were you doing in Las Vegas?
45 A Playing. Having a good time. I've been on the
46 space needle there. Just spent about a week there
47 just playing around.
6
Cross-exam by Mr. Jones
1 Q And whatever observations you've made about those

2 places that you visited have you formed any
3 opinions about where you want to live?
4 A Yes, I like a quiet place. Vancouver is a little
5 intimidating to me, like the big buildings, a lot
6 of people. Just always so much happening, like
7 it's a little confusing to me. I really like just
8 a small town, quiet.
9 Q And you've probably heard, if not from me from the
10 news media, that there's a sense that your
11 community of Bountiful is isolated from mainstream
12 society. You've heard that?
13 A Yes, I've heard that.
14 Q How do you feel about that?
15 A That doesn't really bother me. I do try to
16 isolate myself. I mean, I go to college. I'm out
17 there all the time and I see things that go on,
18 but I really like to come back to the peaceful
19 feeling of everyone believes the same, everyone
20 accepts you how you are within our community. Our
21 home.
22 Q What are your plans for the future? What are your
23 dreams for the future?
24 A I want to go on and start my business, like get my
25 work experience done and start my own business and
26 just live in peace. I just like to live in a
27 peaceful environment.
28 MR. WICKETT: Thank you very much. Those are my
29 questions, My Lord.
30 THE COURT: Thank you. Could I have an indication of
31 who will be cross-examining.
32 MR. JONES: My Lord, it's Craig Jones. I'll be
33 crossing for the Attorney General of British
34 Columbia. I believe --
35 MR. REIMER: My Lord, I'm not sure if you can hear me
36 from back here.
37 THE COURT: I can.
38 MR. JONES: Canada may be cross-examining but they're
39 not sure which counsel at this point.
40 THE COURT: Okay.
41 MR. JONES: And I'm not seeing any indication anybody
42 else will be, My Lord.
43 THE COURT: Thank you Mr. Jones. Go ahead.
44
45 CROSS-EXAMINATION BY MR. JONES:
46 Q Witness 4, as I just said, my name is Craig Jones
47 and I represent the Attorney General of British
7
1 Columbia. I appreciate that it's difficult for

2 you to be here today. I wanted to thank you for
3 coming giving your evidence and helping this court
4 understand your way of live. I'm going to try to
5 be brief and get you back to your family and on
6 with your life, away from all these big buildings,
7 as soon as you can.
8 I'm going to ask you some questions and I hope
9 that it's going to give His Lordship and all of us
10 a clearer picture of life in a polygamous family,
11 as Mr. Wickett's questions did as well. But it's
12 a little bit difficult, and I just wanted to
13 preface this, because I can't see you I want to
14 make sure your answers are as full as possible so
15 please don't hesitate to interrupt me if I start
16 to talk over you. It's not quite as interactive
17 as I prefer it. But I hear you clearly and I take
18 it you can hear me clearly as well?
19 A Yes, I can.
20 Q Thank you. I want to talk about life in your
21 family and Mr. Wickett touched on your
22 relationships with your sister wives and you
23 describe this at paragraph 10 of your affidavit.
24 At -- sorry, paragraph 9 you say you're privileged
25 to have four sweet and loving sister wives to live
26 with, and you go on to describe a little bit about
27 your interrelationship. You've spoken with
28 Mr. Wickett about that. And this Court has heard
29 some evidence that, from some women in polygamy at
30 least, one of the best parts of plural marriage is
31 the relationships that can develop among the
32 sister wives. Would you agree with that?
33 A Yes.
34 Q And you would say you were very close to all your
35 sister wives?
36 A Yes.
37 Q And you all live together, I take it?
38 A Yes, we do. We're all in one house.
39 Q And do you spend a lot of time talking to one
40 another? Do you do -- well, let me ask that
41 question first. Do you spend a lot of time
42 talking to one another?
43 A Yes, I do.
44 Q And do you do particular activities together?
45 Could you give the court some idea of sort of what
46 sorts of things the sister wives would do
47 together.
8
1 A We have meetings. We try to every night, like

2 meet. Sometimes, you know, someone might not be
3 there because they had to stay overnight at where
4 ever, like if your child is in the hospital or
5 sometimes I can't make it home at night after
6 going to college so I'm not there. But we do try
7 to meet every night and talk over the day's
8 events, you know, what happened in everybody's --
9 whatever job it was that they were doing that day.
10 And they talk about the children and just see, you
11 know, if there's something we need to change or,
12 you know, just have a good time together.
13 Q And do you do stuff like cooperate in child care
14 so several of the sister wives might get together
15 with several of the children and do activities,
16 that sort of thing?
17 A Yes, we do a lot of family home evenings. We go
18 on walks. We go to the park sometimes. We have a
19 big basketball court outside of our place. We
20 play basketball or roller skate with the children.
21 Take them swimming in the summertime. Skating in
22 the wintertime.
23 Q His Lordship has heard and, again I apologize, I
24 can't see you, but he's heard of the distinctive
25 dress of the women in the FLDS communities. And
26 our understanding at least at this point is that
27 for women the dress is generally ankle length and
28 to the wrist; is that correct?
29 A I like to be fully covered. Yes. Like your
30 dresses don't necessarily have to go right to your
31 ankle but, you know, down in that area I guess.
32 Q Sure. And is there any rule or -- is there any
33 rule with respect to patterns on the dresses or
34 colours?
35 A No. I have a variety of colours and patterns in
36 my clothing.
37 Q And in your house do the wives make the clothes?
38 A Yes. Or the older girls.
39 Q And all of them participate in that, the older
40 girls and the wives?
41 A Two different levels. I don't sew as much as
42 someone else might. I'm going to college quite a
43 bit but, you know, depending if someone really
44 likes to sew then that's what they do a lot.
45 Other people would prefer to do something
46 different.
47 Q Sure. Would you say that you know your sister
9
1 wives as well as you know your real brothers and

2 sisters?
3 A Yes.
4 Q Or your best friends?
5 A Yes.
6 Q Is there anyone apart from your husband and your
7 children that you would say you're closer to than
8 your sister wives?
9 A No. I mean, I have friends or, you know, people
10 who I know outside of my immediate family but I
11 wouldn't say I have a more personal relationship
12 with them than I do with my sister wives.
13 Q Okay. So I'm just going to ask you some questions
14 just to sort of gauge the depth of the sister
15 wives' knowledge of one another and I want to be
16 clear that I'm not actually asking -- let me put
17 it this way. I'm going to ask you if you know all
18 your sister wives' children's names but I don't
19 want you to say any names. Do you understand?
20 A Yes, I do. And yes, I know all my sister wives'
21 children's names.
22 Q Great. Okay. And do you know all of their
23 birthdays? And again, please don't give any of
24 their birthdays.
25 A I know some of them. I don't remember them all
26 the time. Dates aren't a real important thing in
27 my life. It is to other ones of my sister wives,
28 but no, I couldn't just name off the top of my
29 head every one of their birthdays.
30 Q Sure.
31 A But I know, you know, about the month or whatever.
32 Q Right. Okay. And we haven't heard any evidence
33 on this, but do you celebrate birthdays in the
34 FLDS?
35 A Yes. Celebrate -- we don't actually use that
36 word, but we do, you know, we'll make a cake for
37 that person and, you know, give them some gifts,
38 make them some new clothes or buy them something.
39 We try to make it special for them on that day.
40 Q And then that would go both for the children of
41 the household and for the sister wives and the
42 husband?
43 A Right.
44 Q Okay. And with respect to your sister wives you
45 would know where they were born and where they
46 grew up?
47 A Mostly. I mean I don't know -- I might not know
10
1 exactly, you know, whether it was Creston or

2 Lister, but in the general area, yes.
3 Q Sure. Okay. And you would know about their
4 educational background?
5 A Yes.
6 Q With respect to one another's families do you
7 know -- do you know who their families are and do
8 you have sort of contact with one another's
9 families, your in-laws I guess I would put it?
10 A Yes. They come around some or we've gone over to
11 their place some.
12 Q And do you celebrate -- sorry, I know you don't
13 like that term.
14 A No, that's fine.
15 Q Do you acknowledge -- okay, I'll use the word
16 "celebrate" -- I'm not trying to impose it on
17 you -- anniversaries, marriage anniversaries,
18 wedding anniversaries of the sister wives?
19 A Yes. We do.
20 Q Are those celebrated?
21 A Yes.
22 Q And so all the sister wives would gather together
23 and maybe the family and acknowledge at least the
24 day as the anniversary date?
25 A Yes.
26 Q My hat is off to you for being able to remember,
27 when I get in trouble for not remembering one.
28 Do you know how old your sister wives are?
29 A Within a range. I might not know the exact -- you
30 know, age isn't really a big thing to me.
31 Q Sure. Okay. I read some suggestion that often
32 sister wives who are closest in age to one another
33 are closer to one -- are closer to one another,
34 sort of better friends. Is that a fair
35 characterization of relationships in your
36 household?
37 A No, not in my personal life.
38 Q Okay. You've described the circumstances a little
39 bit about your own marriage and I want to ask you
40 a little more about that later on, but first I
41 wanted to explore sort of what happens among the
42 sister wives when a new wife joins the household.
43 I'm going to assume that you're one of your
44 husband's younger wives. Do you have a sister
45 wife who has joined the family after you?
46 A Yes.
47 Q And how long had you been married before this new
11
1 sister wife joined your family?

2 A I don't remember the exact day but at least half a
3 year.
4 Q And the sister wife that joined after you, was she
5 older or younger than you?
6 A Younger.
7 Q How much younger?
8 A Again, I don't know the exact but at least a
9 couple years.
10 Q Now, you've said that you're 24. You've been
11 married for seven years as I do the math, because
12 you said you were 17. So your marriage occurred
13 after the split in 2002; is that right?
14 A Yes.
15 Q And it follows then that the sister wife who
16 joined half a year later was also after the split,
17 but perhaps you can just confirm that.
18 A Yes.
19 Q And let me just explore how that happens. So how
20 do you and the other sister wives become aware
21 that there's a new sister wife in the family?
22 A We're told.
23 Q And told by whom?
24 A I was told by my husband.
25 Q And were you told by your husband before or after
26 the wedding ceremony?
27 A After.
28 Q Had you met your new sister wife previously?
29 A Yes, I knew of her before.
30 Q I'm sorry, you said you knew of her. Had you met
31 her?
32 A Like what do you mean, directly before or just
33 knew her growing up or?
34 Q Prior to -- well, maybe I'll just ask it that way.
35 Did you know her growing up?
36 A Yes, I did.
37 Q So your sister wife joined your family from the
38 United States as well?
39 A Yes.
40 Q And I take it from what you've said that you
41 didn't have any role in the wedding ceremony. Did
42 any of your other sister wives attend the wedding
43 ceremony?
44 A No.
45 Q And so they learned of the wedding the same way
46 you did, that your husband told them?
47 A Yes.
12
1 Q And the wedding itself occurred in the United

2 States?
3 A I don't know that.
4 Q No one has ever told you?
5 A No.
6 Q Where the wedding occurred?
7 A No.
8 Q And you don't know who officiated at the wedding,
9 or do you?
10 A You mean who performed the sealing?
11 Q That's right.
12 A I can assume, but, no, I wasn't there to witness
13 it.
14 Q And you would assume because the prophet performs
15 the sealing ceremonies; is that right?
16 A Yes.
17 Q And the prophet is in the United States?
18 A He has been in a number of places, yes.
19 Q The prophet is based, at least at all these
20 relevant times, in the Hildale, Colorado City
21 area; is that correct?
22 A He has a home there, yes.
23 Q Does he have a home in Canada?
24 A No.
25 Q But he visits Bountiful, or at least did from time
26 to time?
27 A Yes.
28 Q Is that right? And when he visits Canada it's
29 pretty big news in the FLDS community? Yes?
30 A He actually has not visited in awhile. But yes, I
31 would assume it would be very great news in there.
32 Q And the prophet to your understanding is Warren
33 Jeffs?
34 A Yes.
35 Q And at all the relevant times we're talking about
36 from 2002 onwards it's been Warren Jeffs?
37 A Yes.
38 Q So just to sort of summarize where we're at so
39 far, you were married at 17 in the United States
40 in 2003 and you moved to Canada at that time to be
41 with your husband and family; is that right?
42 A Yes, I was married at 17 and then moved to Canada.
43 Q And then six months later your husband brought to
44 Canada his new wife?
45 A Around that time.
46 Q Is that right?
47 A I'm not sure if it was exactly six months.
13
1 Q Yes, I'm sorry. You said half a year and I

2 appreciate that's rough and I don't need to nail
3 down precise dates. And at that time this bride,
4 the sister wife was 15 years old; right?
5 A Yes.
6 Q Prior to your being informed after the wedding
7 that you would be joined by a new wife, had your
8 husband ever discussed with you and to your
9 knowledge the other sister wives the possibility
10 of bringing in a girl so young?
11 A We had talked about, you know, having other sister
12 wives join our family.
13 Q I guess the point of the question wasn't so much
14 the idea of a new wife but rather the idea of a
15 girl of 15 being the new wife. Had that ever been
16 discussed?
17 A Age had never been discussed.
18 Q And the new sister wife, the 15-year-old, she was
19 to your knowledge -- she had been raised in the
20 FLDS?
21 A Yes.
22 Q I don't need exact ages, but how old was your
23 husband at the time you married?
24 A Again age is not really a big issue to me, but I
25 think he was in his late 30s, early 40s.
26 Q When your new sister wife came to Canada was she,
27 like you, on a student visa?
28 A When I very first came to Canada I wasn't at that
29 moment on a student visa.
30 Q I'm sorry, I wasn't sure if your answer was with
31 respect to you or your sister wife. I was asking
32 about your sister wife. Do you know what her
33 status was?
34 A I do not know.
35 Q When she came across the border do you know who
36 she came with?
37 A I don't know.
38 Q She just arrived at your house by herself or with
39 your husband?
40 A Neither.
41 Q Who did she arrive with, and I don't want any
42 names.
43 MR. WICKETT: Well --
44 THE WITNESS: Other family members.
45 THE COURT: Sorry, just a second.
46 MR. WICKETT: I'm sorry. How is she -- the question is
47 who does she arrive with. How does she answer
14
1 that without giving a name?

