THELMA

FORD

7/21/97
31

Q. boys side? A.
Q. A. Q.

So Robert

Brown

was

the supervisor

on the

2
3
4

Yes. And he was a tutor on the girls side?

5 6

Vh-huh. Do you know.who side? else was a part of the

.i
7
8 9 10

school

on the boys A.
Q. A.

Ray And

Swan. what role did he have maybe ln the school? have

He was school

the school

he would

11
,.."

been

the
Q. A. Q.

supervisor. some confusion there about then, that? but he about

"

12 13 14 15

Is there
No. No.

He was

And

so once

again,

we're

talking

1996.

Right? A.
Q.

16 17
18

Yes.
SO

Ray Swan

was

the

school

supervisor

for

the

boys? A.
Q.

19
20

Vh-huh, And Mr. side?

He

and Mr. Brown. Brown was also a supervisor on

21

the

boys A.

22
23
24

was

the

tutor

over

there,

too. between

(Off-the-record Mr.
A.

discussion

Hodge

and the plaintiff) and Mrs. Swan. Brother and

25

Yeah,

Brother

--

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SIMPSON COURT REPORTI.RS SHREVEI'ORT, LOUISIANA

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(318) 429-2160

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THELMA

FORD

7/21/97
32

./

1 2
3

Mrs.

Swan

were

over

the boys

school

with

the

assistance
Q.

of Mr. Brown. (By Mr. Bernstein) the boys Were there any other

4
5 6

people

involved A.
Q.

with

school?

No. So the three have been people Brother involved and Mrs. in the boys Swan and

7
8 9

school Robert

would Brown?
A. Q. A. Q.

Correct. And Ray. Ray . Raymond. Raymond. And you referred to him likewise -- was it Ray or Roy Swan?

10

11 12
.
/

13 14 15 16

A.
Q.

as"

B rot her. " A.

Q.

Is he an ordained

minister?

Yes. So Reverend Ray Swan they from and did his wife, in the were

17 18 19 20 21 22
23

they Did they

compensated they did

A. Q.

for what a check

school? for what

receive

New B~thany

in the boys Yes. Besides

school?

being side

the

school

-- I'm going being do the

to

go back

to the girls in the else

now.

Besides

r-- \

24

supervisor anything

school,

did JoAnn Home

Madden

25

at New

Bethany

For Girls? -------_._---_.(318) 429-2160

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&

SIMPSON COURT REPORTERS

LOUISIANA

THELMA

FORD

7/21/97
33

A. Q. A. Q.

Worked And As And She

in

the was

dorm. her role in the dorm?

2
3 4 5 6
7

what a hall what looked

monitor. did a hall monitor girls do? 24 hours a

A.
day, 7 days Q. responsible A. Q. A. Q. A. Q. A. Q. they how were old A. Q. also? A. Q. besides A.

after

those

a week. In other words, she the was girls the adult

8 9 10 11

for

overseeing

dormitory?

A hall. That hall of the girls dormitory?

Uh-huh. How She And Did And at about did April the Miss Miss the Chen? thing. Did she have any --

12 13
14 15 16

same

Russell? same Chen thing. and in April 1996, Russell