2 MR. JONES: Well, I'm trying to be excessively
3 cautious, My Lord. I think she said other family
4 members and that's fine for my -- it's the
5 relationship that I wanted to get at, not any
6 identities.
7 THE COURT: Okay. Thank you. And the answer then was
8 other family members?
9 THE WITNESS: Yes.
10 MR. JONES:
11 Q And were these family members from the United
12 States or were they family members from Canada?
13 A The United States.
14 Q And do you know if when she came across the border
15 with her family members from the United States she
16 had a letter with her from her parents?
18 Q It was not her parents that she came up with from
19 the United States; is that correct?
20 MR. WICKETT: Objection. The same objection. It's
21 fine to say "family members" but I don't want any
22 questions or I object to any questions that tend
23 to identify who was with her.
24 THE COURT: Okay. But --
25 MR. JONES: My Lord.
26 THE COURT: Okay. Fair enough. But the fact that it
27 may be her parents doesn't identify her.
28 MR. WICKETT: Indeed.
29 THE COURT: Okay. Is that your question, Mr. Jones?
30 MR. JONES: My question is just to determine that they
31 were family members, not her parents, My Lord.
32 THE COURT: Yes. Could you answer that, witness.
33 Thank you.
34 THE WITNESS: They were family members and not parents.
35 Is that --
36 THE COURT: He's asking if the family members
37 accompanying this young woman were not her
38 parents.
39 THE WITNESS: Her parents were present.
40 MR. JONES: That wasn't my question.
41 THE COURT: I misunderstood you, Mr. Jones.
42 MR. JONES:
43 Q My question was whether the ones that you
44 described as accompanying her, arriving with her,
45 were her parents or not. You said her parents
46 were present but I would like to know whether the
47 people that she arrived with were her parents?
15
1 A Okay. I don't know -- I guess her parents were

2 there. Does that sound better than saying
3 present. Her parents were there.
4 Q Her parents were there in your house?
5 A You asked who accompanied her across the border;
6 is that correct?
7 Q Well, I just want to get a picture of how this
8 looked, and I don't want to find out anybody's
9 identities. All I want to know is how did this
10 look. Were the parents waiting at the house. Did
11 she arrive in a car with other family members.
12 What did the arrival of this 15-year-old look
13 like?
14 A You mean who stepped out of the car?
15 Q Describe it however you like, Witness 4. I would
16 just like to get a picture of what --
17 A Okay. What I think you're asking me is who
18 arrived at the house when she arrived. Who
19 accompanied her across the border.
20 Q Let's start there.
21 A And I did say her parents were there. I used the
22 word "present." Excuse me for using that.
23 Q Well --
24 A Her parents were there.
25 Q When you say present where is there?
26 A Wherever she was.
27 Q So her parents did accompany her across the border
28 to your knowledge?
29 A Yes.
30 Q Now, when your sister wife, the 15-year-old, came
31 to Canada she entered Bountiful Elementary and
32 Secondary School?
33 A She has attended Bountiful Elementary.
34 Q So when she arrived what grade did she go into?
35 A 10. 9. I think it was 9. Sorry. Excuse me.
36 Q Thanks. And when she would attend school in this
37 first year when she went into Grade 9, would
38 anybody take her there from your family? Would
39 anybody accompany her from your family?
40 A I think I rode right by her on the bus. I
41 attended Bountiful school as well.
42 Q I see. So when you say "right by her," you mean
43 you both rode the bus to the school?
44 A Yes.
45 Q I know you've said ages aren't of particular
46 importance to you, but do you know if anyone at
47 the school reported to you or to your knowledge to
16
1 any other member of your family any concern or

2 questions about this 15-year-old or her marriage
3 to your husband?
4 A No, I am not aware of that.
5 Q And has anyone in the Bountiful community or did
6 anyone at that time express any concerns to you or
7 to your knowledge a member of your family
8 regarding the age of this girl at the time of her
9 marriage?
10 A Not that I'm aware of.
11 Q And would that be because this wasn't seen as
12 particularly abnormal or objectionable?
13 A That no one voiced concern?
14 Q That's right.
15 A Of her age, or concern?
16 Q Well, I guess we're trying to understand here a
17 culture that's obviously very different. I mean,
18 I think if I went to a foreign country, married a
19 15-year-old and brought her back to Canada I would
20 expect the police to be waiting for me rather than
21 a community in celebration.
22 THE COURT: Well --
23 MR. JONES: I'm trying to understand the reaction of
24 the community to the marriage of a 15-year-old to
25 a man who is in his late 30s or early 40s, and I'm
26 asking you whether the lack of a reaction was
27 because this wasn't seen as abnormal or
28 objectionable. Can you answer that?
29 THE COURT: Mr. Jones, there's an objection here.
30 MR. WICKETT: Indeed. The entire line of questioning
31 is objectionable. The witness herself has
32 testified as to her own age, and certainly
33 questions about how she felt and her situation are
34 proper, but to question her about how the
35 community felt, that is entirely, with respect,
36 improper.
37 THE COURT: Well, he can ask her if she heard any
38 concerns -- if she heard any concerns expressed in
39 the community, but she can't speculate on what the
40 community might have thought. I agree with that.
41 And you can ask her what she thought of the
42 arrangement. Go ahead, Mr. Jones.
43 MR. JONES: Thank you, My Lord.
44 Q Witness 4, can you tell me whether you had any
45 concerns about the arrangement?
46 A When I look at someone I don't look at age in
47 particular. I look at how someone acts, how
17
1 responsible or grown up, you might say. Age is

2 not really an issue to me. She seemed very
3 responsible.
4 Q After this 15-year-old joined your household did
5 you have any discussion with her about her right
6 to refuse sex?
7 A That's quite a personal matter.
8 Q Yes, it is.
9 A And so I don't really wander around discussing
10 that with other people.
11 Q So the answer is no?
12 A Correct.
13 Q Did you have any discussion with her about the
14 idea that she should hold off on having children
15 until later in life?
16 A I do not go around trying to sway other people's
17 opinion or choice in life. I make my own
18 decisions and I allow them the same privilege.
19 Q And would that go also for birth control, any
20 discussion about birth control?
21 A Same. I wouldn't discuss that with someone.
22 Q And how soon after she joined your family did this
23 girl have her first child?
24 A I don't know exactly. I could count. I'm not an
25 extreme math whiz, but she was 17.
26 Q I think that's good enough. Do you know if this
27 girl when she arrived had any immediate family
28 living at Bountiful?
29 A Yes, I do know of.
30 Q And that's immediate family; is that right?
31 A I -- what I mean is, yes, I know whether there was
32 immediate family or whether there wasn't.
33 Q Oh, I see. And was there?
34 A No.
35 Q I would like to turn to your own marriage, as I
36 said, Witness 4. You've said to Mr. Wickett that
37 you were born into your religion and raised in it
38 in the United States?
39 A Yes.
40 Q You remember that?
41 A Yes.
42 Q And I'm not going to identify any home towns, but
43 I believe you said that you were raised in an FLDS
44 community but not the Twin Cities or Short Creek
45 as we have heard it referred to; is that right?
46 A Yes.
47 Q Now, you've described the lead-up to your own
18
1 marriage, and it sounded to me like the process

2 took some time between the revelation that you
3 received and the dream and your actual marriage.
4 Can you tell His Lordship how long before the
5 wedding ceremony you learned of the identity of
6 your husband-to-be?
7 A Probably about half an hour.
8 Q When you were married were your new sister wives
9 at the ceremony?
10 A No.
11 Q Do you know how they learned of your wedding?
12 A He contacted them by phone.
13 Q When you say "he" do you mean your husband?
14 A Yes.
15 Q And was this after the ceremony or before?
16 A After.
17 Q Now, of the two circumstances -- I mean I guess
18 we're basing stuff off the two circumstances
19 you're aware of in this family, which is your own
20 wedding and the subsequent wedding to your sister
21 wife. If after finding out the identity of the
22 new sister wife the existing sister wives disagree
23 and don't want that person to be a sister wife,
24 what would they do?
25 A Probably voice it.
26 Q To whom?
27 A Their husband.
28 Q And would they have any other options apart from
29 voicing their displeasure to their husband?
30 A They could not accept it.
31 Q And how would that work to your understanding?
32 A I've never been in that situation before.
33 Q Is there any process that's ever been explained to
34 you for not accepting it?
35 A No.
36 Q How soon after your own wedding did you have your
37 child?
38 A I was 18.
39 Q And when you were married at 17 was it very soon
40 after your 17th birthday?
41 A That I had my child?
42 Q No, I'm sorry, I wasn't clear. Was your wedding
43 very soon after your 17th birthday?
44 A Quite close to it.
45 Q Within a month?
46 A Yes.
47 Q Within a week?
19
1 A Around that time.

2 Q So when you spoke earlier about the process by
3 which you decided to become married and had put
4 your name forward, as I understood it, and had the
5 discussions you had that you described taking over
6 a week, you were 16 at that time; is that right?
7 A Yes. I was 16 when I had the dream. Sorry.
8 Q No, no. I understand. So you're 16 when you had
9 the dream but you were also 16 when you started
10 discussing the possibility of getting married with
11 the church officials; is that correct?
12 A With my father. Yes.
13 Q Was it only with your father?
14 A That I asked him if I could placed in marriage,
15 yes.
16 Q Okay. So you asked that at 16 and he approved of
17 that at 16?
18 A He said, we'll see what happens. Keep praying
19 about it.
20 Q Okay. Now, you're aware, Witness 4, that since
21 2008 the church has announced a policy of not
22 marrying anybody below the age of legal marriage
23 in any particular jurisdiction?
24 A Yes.
25 Q Do you agree with that policy?
26 A I do.
27 Q Why?
28 A I just think that's a good age to be married. For
29 people nowadays.
30 Q What age is that?
31 A 18.
32 Q 18 is a good age to be married? Better than 15?
33 A 18 is a good age.
34 Q Better than 15?
35 A I guess.
36 Q Better than 17?
37 A Sure.
38 Q Do you as a sister wife feel that you are equal to
39 your husband in the household?
40 A Equal in terms of other sister wives or?
41 Q No, I'm sorry, I mean equal vis-a-vis your
42 husband?
43 A Equal as my husband?
44 Q Equal to your husband.
45 A I don't know if I understand what you mean.
46 Q I guess what I'm asking is if you consider
47 yourself to be equals in the relationship or if
20
1 you consider one to be more important than the

2 other?
3 A Equal in the relationship?
4 Q It sounds to me like you're struggling with the
5 concept.
6 A I don't know -- what do you mean, do I consider
7 myself as much of a human being as he is or what?
8 Q Well, I don't think there's any question that
9 you're a human being. I guess what I'm getting at
10 is this. If you have a 15-year-old girl marrying
11 a 40-something man --
12 A Okay.
13 Q -- does that cause you -- does that cause you any
14 concern with respect to the equality of that
15 relationship?
16 THE COURT: Just a sec.
17 MR. WICKETT: Again, My Lord, we're moving -- the type
18 of question my friend is seeking to ask is not
19 improper if it's phrased with respect to herself.
20 THE COURT: Right. Yes. Let's talk about -- sorry, go
21 ahead.
22 MR. JONES: I beg your pardon?
23 THE COURT: Well, I was thinking, the witness can speak
24 of her own experience. Why don't we draw on that.
25 MR. JONES: I'll move along, My Lord. Thank you.
26 Q Now, I don't want you to use any words suggesting
27 any particular position, Witness 4, but is it fair
28 to say that your husband enjoys a position of
29 status within the FLDS?
30 A We are all very grateful for our positions in
31 life, and I cannot speak for him because I don't
32 know exactly what he feels like.
33 Q I'm sorry. Perhaps I used the word "enjoys"
34 carelessly and that's what you focussed on.
35 Is it fair to say that your husband holds a
36 position of status within the FLDS?
37 A Yes.
38 Q Now I just want you to answer from your own
39 experience and your own attitudes. You are a
40 member of a household in which to your knowledge a
41 40-year-old, 40-something perhaps, has married a
42 15-year-old girl and the man has a position of
43 status within that girl's church. Would it ever
44 occur to you to discuss that situation with any
45 authority?
46 A To discuss someone else's life with authority?
47 No, that wouldn't occur to me.
21
1 Q It wouldn't occur to you to report that to the

2 police, for instance?
3 A If I felt like someone was doing something,
4 someone was in an abusive situation or was in
5 harm, being harmed of some sort, I would feel to
6 report that to authorities.
7 Q And if it was happening in your own home that
8 would give you a special responsibility, wouldn't
9 it?
10 A Yes.
11 Q And it's probably needless to add, but you never
12 did that with respect to this 15-year-old girl's
13 situation?
14 A Was that just a comment or you wanted me to
15 comment on that?
16 Q I want you to confirm that that was the case.
17 A That I happened to see someone in a harmful or
18 abusive situation and I didn't report?
19 Q No, ma'am. That you never reported to the police
20 or any other authority the 15-year-old's
21 situation?
22 A No.
23 Q And that to your knowledge no one else in the
24 Bountiful community ever reported it?
26 Q You don't know of any reporting?
27 A I don't have any idea what anybody else did or
28 said.
29 Q But you never received any inquiries that would
30 suggest somebody had or did you?
31 A No one ever came up to me and said I think there
32 is something serious happening, you should report
33 that to the police.
34 Q Okay. And you considered it God's will that this
35 15-year-old should marry your
36 40-something-year-old husband; is that correct?
37 A That it was a revelation from God, yes.
38 Q I want to turn to questions of education that your
39 affidavit focussed on. Before I do that, can I
40 ask you how you came to be a witness in these
41 proceedings. Were you approached, and if so by
42 whom?
43 A Mr. Wickett came out to the Bountiful community
44 and interviewed me and then requested that I write
45 an affidavit.
46 Q And is it fair to say that one of the reasons that
47 you understand you were asked to write an
22
1 affidavit was that you were thought to be a

2 particularly good example of a young, successful
3 Bountiful woman?
4 MR. WICKETT: Objection, My Lord. It's not -- she
5 can't possibly answer that question.
6 THE COURT: Yeah. I think that is so, Mr. Jones.
7 MR. JONES: And she can answer if she knows, My Lord.
9 MR. WICKETT: She's just said, My Lord, that I
10 interviewed her and asked that she write an
11 affidavit so how can she possibly speak to my
12 motivation in making that request.
13 THE COURT: Yeah, I think you should move on,
14 Mr. Jones.
16 Q Witness 4, you'll agree with me, wouldn't you,
17 that you are exceptional in being a woman who has
18 gone on to college or university from the
19 Bountiful FLDS community?
20 A Exceptional compared to whom?
21 Q Compared to other women in the Bountiful
22 community.
23 A Exceptional. What do you mean, I have better
24 grades or something?
25 Q No, I mean that it's not common, is it, for women.
26 A For people to go on to college?
27 Q Yes.
28 A I don't know if I would say that. We have more
29 women in college from the Bountiful community
30 right now than males.
31 Q How many?
32 A How many people are in college?
33 Q How many women, how many men?
34 A There's at least -- there's at least eight to ten
35 women, and I'm not sure the number of men but I
36 know that it's less than the women.
37 Q Now, I'm going to ask you a truncated form of
38 question that was asked yesterday. Do you know of
39 anyone from Bountiful, male or female, who has
40 gone on to do any type of work for which a
41 university degree is required, apart from
42 teaching, midwifery or nursing?
43 A I don't think so.
44 MR. JONES: I notice the time. I think I have only a
45 few questions left but if I could review that over
46 the break perhaps I could make it as brief as
47 possible.
23
1 THE COURT: Thank you. Witness, you're under

2 cross-examination so we ask that --
3 MR. JONES: I'm sorry, one more.
4 THE COURT: Yes. Sorry, Mr. Jones.
5 MR. JONES: Sorry, I beg you pardon. Just one small
6 matter of housekeeping. I believe Ms. Greathead
7 as an envelope for the next anonymous witness and
8 was hoping we could meet Mr. Wickett at the break
9 to give it to him.
10 THE COURT: Okay. Well, that's up to Mr. Wickett. I'm
11 going to break. I'll let you make your
12 arrangements with Mr. Wickett, but I just ask the
13 witness not to discuss her evidence with anyone
14 during the break.
15 THE WITNESS: Okay.
16 THE COURT: Thank you.
18
19 (WITNESS STOOD DOWN)
20 (MORNING RECESS)
21
22 THE CLERK: Order in court.
23
24 WITNESS NO. 4, a witness
25 for the FLDS, recalled.
26
27 THE COURT: Thank you. Mr. Jones. Are we on line,
28 Mr. Jones?
29 THE CLERK: Can you hear us now, Mr. Jones?
30 MR. WICKETT: They can hear us but we can't hear them.
31 THE CLERK: Can you hear us now, Mr. Jones?
32 THE COURT: You can hear us. We can't hear you.
33 Mr. Wickett is very happy.
34 THE REGISTRAR: Maybe we can stand down, My Lord. I
35 will call IT.
36 THE COURT: Sure. Thank you.
37 THE CLERK: Order in court. Court stands down.
38
39 (BRIEF ADJOURNMENT)
40
41 THE COURT: Thank you. I think everything is all
42 right, Mr. Jones.
43 MR. JONES: Thank you, My Lord. We just moved
44 microphones and I think this one's working.
45 THE COURT: Okay.
46 MR. JONES: I think I was saying I have a couple more
47 areas to cover off and I don't expect to be long.
24

2
3 CROSS-EXAMINATION BY MR. JONES: (Continued)
4 Q Witness 4, you've lived in Canada continually
5 since you were married?
6 A I've been back and forth between the States and
7 Canada.
8 Q And how long do you spend when you visit the
9 States?
10 A Depending. Sometimes I've been a week. Sometimes
11 I've been a couple days. Sometimes I've been a
12 month, couple months.
13 Q How many times have you been down for a month or
14 more?
15 A I'm not sure. Probably not more than two or three
16 times.
17 Q And when you moved to Canada immediately after
18 your wedding I think you said you had half an
19 hour's notice of the wedding. So you had the
20 wedding and then how long after that were you
21 relocated to Bountiful?
22 A I left that night. I didn't take all my stuff
23 with me.
24 Q I see. And so then you returned to the US to pick
25 up your stuff and come back?
26 A Yes.
27 Q And when you came across the border initially --
28 I'm not sure, how long is the drive from the
29 States, assuming that you drove. How long did
30 that take?
31 A From where I was coming from it took us 18 hours.
32 Q And you crossed the border at one of the border
33 crossings, did you?
34 A Yes.
35 Q And when you did did you have a letter from your
36 parents?
37 A Yes.
38 Q And what did it say?
39 A I don't the exact wording but it was allowing me
40 to go to Canada to visit my aunts and stay at a
41 friend's place.
42 Q But that wasn't true, was it? You weren't coming
43 to Canada to stay at a friend's place, were you?
44 A That was true. I stayed at a friend's place.
45 Q Your friend being your new husband?
46 A Yes.
47 Q Are you aware of -- His Lordship has heard some
25
1 evidence with respect to a road that leads from

2 the Bountiful property across the US border. It's
3 called the smugglers road or the rum runners road.
4 Are you familiar with that?
5 A No.
6 Q Never heard of that?
7 A I have heard that there is a spot there but I've
8 never seen it or been on it.
9 Q And have you ever gone back and forth between
10 Canada and the United States except through a
11 government border crossing?
12 A No.
13 Q And soon after your arrival I take it you arranged
14 for a student visa; is that correct?
15 A No.
16 Q I'm sorry. Can you tell us how the student visa
17 came about -- or perhaps I should back up a little
18 bit then. What was your status when you initially
19 came across the border, was it visitor?
20 A Yes.
21 Q And at some point that changed to a student visa;
22 is that right?
23 A Yes.
24 Q What point was that? How did that come about?
25 A I came up. I was here for two weeks at first,
26 then I went back. I didn't get onto a student
27 visa until the next fall.
28 Q So until that time you would be coming to Canada
29 on visitor's visas?
30 A Or just coming across.
31 Q Yes, I'm sorry. That was a bad term. It wasn't a
32 visitor's visa but your status would be as
33 visitor?
34 A Yes.
35 Q And then since that time you have renewed your
36 student visa, I take it, through the remainder of
37 high school and then college?
38 A Yes.
39 Q And would it be fair to say that one of the
40 reasons that you have remained in school is
41 because the student visas allow you to remain in
42 Bountiful with your family. Would that be fair?
43 A I choose to go to school, or I could not.
44 Whichever.
45 Q But you said in your earlier testimony that you
46 recognized that if you didn't have your student
47 visa you would have to leave. Do you remember
26
1 saying that?
2 A Yes, if I had not longer had status that they
3 wouldn't grant me my work permit I would go back
4 to the States.
5 Q So your ability to stay in Canada all these years
6 has depended on your renewed student status?
7 A Yes.
8 Q Now, when you were a student at Bountiful
9 Elementary and Secondary School, you received some
10 religious instruction?
11 A While I was attending school?
12 Q Yes.
13 A Yes, they have a morning class.
14 Q And they also have a daily assembly that is
15 separate from the religion class; is that right?
16 A No, that's the same thing. Morning class,
17 assembly, devotional, whatever you want to call
18 it.
19 Q I see. So this devotional, how long does it last?
20 A Anywhere from 30 to 40 minutes.
21 Q And that's every day?
22 A Yes.
23 Q And in that time -- that's all of the students in
24 the school gather?
25 A Yes.
26 Q And you receive religious instruction?
27 A Yes.
28 Q In that time? Just a couple of points I wanted to
29 refer you to in your affidavit. Do you have that
30 in front of you?
31 A Yes.
32 Q We've heard a few different things about the --
33 various peoples' understanding of the line of
34 communication between God and the prophet and
35 flock, if I can put it that way. You say at
36 paragraph 5 of your affidavit which is just there
37 on page 1, beginning on page 1. I'm going to
38 start reading at the second line. It says:
39
40 When we come to earth our channel with the
41 heavens and heavenly father is our prophet.
42 He is the one who talks with the heavenly
43 father.
44
45 Let me just pause there. That's your
46 understanding, that the prophet is the one who
47 talks with the heavenly father?
27
1 A Everyone has the ability to pray and talk with

2 heavenly father. But, yes, that is what I state
3 there. He does as well.
4 Q And he's unique in the sense that the heavenly
5 father answers him?
6 A God answers all of us.
7 THE COURT: Sorry, you talked over each other there.
8 Would you repeat the answer, witness? Thank you.
9 THE WITNESS: Heavenly father can talk to all of us who
10 pray to him.
11 MR. JONES:
12 Q So the prophet -- your testimony is the prophet is
13 not in any privileged position with respect to
14 receiving revelations, for instance?
15 A He receives revelations for the people. Each
16 person can receive revelation for their personal
17 self.
18 Q Okay. But he is, as you say, the channel?
19 A Yes.
20 Q Now, if I can turn you to paragraph 7, over the
21 next page. And you spoke about this as well in
22 your testimony so far and that's, if I can put it
23 this way, the shock that you experienced when you
24 left the community and went into what you call
25 elsewhere, the outside world, college and the
26 things people got up to that you didn't approve
27 of. Do you remember talking about that?
28 A I think I call it the wild and unstable world.
29 Q No debate there. And that you encountered people
30 who were doing things that you weren't prepared
31 for; is that fair to say?
32 A Who were doing things that I didn't agree with.
33 Q Right. You said at the end of paragraph 7 you
34 find it hard to get an education in the middle of
35 all this. Is that true?
36 A I find it hard to be focussed at times in the
37 classroom. It feels more like the students are
38 ruling it instead of the teacher.
39 Q And it's not just the rowdiness though, is it,
40 it's also the dangers of conflict and drugs and
41 alcohol, and as you put it, dating and breaking
42 up. That sort of stuff?
43 A When they all come together in a classroom and
44 they're all talking quite loudly sometimes it's
45 hard for the instructor to talk over them if they
46 don't respect her request and be quiet.
47 Q Sure. And that's the classroom, but let me ask
28
1 you about the wider world because you talked about

2 visiting some places that seemed to be
3 intimidating to you. And Vancouver is very busy
4 and has lots of tall buildings?
5 A Okay.
6 Q What I'm trying to get at, I wonder if you would
7 agree with me that the nature of your upbringing
8 and education left you ill prepared to deal with
9 what you call the outside world.
10 A Ill prepared to deal with it?
11 Q Yeah.
12 A I don't think I would agree with your first word
13 that you used as "shocked." I did have an
14 understanding of what the outside world was doing
15 but I didn't agree with it. I don't agree with
16 what a lot of the young people do out there, even
17 doing drugs in the parking lot or whatever. I
18 just -- I don't agree with it. I wouldn't want to
19 participate in it.
20 Q Oh. And perhaps I can just get back to my
21 question. I was suggesting to you that your
22 upbringing and education had left you ill prepared
23 to deal with it. Would you agree with me?
24 A No. I know how to say no.
25 Q Okay. Now, you also said that you liked to keep
26 to yourself and that you like, as I understood it,
27 the sort of insular and isolated nature of the
28 Bountiful community; is that right?
29 A Yes, I enjoy that.
30 Q And you would hope that that isolated and
31 insulated nature of that community would continue;
32 is that right?
33 A Yes.
34 Q And so I'll just take you to paragraph 11, and
35 this is when we talk about what you would expect
36 if polygamy were decriminalized. Do you remember
37 writing about that in your affidavit?
38 A Yes.
39 Q And you say that your family could all take the
40 same last name. They would have the benefits as
41 other Canadians have. You would use the money to
42 spend on fighting for your religion and nice
43 housing for your families. You would be able to
44 bring in more industry and so forth. "We would be
45 able to live in peace," you say at the last line
46 on the page, and not have the outside world
47 peering down our necks and ridiculing you for the
29
1 way you believe in.

2 So your expectation is that if polygamy were
3 decriminalized then -- and combined with your hope
4 that your community would remain isolated and
5 insulated, you would -- you would expect that if
6 it was decriminalized you would be able to
7 continue that isolated and insulated existence; is
8 that right?
9 A Yes.
10 Q I just have one other question or perhaps series
11 of questions.
12 I want you to take your mind back to when you
13 became a teenage bride, brought up from the United
14 States, living with your new sister wives and your
15 husband at Bountiful, and you've described a
16 similar situation that your sister wife found
17 herself in when she arrived half a year later.
18 If a teenage girl found herself -- well, no,
19 I'll ask more specifically. When you found
20 yourself in that situation, if you had come to the
21 conclusion that that was not a good situation to
22 be in who would you have turned to with those
23 concerns?
24 A The Lord first and then I would have voiced it to
25 my husband and my father.
26 Q And to your understanding both your husband and
27 your father approved of the situation that you
28 were in?
29 A Yes.
30 Q Is there anyone else that you would have turned
31 to?
32 A To tell that I didn't agree with?
33 Q Yes.
34 A I guess I could have told my sister wives or my
35 mother, my sisters.
36 Q And to your knowledge all of those people too
37 agreed with the situation you were in?
38 A I didn't go around and personally ask them but I
39 can assume they did.
40 MR. JONES: Thank you, Witness 4. If you could remain
41 in the witness box I believe my friends from the
42 Attorney General of Canada might have some
43 questions for you. Thank you very much for your
44 testimony today.
45 THE WITNESS: Thank you.
46 THE COURT: Canada.
47 MR. REIMER: Yes, My Lord. For the record Keith Reimer
30
1 for the Federal Crown this morning. We do not

2 have any questions at this time for this witness.
4 MR. REIMER: Thank you.
5 THE COURT: Any other parties wishing to cross-examine?
6 MR. JONES: Looks like nobody at this end, My Lord.
7 THE COURT: Any redirect?
8 MR. WICKETT: No, no redirect, My Lord.
9 THE COURT: Thank you. Thank you very much, witness,
10 for coming to court.
12
13 (WITNESS EXCUSED)
14
15 MR. WICKETT: For the benefit of those not able to see,
16 we now have, My Lord, Witness No. 3 in the box.
17 THE COURT: Thank you. Madam registrar.
18
19 WITNESS NO. 3, a witness,
20 called by the FLDS, sworn.
21
22 EXAMINATION IN CHIEF BY MR. WICKETT:
23 Q Witness No. 3, you've sworn an affidavit in this
24 proceeding and it's dated the 15th of October,
25 2010. Do you have that before you?
26 A Yes.
27 Q Is that your signature on the third page?
28 A Yes.
29 MR. WICKETT: My Lord, I believe it's Exhibit 80.
30 THE COURT: Yes. Thank you.
31 MR. WICKETT:
32 Q Before we begin I understand there was a mistake
33 in paragraph 6 of your affidavit you wanted to
34 correct?
35 A Yes.
36 Q What is it you'd like to correct?
37 A The year was 2008 not 2007.
38 Q And that's in the first sentence of paragraph 6?
39 A Yes.
40 Q Thank you. You were -- Witness No. 3, you were
41 born in Creston, British Columbia?
42 A Yes.
43 Q You're now age 22?
44 A Yes.
45 Q Are you married?
46 A No.
47 Q You're a member of the FLDS faith and you live in
31
1 Bountiful, British Columbia?

2 A Yes.
3 Q You grew up in a family -- I'm asking. Did you
4 grow up in a family with plural marriage?
5 A Yes.
6 Q How many children did your mother have?
7 A Nine.
8 Q Can you describe for His Lordship, please, your
9 relationship with your parents growing up.
10 A I was always very close to my father. I'm sure I
11 was his favourite daughter, but they all say that.
12 He was someone I could always turn to and talk to.
13 And I was usually close to my mothers but there
14 was times when I was a teen that I didn't really
15 see eye to eye with them but it's better now. I'm
16 quite close to them all right now.
17 Q Now, you attended the Bountiful school?
18 A Yes.
19 Q And what level did you achieve there?
20 A Grade 12.
21 Q Now, we've had some discussion in this case about
22 the teaching of religion in the school. Do you
23 recall when you were attending there that religion
24 was taught as a subject?
25 A Yes.
26 Q And how often was it taught?
27 A When I was going to school there was 15 to half an
28 hour morning devotional prayer, song, morning
29 message, and then one year when I was in high
30 school three times a week it was an hour and it
31 was just church history.
32 Q Now, other than religion -- devotionals,
33 et cetera, other than the religious instruction
34 what were the other subjects that you took in
35 school?
36 A Oh, I took math, English, science, social studies
37 biology, digital photography, drama, did career
38 and personal planning, physical education.
39 Q When you were going through school did you have
40 any particular interests in a job or academic
41 interests?
42 A I did. I knew I wanted to go to college. When I
43 was a child I always dreamed and said I was going
44 to be a teacher, but when I got into high school I
45 was looking at some different options and I was
46 taking the prerequisite courses that I would need
47 for whatever I decided to do afterwards.
32
1 Q And what did you do when you graduated from

2 school?
3 A Well, I couldn't quite decide what I wanted to be.
4 I knew I wanted to work in and around the
5 community and so I decided I would go back to my
6 childhood dream which was to be a teacher because
7 I wanted really bad to stay in the community and
8 work in the community. And so I volunteered for a
9 year at the school to see if that was what I was
10 interested in and then I started looking at
11 different colleges and different options.
12 Q And are you going to college now?
13 A Yes. I've been attending the Southern Utah
14 University in Cedar City, Utah since 2008, the
15 summer sessions.
16 Q And what's the -- what is the objective there?
17 What do you get, a degree or a certificate?
18 A Yes, I'm getting a Bachelor of Science degree in
19 education.
20 Q And when you were deciding on what you wanted to
21 do after high school did you feel you were limited
22 in the choices you could make coming out of the
23 Bountiful school?
24 A Well, I knew that I really could be whatever I
25 want to be and my father and my family encouraged
26 me to do so, but I realized that I wanted to work
27 in our own community. I wanted to work with our
28 own people and so I choose to do that.
29 Q When will you be complete in your education?
30 A I'm about two-thirds down. I'm guessing two more
31 semesters I will be finished.
32 Q What do you plan to do when you're done?
33 A I want to come back and teach at Bountiful school.
34 Q Now, I think you said at the outset you're not
35 married?
36 A That's true.
37 Q I'm suggesting to you you learned about and become
38 aware of the covenant in marriage for the FLDS?
39 A Yes.
40 Q And in paragraph 8 I think you've discussed it
41 and -- paragraph 8 of your affidavit that is.
42 A Yes.
43 Q You've discussed it and mentioned the principle,
44 which you put in quotes at the end of paragraph 8?
45 A Yes.
46 Q What are you referring to?
47 A The law of celestial and plural marriage.
33
1 Q What does that refer to?

2 A That refers to the law and our belief that for a
3 person to enter into the highest degree of the
4 celestial kingdom he must enter into and abide
5 that law.
6 Q Now, do you believe in that?
7 A Yes, I do.
8 Q What's your understanding of the role of the
9 prophet in marriage and the FLDS?
10 A He is the one that would perform the marriage and
11 he is also the one who receives the revelation
12 from God who I would marry.
13 Q What is your understanding of the process by which
14 that occurs?
15 A My understanding of it is, from what I've seen and
16 heard, is it first begins with a girl wanting to
17 be married and then she prays about it a lot, and
18 then she would make a request either to her father
19 or to the bishop and ask him to relay that to the
20 prophet.
21 Q And marriage follows after that?
22 A Yes.
23 Q Have you made such a request?
24 A No, I never have.
25 Q We've heard evidence in this case about people
26 having been assigned -- it's my word, assigned in
27 marriage to people that they did not want to be
28 married to. Have you considered that this might
29 happen to you?
30 A No.
31 Q Why is that?
32 A Because I would never marry someone I did not want
33 to marry.
34 Q Have you considered the possibility that the
35 prophet would insist upon it?
36 A He might possibly. I don't think so.
37 Q What would happen? What would be your position if
38 he did?
39 A Well, I would for sure explain to him the reason
40 why I didn't want to marry that particular person.
41 But -- and I might ask for more time to think
42 about it, but I would also -- I believe I can talk
43 to God myself and I would tell him I'm not really
44 sure what you see in this guy. I'm not seeing the
45 same thing. And could I have more time, would you
46 consider somebody else. And I believe that that
47 would be taken into consideration.
34
Cross-exam by Mr. Greathead
1 Q Do you feel that you would have the ultimate right

2 to say no if the prophet continued to insist?
3 A Yes, I do.
4 Q Now, I understand you've done a little bit of
5 travelling outside of Bountiful community?
6 A Yes, I have.
7 Q Give us perhaps a list of some of the places
8 you've been to.
9 A Oh, I've been over to Victoria a few times. I
10 went there with my grad class when we graduated
11 and then I went again on a geology field trip when
12 I was working on a geology course in college.
13 Went on a tour of caves. I've also been to
14 Calgary. I went to look at some different art
15 museums when I was studying humanities.
16 Q Have you travelled at all to any place in the
17 United States?
18 A Yes, I have. I've been to California, Nevada,
19 Arizona, Utah.
20 Q What were you doing in California?
21 A I went there to go to the Magic Mountain theme
22 park with my grandma and some friend.
23 Q And Nevada, what were you doing in Nevada?
24 A I got my eyes lasered. Eye laser surgery.
25 Q Was that in Las Vegas?
26 A Yes, in Vegas.
27 Q Now, you're obviously a young person. You're
28 age 22?
29 A Yes.
30 Q And you got your life ahead of you. What are
31 you -- what do you want for your future?
32 A My hopes for my future is that for myself and for
33 my family and for those that I love that we can
34 choose to live the way that we want to live
35 without fear of persecution or discrimination and
36 just live it in freedom and peace.
37 MR. WICKETT: Thank you, My Lord. Those are my
38 questions.
39 THE COURT: Thank you. We'll have some questions on
40 cross from Ms. Greathead.
41
42 CROSS-EXAMINATION BY MS. GREATHEAD:
43 Q Yes, My Lord.
44 Witness No. 3, my name is Leah Greathead and
45 I'm a lawyer with the Ministry of Attorney
46 General, and I'm going to be asking you some
47 questions on behalf of the Attorney General.
35
Cross-exam by Ms. Greathead
1 Can you hear me?

2 A Yes, I can.
3 Q And I too would like to thank you for coming to
4 give your evidence today and helping us and the
5 court understand what life is like living in a
6 polygamous community. Were you in the courtroom
7 when Witness No. 4 gave her evidence?
8 A Yes, I was. No, I wasn't -- I wasn't in the
9 courtroom.
10 THE COURT: Sorry. She wants to clarify that. Go
11 ahead.
12 THE WITNESS: No.
13 MS. GREATHEAD:
14 Q Did you hear the evidence of Witness No. 4 that
15 was just before you this morning?
16 A Sorry, no. I was outside the courtroom.
17 Q Okay. Now, you've told us that you were born in
18 Creston and that you live in Bountiful; is that
19 right?
20 A Yes.
21 Q And so -- and you mention in your affidavit that
22 you spent three months away at college in Utah; is
23 that correct?
24 A Yes.
25 Q So apart from those three months you've lived your
26 entire life in Bountiful?
27 A Well, that was three months at a time. I've gone
28 down three summers but I have stayed for three
29 months at a time.
30 Q Oh. So total of nine months away?
31 A Actually the first summer I was -- it was about
32 nine weeks and the second one was 12 weeks, so
33 three months was the longest I've stayed away from
34 Bountiful.
35 Q And now when you're living in Bountiful do you
36 live in your father's home?
37 A Yes, I do.
38 Q And is your father your priesthood head?
39 A Yes, he is.
40 Q And when you get married your husband would become
41 your priesthood head; is that correct?
42 A Yes.
43 Q Now, you've mentioned, or we've had Bountiful
44 described as an isolated and insular community.
45 Would you agree with that description?
46 A Yes.
47 Q And would you agree that it's a close knit
36
1 community?
2 A Yes, I would.
3 Q And you grew up playing with a number of children
4 in the community?
5 A Yes, I did.
6 Q And what kinds of things did you do with the other
7 children in the community?
8 A Oh, all sorts of things. We swam, we biked,
9 different sports. Skated. Snowboarded.
10 Snowboarded. Skied.
11 Q And you feel that you know the other children that
12 you grew up with in the community very well?
13 A Some of them.
14 Q Would you know the ones around your age very well?
15 A Some of them.
16 Q And some of these children that -- you mentioned
17 that your mother had nine children?
18 A Yes.
19 Q How many full sisters do you have?
20 A Three.
21 Q And what about step sisters or step brothers. How
22 many -- or half sisters or half brothers. How
23 many half or step sisters do you have?
24 A You're asking just about the sisters, step sisters
25 or siblings?
26 Q Yeah. Just the sisters.
27 A Seven. Sorry, let me clarify that. Four.
28 Q And half or step brothers. How many did you have?
29 A Six.
30 Q So there was a total of 19 children in your
31 family?
32 A Yes.
33 Q And how many mothers?
34 A Two.
35 Q Did you -- sorry?
36 A Two.
37 Q How many mothers did you grow up with?
38 A Two.
39 Q Thank you. Sorry. We're talking over each other.
40 Now, in addition to the playing and doing the
41 activities you described with the children in
42 Bountiful as you were growing up you also went to
43 school with them; is that right?
44 A Yes.
45 Q Bountiful Elementary and Secondary?
46 A Yes.
47 Q And do you refer to that as -- by the acronym of
37
1 BESS, B-E-S-S?
2 A Sometimes.
3 Q So if I use the acronym BESS then you would
4 understand what I meant?
5 A Yes, I would.
6 Q Now, and so all of the -- all of the students that
7 attended school with you at BESS were members of
8 the FLDS religion?
9 A Yes.
10 Q Now, you've told us that you've gone down in the
11 summers to Cedar City, and Cedar City is in Utah?
12 A Yes?
13 Q And have you been to Hildale, Utah as well?
14 A Yes, I have.
15 Q And Cedar City would be just over an hour's drive
16 from Hildale; is that correct?
17 A Yes.
18 Q And in your affidavit you mention Southern Utah
19 University and you also used the word "college"
20 and talked about attending college in Utah. Are
21 you referring when you use the word "college" to
22 the Southern Utah University?
23 A Yes, I am.
24 Q And you -- so you'd have explained a bit more that
25 the longest you've been down there for is three
26 months -- the longest you've been there was for
27 three months and when was that?
28 A That was just this last summer. 2010.
29 Q And did you start there in June or July?
30 A It was actually in May.
31 Q In May. So for May, June and July?
32 A Yes. The end of May.
33 Q And then into August as well then?
34 A Into the first couple of days of August. I'm not
35 sure exactly when we came back, but yes.
36 Q Now you mentioned when we came back. Who are you
37 including in the "we" there?
38 A The other girls that are attending the university
39 with me.
40 Q And who -- are the other girls that are attending
41 the university with you part of the FLDS
42 community?
43 A Yes.
44 Q From Bountiful?
45 A Yes.
46 Q How many other girls are there?
47 A Four.
38
1 Q So four girls are down from Bountiful studying in

2 the southern University of Utah?
3 A And myself.
4 Q So five altogether. Sorry. And are the other
5 girls studying education as well?
6 A Yes, they are.
7 Q Are they also in elementary education?
8 A Yes, they are.
9 Q And do you know, do they too hope to go back to
10 BESS to teach?
11 A I'm not really sure. As far as I know they do but
12 I can't say exactly for them.
13 Q Have you talked with them about what their goals
14 are after they finish their education?
15 A A couple of them, yeah.
16 Q And what have they told you?
17 A For the most part they do want to come back to
18 BESS, yes.
19 Q And are any of those girls that -- the four
20 additional girls that are down studying in Utah
21 with you, are any of them married?
22 A Yes.
23 Q How many of the four are married?
24 A One.
25 Q And do these -- are these four girls doing the
26 same as you, they're going down to study in the
27 summer; is that right?
28 A Yes.
29 Q And did they start their university program at the
30 same time that you did?
31 A Yes, they did.
32 Q And when was that?
33 A It was in 2008.
34 Q Was that in May of 2008?
35 A Yes. Yes.
36 Q And so did you travel together down to university?
37 In Cedar City?
38 A Sometimes.
39 Q And what about -- where did you live while you
40 were going to university in Cedar City?
41 A In Cedar City.
42 Q In an apartment?
43 A No. In a house there.
44 Q And were you renting the house?
45 A No.
46 Q How did you come to live in the house?
47 A It was owned by a friend in -- from Colorado City.
39
1 Q So the friend from Colorado City was a member of

2 the FLDS?
3 A Yes.
4 Q And so is the church then providing accommodation
5 for you and the other girls that are studying in
6 Cedar City?
7 A They provided the housing. We pay the utilities.
8 Q And in addition to the five of you Canadian girls
9 down studying in university in Cedar City is there
10 anyone else living in the house?
11 A No.
12 Q Now, you mentioned that you are about two-thirds
13 through your education; is that correct? Your
14 post secondary education?
15 A Yes.
16 Q And so parts of this have been done by going down
17 for up to three months in the summer down to Cedar
18 City. And how are you getting the other parts of
19 that two-thirds of your education completed?
20 A We've taken some online courses, but we're just
21 going to continue going down there until we're
22 finished.
23 Q Sorry, so you said we've taken some online
24 courses? Did I hear you correctly?
25 A Yes.
26 Q So the five of you have taken these online
27 courses?
28 A Yes.
29 Q And you plan to finish off your education by
30 returning to Cedar City for summer sessions; is
31 that correct?
32 A As far as I know. As far as it stands right now
33 that's our plan.
34 Q And so you talk about "our plan." Did you speak
35 with the other girls? Who are you referring to in
36 "our plan"?
37 A I guess I should have said "my plan" because I'm
38 not really sure if that's what they want to do.
39 We've talked about it but we haven't made any
40 definite ...
41 Q And how many more summer sessions will you have to
42 do to complete your educational -- to get your
43 degree?
44 A I'm guessing two because I'm hoping to test out of
45 some of the courses but I'm not sure.
46 Q Now, at paragraph 5 of your affidavit you indicate
47 that the school and community provided housing and
40
1 supplies as well as emotional support. Do you see

2 that?
3 A I do.
4 Q And I take it when you're talking about the
5 community there you're talking about your church?
6 A Yes.
7 Q And did you have to take any steps to find the
8 housing or was that all arranged for you?
9 A It was arranged for us.
10 Q And does your church -- does the church provide
11 you with living expenses while you're going to
12 school in Cedar City?
13 A Sorry, I'm not sure what you're asking. What was
14 that question again?
15 Q I'm sorry. I was asking whether your church
16 provides you with money for living expenses while
17 you're living in Cedar City?
18 A It's more of our families -- or I should say in my
19 case it is my family.
20 Q And in -- outside of the -- yourself and the four
21 other girls that you've told us about that are
22 going to college in Cedar City, are there any
23 other people that you're aware of from Bountiful
24 that are attending college in Cedar City?
25 A Yes.
26 Q And how many?
27 A One.
28 Q And is that a male or a female?
29 A A male.
30 Q And what's he studying?
31 A I'm not sure, entirely.
32 Q Do you know at all? You said you're not sure
33 entirely.
34 A I think he is going into education. He's doing
35 some accounting as far as I know. I can't say for
36 sure.
37 Q And what about members of the larger FLDS
38 community, the members from the -- Hildale or
39 Colorado City or elsewhere in the United States?
40 Are you aware of any of those people attending
41 university -- the same university as you?
42 A Not that I know of.
43 Q And was the -- was your university, the University
44 of Southern Utah, until recently a teacher's
45 college?
46 A I don't know.
47 Q It also -- back to paragraph 5 of your affidavit.
41
1 You mentioned that the community was providing --

2 community and school was providing you with
3 emotional support. What do you mean by that?
4 A What I mean by that is they all very strongly
5 encourage me in this effort and came to visit me
6 if they could or ...
7 Q Now, while you're in Cedar City do you continue
8 with your religion studies?
9 A Yes.
10 Q And how do you do that?
11 A What for sure do you mean religious studies? I do
12 a personal study where I read.
13 Q And do you attend any church meetings?
14 A Yes.
15 Q And where do you attend those?
16 A Sometimes we connected up to the meeting from
17 Bountiful and sometimes we went down to Colorado
18 City.
19 Q How do you connect up to the meeting in Bountiful?
20 A By a phone call.
21 Q So you listen to the meeting over the telephone?
22 A Yes.
23 Q And then you mentioned sometimes you would attend
24 meetings in person in Colorado City?
25 A Yes.
26 Q And how often would you do that?
27 A I can't say for sure. I can't remember for sure,
28 but I would say probably once or twice a month.
29 Q Now, the last time you went down, which was in May
30 of 2010; right?
31 A Yes.
32 Q Did the five of you travel together?
33 A No.
34 Q How did you get down?
35 A I can't remember.
36 Q Did you travel by car?
37 A Yes.
38 Q And who took you? Not -- you don't have to give
39 me their name but the relationship of the person
40 that took you down to Cedar City?
41 A It was an uncle as far as I remember.
42 Q Now, you mention in your affidavit that your
43 sister left the FLDS community with her husband?
44 A Yes.
45 Q Is that correct?
46 A Yes.
47 Q And would you agree with me that all of the women
42
1 that you know that have left the FLDS community

2 and religion, and by that I'm including both the
3 supporters of Warren Jeffs and the supporters of
4 Winston Blackmore, that all of -- all of the women
5 that you know that have left the FLDS religion
6 have left with a man; is that correct?
7 A I can't say exactly. I'm not sure about that.
8 Q Well, do you know of or have you ever heard of an
9 unmarried young woman or girl leaving Bountiful on
10 her own?
11 A Yes, actually. Yes.
12 Q How many?
13 A One that I can think of.
14 Q And do you know other women like your sister who
15 left the community with their husbands?
16 A Yes.
17 Q And approximately how many are you aware of?
18 A I can't say. I'm not sure.
19 Q Many more than one?
20 A I would say a few more than one, yes.
21 Q More than ten?
22 A Yes, that would probably be correct as well.
23 Q What about more than 20?
24 A Yes, that is possible.
25 Q And what about boys? I take it that you know a
26 number of boys that have left the FLDS religion on
27 their own, don't you?
28 A Yes.
29 MS. GREATHEAD: My Lord, I notice the time.
30 THE COURT: Well, is there any chance we could finish
31 within a reasonable period?
32 MS. GREATHEAD: Of my cross? I think I -- I have
33 definitely more than 10 minutes or 15 minutes.
34 THE COURT: Okay. In that case we'll take the luncheon
35 adjournment. Thank you.
36 THE CLERK: Order in court. Court is adjourned until
37 2:00 p.m.
38
39 (WITNESS STOOD DOWN)
40 (NOON RECESS)
41
42
43 THE CLERK: Order in court.
44
45 WITNESS NO. 3, a witness
46 for the FLDS, recalled.
47
43
1 THE COURT: Ms. Greathead.

2 MS. GREATHEAD: My Lord, thank you.
3
4 CROSS-EXAMINATION BY MS. GREATHEAD: (Continued)
5 Q Witness, are any of the women you were going to
6 university with in Utah your sisters or half
7 sisters?
8 A No.
9 Q Did you speak with your bishop about the kind of
10 post secondary education that would be helpful for
11 your community?
12 A No.
13 Q And what do you do when you're not at university
14 in Cedar City?
15 A We take a pretty full course load so I was doing
16 school pretty much full-time, but we did go to the
17 Shakespearean theatre, hiked up the mountains,
18 swam at the pool. That kind of stuff.
19 Q Sorry, I must have worded that question poorly. I
20 meant when you're back -- when you're not down in
21 the United States going to university what do you
22 do?
23 A I work at the school.
24 Q Are you teacher?
25 A Yes. Yes, I am teaching with a letter of
26 permission from the Ministry of Education.
27 Q And is it your understanding that you need one of
28 these letters of permission to teach if you
29 haven't obtained a university degree?
30 A Yes.
31 Q Now, I was asking you before the lunch break about
32 people who have left your community. Do you
33 remember that?
34 A Yes.
35 Q And I was asking about boys that -- that had left,
36 and so do you know boys that have left your
37 community on their own?
38 A Yes.
39 Q And would you know more than 20 that have left?
40 A No.
41 Q More than ten?
42 A Yes.
43 Q And you mentioned in your affidavit that your
44 brother left the community. Did he leave on his
45 own?
46 A Yes, he did.
47 Q And what level of education had your brother
44
1 attained prior to leaving?

2 A I'm not even sure about that.
3 Q How old was he?
4 A He was 18.
5 Q Had he gone to school?
6 A Yes.
7 Q Do you know whether he completed his Grade 12?
8 A No, I don't think he did.
9 Q Do you know if he completed Grade 9?
10 A I think he did, yes.
11 Q Do you know whether he completed Grade 10?
12 A I'm not sure about that.
13 Q And what about your sister? What level of
14 education had she attained prior to leaving the
15 FLDS community?
16 A As far as I can remember I think it was Grade 9.
17 Q And how old was she when she left?
18 A I don't remember exactly. I think she was 20.
19 Q Did she have any children when she left?
20 A Yes, she did.
21 Q I'm going to move on and ask you some questions
22 about BESS, the school. I believe you've
23 confirmed already that you did all of your
24 kindergarten to Grade 12 schooling at BESS; is
25 that correct?
26 A Yes, that is.
27 Q And during the time that you were a student at B
28 ESS, were all of the teachers members of the FLDS?
29 A Yes, they were.
30 Q And is that true today as well?
31 A Yes.
32 Q And what about the principal, was he a member of
33 the FLDS when you attended school there as a
34 student?
35 A Yes, he was.
36 Q And is that true today as well?
37 A Yes.
38 Q And what about the -- was there a number of
39 support staff that worked at the school?
40 A Yes.
41 Q What would that include?
42 A Sorry, what is your question for sure?
43 Q So are there teacher's aides?
44 A Yes, there is.
45 Q And secretaries?
46 A Yes.
47 Q And janitors?
45
1 A Yes.
2 Q Anybody -- any other group or category of
3 employment at this school?
4 A There's a special education teacher as well.
5 Q And are all of these people members of the FLDS as
6 well?
7 A Yes.
8 Q Now, you said you're pursuing a degree in early
9 childhood education. What is it that you are
10 teaching at the school now?
11 A I'm pursuing a degree in elementary education.
12 Early child education is just the minor.
13 Q I was just wondering, are you teaching in the
14 early childhood grades K to 3 somewhere?
15 A No, I'm not.
16 Q What are you teaching?
17 MR. WICKETT: I rise only, My Lord, because although I
18 have left the questions about teaching at the
19 school, getting too particular about it is going
20 to identify the witness.
21 THE COURT: It's a very small school, isn't it?
22 MR. WICKETT: It is indeed.
23 THE COURT: Yes. Ms. Greathead, do you appreciate
24 that?
25 MS. GREATHEAD: Yes, My Lord. I'll move on.
26 Q Now, you have already spoken about religious
27 instruction at the school and I just have one more
28 question in respect to that area, and that is
29 whether were any of your prophet Warren Jeff's
30 sermons ever played during school religious
31 instruction?
32 A Yes, there were selections of them that were
33 played during the morning sometimes.
34 Q And I understand that the prophet has made a
35 number of tapes that have sermons on them. Are
36 you aware of these tapes?
37 A Yes, I am.
38 Q Have you listened to them yourself?
39 A Yes, I have. Some of them.
40 Q And what about the book In Light and Truth. Are
41 you familiar with that as a book of scriptures for
42 your religion?
43 A I am aware of it. I'm not very familiar with it.
44 Q Have you read parts of it?
45 A I have read parts of it.
46 Q Now, it's my understanding -- you know, you said
47 you graduated in 2005 from Grade 12; is that
46
1 correct?
2 A Yes.
3 Q That would be June of 2005?
4 A Yes.
5 Q And it's my understanding that at that time and,
6 in fact, throughout the time that you attended
7 BESS that it was not certified to provide -- not
8 certified to provide Grades 11 and 12. Is that
9 your understanding as well?
10 A I am aware that there was not funding provided for
11 teaching 11 and 12 but the teachers were
12 certified.
13 Q And when you say the teachers were certified what
14 do you mean by that?
15 A They had licenses to teach.
16 Q And were they university educated, had a
17 university degree?
18 A Some of them were.
19 Q So it was my understanding that BESS, as you
20 mentioned, that it didn't get funding for Grades
21 11 and 12 and they couldn't issue the provincially
22 recognized dogwood high school diploma; is that
23 correct?
24 A That is.
25 Q And so do you have a dogwood?
26 A No, I don't.
27 Q And so what you have is a high school diploma
28 issued by BESS; is that right?
29 A That is.
30 Q Now, is it your understanding that BESS the school
31 is working towards getting -- I had used
32 certification in my question before, not to refer
33 specifically to whether the teachers are certified
34 but whether the school is certified to offer
35 Grades 11 and 12. Is it your understanding that
36 BESS is working towards getting that
37 certification?
39 Q So the school would like to be able to issue
40 dogwood diplomas?
41 A I can't say that for sure. I'm not -- I would
42 guess that to be so but no one has ever refused my
43 diploma.
44 Q And I -- is it an accurate statement to say that
45 the -- the church leaders would like to have
46 certified teachers to come from within your group
47 and to come back and teach at BESS?
47
1 MR. WICKETT: Well --

2 THE COURT: Yes.
3 MR. WICKETT: The question could be phrased perhaps
4 based on what she knows. She obviously can't
5 speak for what the leadership wants.
6 THE COURT: Correct.
7 MS. GREATHEAD: Sorry.
8 Q The question then, do you know whether the church
9 leaders would like to have certified teachers to
10 teach at BESS?
11 THE COURT: Based on her knowledge.
12 MR. WICKETT: Yes, all right.
13 THE WITNESS: I don't know that.
14 MS. GREATHEAD:
15 Q Do you know whether the church leaders would like
16 people from within your group to teach at BESS?
17 A I don't have personal knowledge of that. I
18 haven't heard them say that.
19 Q Now, you -- so you've told us that you've
20 graduated from BESS in 2005. Did you repeat any
21 grades?
22 A No, I never.
23 Q Did you ever take any extra time to finish any of
24 the grades?
25 A No.
26 Q So is it accurate to say then that you began
27 kindergarten in September of 1992, the 1992/93
28 school year? And maybe if I might assist,
29 My Lord, and if the -- there's a package that has
30 been provided to the clerk for this witness.
31 There's a document that I prepared just to assist
32 to make it easier to figure out the grade years
33 here, and if I could I would like to put that
34 document to the witness.
35 THE COURT: Have you seen these?
36 MR. WICKETT: No.
37 THE COURT: Okay. We're opening the envelope now. And
38 would you show them to Mr. Wickett. Thank you.
39 MS. GREATHEAD: That's not the right one. It should
40 just be one page.
41 MR. WICKETT: You have handed us a document with four
42 pages attached to it.
43 MS. GREATHEAD: No, there should be two different
44 packages and one is one page and it has a number
45 of years on it. That one.
46 THE COURT: Okay. But they're all together with other
47 documents.
48
1 MS. GREATHEAD: Well, that's fine. They were supposed

2 to be separate. Two separate packages.
3 THE COURT: Okay. They weren't. That's okay. Go
4 ahead.
5 MS. GREATHEAD:
6 Q So I am looking. The document I would like to
7 have put to the witness is the one that has a
8 series of numbers, dates with the years.
9 A Yes.
10 Q Starts -- it says year and grade.
11 THE COURT: Yes, we have that.
12 MS. GREATHEAD:
13 Q So witness, you've told us that you graduated from
14 Grade 12 in 2005, so alls I've done here is taken
15 the school years and that's why I have had to
16 divide -- so 2004/2005 would have been the school
17 year that you were in Grade 12; is that correct?
18 A Yes.
19 Q And then if you go down the year before that would
20 have been 2003/2004, the school year you were in
21 Grade 11?
22 A No.
23 Q No? What year were you in Grade 11?
24 A I did an accelerated program the year I was in
25 Grade 11, so the year 2004/2005 was also the year
26 I did grade 11.
27 Q Okay. So from -- so you were in Grade 11 and 12
28 in 2004 and 2005?
29 A Yes.
30 Q Is that correct?
31 A Yes.
32 Q And so you were in Grade 10 in 2003/2004?
33 A Yes.
34 Q Then if we went down this chart and just took one
35 grade off each time would it be accurate?
36 A I believe so.
37 Q So was it the 1993/1994 school year that you began
38 kindergarten?
39 A As far as I can remember. That would be correct.
40 Q Okay. So can you tell us how the classrooms were
41 set up at BESS. Did each grade have its own
42 classroom or were there a number of grades within
43 one classroom?
44 A When I was going through school each grade had
45 their own classroom that I can remember. There
46 was a couple of grades that were double blocked.
47 Q So if I could ask you then to think back to your
49
1 Grade 8 year, and if you look at the chart that

2 I've handed you is it accurate to say that it was
3 from September 2001 to June 2002 that you were in
4 Grade 8?
5 A As far as I can remember, yes.
6 Q And how many kids were in your class in Grade 8?
7 A As far as I can remember there was 19. 19, 20.
8 Q Of those 19 or 20 students how many of them were
9 still in school with you in Grade 11?
10 A There were only five of us that continued on with
11 the accelerated program. The rest of them took
12 two years to do 11 and 12.
13 Q So five did an accelerated program, and did any of
14 the students leave?
15 A Yes, there was some that left.
16 Q How many left altogether?
17 A I'm going to have to say -- I can't remember this
18 exactly. I would say eight or nine. Ten.
19 Q So somewhere between eight and ten dropped out of
20 school altogether?
21 A No, they left with Winston's group. And I'm not
22 sure what they did with their education after
23 that.
24 Q And so other than those kids were there any kids
25 that left school from your group?
26 A Yes.
27 Q How many left school from your group?
28 A I would say three. I'm not positive on that
29 number.
30 Q And you don't know what happened to the eight or
31 ten that went to Winston's group?
32 A No, I don't.
33 Q Now, did any of your classmates get a dogwood
34 diploma that you know of?
36 Q And have you heard of anybody from your community
37 getting a dogwood diploma?
38 A Not that I can think of.
39 Q Now, you said no one has been -- has ever refused
40 to accept your high school diploma from BESS. Who
41 have you submitted that high school diploma to,
42 which institutions?
43 A The College of the Rockies and then Southern Utah
44 University.
45 Q And is it your understanding that universities in
46 BC require a dogwood?
47 A No, I didn't know that.
50
1 Q Now, while you were at school you mentioned that

2 you studied career and personal planning; correct?
3 A Yes.
4 Q And was there a work experience component part of
5 that?
6 A Yes, there was.
7 Q And did you participate in the work experience
8 program?
9 A Yes.
10 Q And how much of your week -- school week time was
11 taken up with the work experience program?
12 A I don't remember that.
13 Q I understand it was offered for two hours on
14 Fridays. Does that coincide with your
15 recollection?
16 A That is possible. I don't -- I don't remember.
17 Q Do you remember for the work experience component
18 being paired up with another girl?
19 A No.
20 Q What happened in your work experience program?
21 A When I did it then it was when I was kind of
22 interested in the medical field and so I worked
23 with an RN.
24 Q Was that within Bountiful?
25 A Some of it was.
26 Q Did part of your work experience involve going to
27 various homes in the community?
28 A Not that I remember.
29 Q Now, did your school include a sexual education
30 component part of the instruction?
31 A No.
32 Q Did you have a life skills component part, for
33 example on how to write a cheque, keep a bank
34 account, those kinds of things?
35 A Not that I remember.
36 Q And apart -- I'm going to ask you a question that
37 has been posed to the other -- the other witnesses
38 that have come to testify, the other anonymous
39 witnesses, and that is, apart from midwifery,
40 nursing and education do you know of a person from
41 your community who has a job that requires a
42 university degree?
43 A Would this just be the Bountiful community?
44 Q Yeah, the Canadian community.
46 Q Now, did you draft your affidavit?
47 A Yes, I wrote it.
51
1 Q Did you discuss it with anyone?

2 A Not really.
3 Q Did the bishop approach you to speak with someone
4 about coming to testify in court or writing the
5 affidavit?
6 A Well, I had always wanted an opportunity and a
7 chance to defend my people and so he did call me
8 and wonder if I wanted to, that was an option, and
9 so I did jump at the chance.
10 Q Now, I'm moving on to a new subject area now and
11 that is about the marriage covenant. I understand
12 that you believe in the marriage covenant of your
13 faith?
14 A I do.
15 Q And you believe that God speaks to your prophet
16 about the people in your community?
17 A Yes.
18 Q And that God receives revelations about
19 individuals in your community in particular?
20 A Would you resay that. God receives revelations,
21 is that what you said?
22 Q I'm sorry. Yes. I didn't word that correct at
23 all. The prophet receives revelations from God
24 about individuals in particular?
25 A Yes, I do believe that.
26 Q And one of the most important kinds -- and sacred
27 of the revelations would be revelations about the
28 placement in marriage for life and all eternity of
29 individuals within your community?
30 A Yes.
31 Q And it's a huge commitment because it is for the
32 time on earth and forever essentially; isn't that
33 right?
34 A That is.
35 Q Now, you've testified that your understanding of
36 how it works sometimes is that a girl would pray
37 about who she might marry and whether she's ready
38 to marry and then she puts herself forward when
39 she is ready; is that accurate?
40 A Yes, she does make a request according to my
41 understanding.
42 Q And she would pray about it in advance of the
43 request?
44 A Yes, I would say so.
45 Q Has anyone ever asked you whether you're ready to
46 put yourself forward to be placed in marriage?
52
1 Q And would you agree that it's possible that as the

2 prophet -- it's the prophet who receives
3 revelations from God about marriage. It's
4 possible that the prophet might receive a
5 revelation about where a girl should be placed in
6 marriage without the girl first putting herself
7 forward.
8 A Not --
9 Q That's possible, isn't it?
11 Q The prophet can't have a revelation independent of
12 the girl putting herself forward?
14 Q Now, I -- you believe also that in order to get to
15 the highest level of the celestial kingdom of
16 heaven that you must live plural marriage?
17 A Yes, I do.
18 Q And you yourself aspire to get to the highest
19 level of the celestial kingdom of heaven?
20 A Yes, I would.
21 Q And do you agree that you feel that prophet and
22 God will act in your best interests with respect
23 to placement marriage?
24 A I do believe that.
25 Q Now, I would like to put a document to you and ask
26 you a few questions about it, and I guess that's
27 the other document, My Lord, that was in the
28 package. It has two blacked-out provisions in it
29 and 103 at the top of it.
30 THE COURT: Yes. Are we going to mark the grade years?
31 MS. GREATHEAD: No, My Lord. I just wanted -- I don't
32 think it needs to be marked. It was just to help
33 with what year was what.
34 THE COURT: Thank you. Okay. Witness, have you got
35 the other two pages that counsel is referring to?
36 THE WITNESS: I have three.
37 THE COURT: Yes. Yes, we have those, thank you.
38 MS. GREATHEAD:
39 Q And so witness, just as some background, this
40 document that I am placing before you is from an
41 affidavit that has been filed in these
42 proceedings. I believe it's Exhibit H to the
43 affidavit of Eric Nicols. And I'm sorry, My Lord,
44 I had the exhibit number for that affidavit
45 yesterday but I failed to write it down today.
46 But it's the exhibit of Eric Nicols.
47 What I would like to do is I'm going to read
53
1 you just certain passages of this and then I'm

2 going to ask you a question about it. So I will
3 tell you first where I'm reading from, and you
4 will note at the bottom, you see "witness" at the
5 bottom where it says "record of President Warren
6 Jeffs"?
7 A Yes.
8 Q And Warren Jeffs is your prophet; is that correct?
9 A Yes.
10 Q Okay. So if you could turn over the page. And
11 the first full paragraph -- or first full
12 paragraph in the column on the left and I'll read
13 that to you:
14
15 I read some mail through the afternoon. I
16 met with the ladies in their hourly prayers.
17 Between 7 p.m. and 7:30 p.m. the Lord took me
18 into the heavenly session so I was not able
19 to meet with the first presidency in the
20 appointed 8 o'clock p.m. prayer time that
21 evening. And I went through the heavenly
22 session until 6 o'clock a.m. the next
23 morning. The Lord showed me more marriages
24 to perform. He showed me that Thomas Barlow,
25 Louis Barlow's son, and Don Home and also
26 David Jeffs, my brother, couldn't exalt their
27 ladies, had lost the confidence of God, and
28 the lord revealed where they should be
29 placed. Also, two other young marriages were
30 revealed and I was told to travel to
31 Mesquite, Nevada and stay at Guy Allred's
32 house there and perform the ordinances in a
33 motel somewhere nearby.
34
35 I am going to pause there, and do you agree here
36 that your prophet Mr. Jeffs is speaking about
37 revelations that he gets from God?
38 A I have never seen this before. I'm not sure what
39 that has been talking about.
40 Q But as I read it to you don't you see that -- is
41 he not talking about -- when he says I -- "took me
42 into the heavenly session so I was not able to
43 meet with the first presidency in the appointed
44 8 o'clock prayer time" and that lasted until 6 in
45 the morning, is he not talking about what you
46 described as a revelation?
47 MR. WICKETT: My Lord, this line of questioning is
54
1 improper. The words speak for themselves. The

2 witness has not seen this before and has said she
3 is not familiar with it. She is not in any
4 position to say what Mr. Jeffs or the author of
5 this is saying or not saying.
6 THE COURT: Anything, Ms. Greathead?
7 MS. GREATHEAD: I'm just asking her if it's her
8 understanding what she understands to be
9 revelation to the prophet.
10 MR. WICKETT: With respect, My Lord, she just finished
11 saying she never seen this before and doesn't know
12 what it is. The words speak for themselves of
13 course.
14 THE COURT: Yes. She did say she doesn't know what he
15 was talking about.
16 MS. GREATHEAD:
17 Q Okay. Well, witness, would you agree the names
18 Barlow, Holm and Jeffs are common names, or are
19 familiar names anyways to you in the FLDS
20 community?
21 A Yes.
22 Q And would you agree that Mr. Jeffs here is
23 speaking about when he says that "my brother
24 couldn't exalt their ladies," what does it mean to
25 exalt your lady? To you?
26 A I'm not even sure about that.
27 Q What does "exalt" mean. Have you used that word
28 in the past?
29 A I could make a guess at what it meant but I have
30 never been told.
31 Q And down further then, at the last full paragraph
32 on that column your prophet says:
33
34 We left Arwen at 2:00 p.m. in the afternoon
35 and travelled to Mesquite, Nevada. I made
36 phone calls along the way. I had the bishop
37 William Esson Jessop gather the six ladies.
38 I talked to each of the ladies, Tom Barlow's
39 wife's first and then Don Home's former wife
40 and then David Jeffs' former wife. All over
41 the phone I talked to each one. Gave them
42 the lords message that their former husband
43 could not exalt them, and that the Lord had
44 revealed where they should be sealed for time
45 and eternity. I asked each one if they
46 received the Lord's message and were willing
47 to go forward, and all six ladies said yes.
55
1
2 And I'll ask the question -- I'm going to read
3 one more paragraph and then ask you a question.
4 If you go down then to the paragraph that begins:
5
6 I then brought in Madeline Barlow, David
7 Jeffs' former wife. She received the Lord's
8 message. I told her she belonged to Merril
9 Jessop. There was some emotion but she acted
10 on correct principles, and at least put on an
11 outward show of a smile. And I sent Merril
12 Jessop with Madeline back to Short Creek in
13 one car. Then separately I brought in
14 Susanna Barlow, the former first wife of
15 David Jeffs, and I felt a great concern about
16 her. I asked her again if she received the
17 Lord's message. She hesitated a long time.
18 She asked if there was any hope for David
19 Jeffs. I said, I love my brother but I love
20 God most and I will tell you the truth. What
21 the Lord has shown me that David cannot exalt
22 his ladies but if he will continue in his
23 repentance he can earn a degree of salvation.
24 Each step was a long hesitation for her. She
25 finally said almost in a whisper, I want to
26 do what the Lord wants me to do. I said to
27 her, I have told you what the Lord wants to
28 do. I told her I would give her an official
29 release before her sealing. I had her stand,
30 and taking her hand in the patriarchal grip
31 was a resistance. I told her there is no
32 force in this. That is when she said, I just
33 want to do what the Lord wants me to do.
34
35 So witness, is it your understanding that the
36 choice you have when God -- when the prophet
37 receives a revelation from God is that you can --
38 your choice is to do what the Lord wants you to do
39 or not do who the Lord wants you to do, are those
40 the two choices you face?
41 A Yes, you do have a choice.
42 Q Between those two options?
43 A Yes.
44 Q Now, are you aware of situations where teenage
45 girls have been placed in marriage with men much
46 older than the girl?
47 A Yes.
56
Cross-exam by Mr. Cameron
1 Q And was that something that you ever worried

2 about, that you would be placed into a marriage
3 with a man much older than you?
4 A No.
5 Q And is that because you believe that your prophet
6 would always act in your best interests?
7 A I knew that I would always have a choice.
8 Q And at the -- I'm going to refer to paragraph 9 of
9 your affidavit. And you've told us that you
10 believe in the principle of plural marriage and
11 that God will act in your best interests and the
12 prophet will act in your best interests and that
13 God will reveal to the prophet who you should
14 marry, and so what I'm wondering is why is it that
15 you mention the issue of force at the end of
16 paragraph 9 of your affidavit?
17 A Because I have heard that a lot of people believe
18 we are forced into marriages and I wanted to make
19 that clear.
20 Q And you're 22 years old now?
21 A That is correct.
22 Q Are you at all concerned that the prophet has not
23 had a revelation about where you should be placed
24 in marriage?
25 A No. I haven't made the request.
26 MS. GREATHEAD: Those are my questions, My Lord.
27 THE COURT: Thank you. Any other cross-examiners?
28 MS. GREATHEAD: Canada is coming, My Lord.
29 MR. CAMERON: My Lord, it's less than Canada. It's
30 Craig Cameron for the Attorney General of Canada
31 today.
32
33 CROSS-EXAMINATION BY MR. CAMERON:
34 Q Witness No. 3, I just have a few questions for you
35 and I will endeavour not to repeat what my friend
36 was asking, so forgive me if I pause.
37 You testified about attending school at
38 Southern Utah University. What are your fees to
39 attend that school?
40 A Like tuition? Is that what you're?
41 Q Yeah. What do you have to pay to attend the
42 school?
43 A The summer tuition is about 2,500.
44 Q And is there any tuition for the courses you take
45 online the rest of the year?
46 A Yes.
47 Q Can you tell us what that tuition is?
57
1 A Mostly I've just taken online courses even while

2 I'm down there in Cedar City so I can get a full
3 course load. But I've only once done a semester
4 online, so the fees for that I believe were 5,000.
5 I'm not exactly positive on this one.
6 Q So I'm just trying to get a picture of your annual
7 costs of going to school at Southern Utah
8 University and what I hear you saying is it's
9 somewhere between 5,000 and $7,500 for a year?
10 A No, that was only one year. So usually it would
11 be $2,500 for a year because I just do the summer
12 session.
13 Q Okay. Who pays that tuition?
14 A Mostly I and my family do.
15 Q Why didn't you go to school in Canada?
16 A I wanted to go to the -- I was interested in a
17 really good summer session. I wanted to go to the
18 school through the summer so I could continue to
19 work at the school during the winter.
20 Q Is it your understanding that going to school in
21 Canada would be less expensive than going to
22 school in Utah?
23 A Yes, but for the summer sessions in Utah they
24 didn't charge any more for a foreign student.
25 Q So I take it the cost of tuition has never been an
26 issue for you?
27 A Not really.
28 Q It's never prevented -- okay. Now, you said in
29 your affidavit at paragraph 8 that you have
30 personally studied the history of the events
31 surrounding the establishment of plural marriage
32 as an integral part of our religion speaking from
33 your perspective?
34 A Yes.
35 Q And that you had special interests in the lives of
36 many of the first plural wives, Eliza R. Snow,
37 Lucy Walker, and have been impressed by their
38 stories how they gained their testimony of the
39 principle. And I take it that you studied how
40 these early plural wives decided that polygamy was
41 for them?
42 A Yes.
43 Q And what sources have you read about those plural
44 wives?
45 A What is that you're asking? What sources?
46 Q Well, where did you study about these early plural
47 wives and where did you find the information about
58
1 them?
2 A Some of it was just the church history books.
3 Documentary history of the church.
4 Q And you would have found -- you would have found
5 those research aids where?
6 A Some of them we have in our home.
7 Q And outside the home?
8 A Yes, I think there would be some outside the home.
9 Q Did your research?
10 A Yes.
11 Q Did you attempt to try to get a balanced picture
12 of the accounts of the early plural wives?
13 A Yes, in a way.
14 Q Now, am I correct that Lucy Walker was married to
15 the prophet Joseph Smith?
16 A Yes, she was.
17 Q And she was 17 when she got married. Am I correct
18 about that?
19 A I'm not real certain about her age. I couldn't
20 say for sure.
21 Q Okay. Eliza Snow was also married to Joseph
22 Smith?
23 A Yes.
24 Q And then after Joseph Smith died Eliza Snow was
25 assigned to Brigham Young?
26 A Yes, I do think she married Brigham Young.
27 Q And are you aware that most historians --
28 according to most historians Joseph Smith had at
29 least 33 wives?
30 A I wasn't aware of that number.
31 Q What was the number you thought for the number of
32 wives he had?
33 A Some reason 27 sounded more familiar.
34 Q And were you aware that Brigham Young had 55 wives
35 by some accounts?
36 A No.
37 Q What was your understanding of about how many
38 wives he had?
39 A I wasn't sure how many. I knew he had plural
40 wives but I didn't know the number.
41 Q Now, other than the Eliza Snow and Lucy Walker are
42 you familiar with some of the other wives that
43 Joseph Smith and Brigham Young had and how they
44 gained testimony of the plural marriage principle?
45 A A few of them but not as well.
46 Q Have you heard about Fanny Alger who was married
47 to Joseph Smith when she was 16 years old?
59
1 A I have heard of her, that's all.

2 Q And have you heard of Nancy Marie Winchester who
3 was married to Joseph Smith when she was 14 years
4 old?
5 A No, I haven't heard that name.
6 Q Have you heard of Helen Mar Kimball who was
7 married to Joseph Smith when she was 14 years old?
8 A I have heard of her. I wasn't aware of how old
9 she was.
10 Q Since you heard of her, I wonder if you recognize
11 this quote from her from a book called In Sacred
12 Loneliness: The Plural Wives of Joseph Smith. I
13 will just read you the quote and maybe you could
14 tell me if you're familiar with it.
15
16 My father asked me if I would be sealed to
17 Joseph. He said to me if you will take this
18 step it will ensure your eternal salvation
19 and exultation and that of your father's
20 household and all of your kindred. The
21 promise was so great that I willingly gave
22 myself to purchase so glorious a reward.
23 After the marriage I felt quite sore over it
24 and thought myself an abused child, and that
25 it was pardonable if I did murmur.
26
27 Do you recognize that as something Helen Mar
28 Kimball wrote?
29 A I haven't heard that before.
30 Q Would that interest you to research more about
31 Helen Mar Kimball's mixed feelings or negative
32 feelings about polygamy?
33 A Sure.
34 Q And have you heard of Anna Eliza Young who I
35 believe was married to Brigham Young?
36 A I think so. It sounds familiar. I'm not sure.
37 Q Do you know -- well, perhaps I'll ask you then.
38 Do you know how she became to be one of Brigham
39 Young's plural wives?
40 A No.
41 Q Did you know that she published a book in 1876
42 that was called Wife Number 19, A life in Bondage,
43 Being a Complete Expose of Mormonism and Revealing
44 the Sorrows and Sufferings of Women in Polygamy"?
45 Are you familiar with that book?
46 A I have heard of it, yes.
47 Q Have you read it?
60
1 A No.
2 Q Are you aware that in the book -- perhaps I'll
3 ask. Are you aware that Anna Eliza Young has
4 described how despite the fact that Brigham Young
5 was older than her own father, that Brigham Young
6 applied pressure to both her parents and even
7 threatened to excommunicate Anna Eliza's brother
8 if she did not become his plural wife?
9 MR. WICKETT: My Lord, the witness has just said she
10 hasn't read the book.
11 MR. CAMERON: Yes, My Lord, this is information that's
12 derived more generally from Anna Eliza Young and
13 the witness said she is familiar with it, so it's
14 a fair question to ask her if she's aware that
15 Anne Eliza Young has expressed these sentiments?
16 THE COURT: Go ahead.
17 THE WITNESS: Sorry, what was the question?
18 MR. CAMERON:
19 Q Are you aware that Anna Eliza Young has said that,
20 despite the fact that Brigham Young was older than
21 her own father Brigham Young applied pressure to
22 both her parents and threatened to excommunicate
23 her brother if she did not become his plural wife?
24 A No, I am not aware that she said that.
25 Q Are you aware that she has said publicly:
26
27 I returned home feeling more than ever that
28 my doom was fixed. My religion, my parents,
29 everything was urging me on to my unhappy
30 fate and I had grown so tired of struggling
31 that I felt it was easier to succumb at once
32 than fight any longer.
33
34 Are you aware that that was the way she expressed
35 her experience of entering into plural marriage?
36 A No.
37 Q Now, I believe you've already testified that
38 you've heard or witnessed or read about accounts
39 of women who in modern times married -- entered
40 into marriage and plural marriage under the age of
41 19.
42 A What was that question again?
43 Q Sorry, I believe you have already testified that
44 you're aware that in recent times, in modern times
45 women in the FLDS have been married and entered
46 into plural marriage at the ages of under 19?
47 A Yes, I am aware.
61
1 Q And, in fact, your own sister was married at 16,

2 was she not?
3 A No.
4 Q Oh. How old was your sister when she married?
5 A She was 15.
6 Q Oh. Okay. And your mother, what age was she when
7 she was married?
8 A She was 16.
9 Q So I assume you would agree then that underage
10 marriage has been a feature of Mormon polygamy
11 since the beginning of Mormon polygamy?
13 MR. WICKETT: My Lord, the first part of the question
14 is proper, the last part is not.
15 MR. CAMERON:
16 Q My Lord, the witness has said that she has
17 researched the history of plural marriage in the
18 Mormon church and I'm asking her whether she would
19 agree with the statement that Mormon polygamy --
20 underage marriage has been a feature of Mormon
21 polygamy since the beginning of Mormon polygamy.
22 THE COURT: Based on her readings, okay.
23 THE WITNESS: Based on my readings I haven't noticed
24 that, no, to be a big feature.
25 MR. CAMERON:
26 Q But it has been a feature?
27 A It's possible.
28 Q Now, you testified that you were raised in a
29 polygamous family and you would like to be in a
30 plural marriage in the future?
31 A Yes.
32 Q And you are aware that polygamous marriage is
33 presently prohibited by the criminal law in
34 Canada?
35 A Yes.
36 Q But you're also aware, are you not, that polygamy
37 has not been prosecuted in Canada for the last
38 hundred years or so?
40 Q I assume that if you knew that you or your
41 prospective husband was going to be prosecuted for
42 polygamy you would think twice about entering
43 plural marriage; am I right?
44 A It would be something I would consider seriously.
45 Q In fact, I put it to you you would not enter into
46 plural marriage willingly if you knew you were
47 going to be prosecuted for doing so criminally?
62
Discussion re Scheduling
1 A I would really have to think about that at the

2 time. I can't say for sure what I would do now.
3 MR. CAMERON: Those are my questions, My Lord.
4 THE COURT: Thank you. Any other parties wishing to
5 cross-examine? Thank you. Any redirect?
6 MR. WICKETT: No, My Lord. Nothing in redirect.
7 THE COURT: Witness, thank you very much for coming
8 court.
10
11 (WITNESS EXCUSED)
12
13 THE COURT: Does that conclude the evidence for today?
14 MR. WICKETT: It does, My Lord.
15 THE COURT: Tomorrow we have an application in 55?
16 MR. WICKETT: I'm not exactly sure what the lineup is
17 tomorrow. Perhaps my friend Mr. Jones can speak
18 to that.
19 MR. JONES: Yes, My Lord. We've got the application
20 with respect to the late evidence. We are -- with
21 apologies, we circulated some materials to the
22 participants today and we will have copies of the
23 affidavits that we want to introduce for
24 convenience tomorrow.
25 So the plan is I am assuming to convene at
26 10 o'clock. I'm not sure what my friend had
27 planned. I think it will be fairly perfunctory,
28 perhaps half a day. And then if necessary on
29 Friday the cross-examination of Mr. Monroe and/or
30 Mr. Vanderboom, who are two of the affiants to be
31 discussed tomorrow. And the only other thing
32 housekeeping-wise, My Lord, there is one remaining
33 sealed envelope that was given to Madam Clerk
34 yesterday and that's marked Envelope A and I would
35 just ask that that either be destroyed or returned
36 to me by Mr. Wickett.
37 THE COURT: Okay. We'll give them to Mr. Wickett.
38 MR. WICKETT: Then I will destroy them.
39
40
41
42
43
44
45
46
47
63
Certification
1 THE COURT: Okay. We're adjourned then? Thank you.

2 MR. JONES: Thank you, My Lord, thank you very much.
3 THE CLERK: Order in court. Court is adjourned until
4 January 27th, 2011 at 10 a.m.
5
6 (PROCEEDINGS ADJOURNED AT 3:08 P.M.)
7
8 I, SPENCER J. CHAREST, OFFICIAL REPORTER
9 IN THE PROVINCE OF BRITISH COLUMBIA, CANADA,
10 DO HEREBY CERTIFY:
11
12 THAT THE PROCEEDINGS WERE TAKEN DOWN BY
13 ME IN SHORTHAND AT THE TIME AND PLACE HEREIN
14 SET FORTH AND THEREAFTER TRANSCRIBED, AND THE
15 SAME IS A TRUE AND CORRECT AND COMPLETE
16 TRANSCRIPT OF SAID PROCEEDINGS TO THE BEST OF
17 MY SKILL AND ABILITY.
18
19 IN WITNESS WHEREOF, I HAVE HEREUNTO
20 SUBSCRIBED MY NAME THIS 9TH DAY OF FEBRUARY
21 2011.
22
23
24
25 ______________________
26 SPENCER J. CHAREST
27 OFFICIAL REPORTER
28
29
30
31
32
33
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1 26 11 Transcript Day27 Canadian Reference Case On Polygamy

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1 26 11 Transcript Day27 Canadian Reference Case On Polygamy

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1

Witness No. 4 (for FLDS)

1 January 26, 2011

1 gain my highest degree in the celestial kingdom.

1 on earth as well as in the next life in eternity.

1 get down and talk to the child. Maybe they didn't

1 Q And whatever observations you've made about those

1 Columbia. I appreciate that it's difficult for

1 A We have meetings. We try to every night, like

1 wives as well as you know your real brothers and

1 exactly, you know, whether it was Creston or

1 sister wife joined your family?

1 Q And the wedding itself occurred in the United

1 Q Yes, I'm sorry. You said half a year and I

1 that without giving a name?

1 A Okay. I don't know -- I guess her parents were

1 any other member of your family any concern or

1 responsible or grown up, you might say. Age is

1 marriage, and it sounded to me like the process

1 A Around that time.

1 you consider one to be more important than the

1 Q It wouldn't occur to you to report that to the

1 affidavit was that you were thought to be a

1 THE COURT: Thank you. Witness, you're under

1 THE COURT: Thank you.

1 evidence with respect to a road that leads from

1 A Everyone has the ability to pray and talk with

1 you about the wider world because you talked about

1 way you believe in.

1 for the Federal Crown this morning. We do not

1 Bountiful, British Columbia?

1 Q And what did you do when you graduated from

1 Q What does that refer to?

1 Q Do you feel that you would have the ultimate right

1 Can you hear me?

1 Q So four girls are down from Bountiful studying in

1 Q So the friend from Colorado City was a member of

1 supplies as well as emotional support. Do you see

1 You mentioned that the community was providing --

1 that you know that have left the FLDS community

1 THE COURT: Ms. Greathead.

1 attained prior to leaving?

1 MR. WICKETT: Well --

1 MS. GREATHEAD: Well, that's fine. They were supposed

1 Grade 8 year, and if you look at the chart that

1 Q Now, while you were at school you mentioned that

1 Q Did you discuss it with anyone?

1 Q And would you agree that it's possible that as the

1 you just certain passages of this and then I'm

1 improper. The words speak for themselves. The

1 Q And was that something that you ever worried

1 A Mostly I've just taken online courses even while

1 A I have heard of her, that's all.

1 Q And, in fact, your own sister was married at 16,

1 A I would really have to think about that at the

1 THE COURT: Okay. We're adjourned then? Thank you.

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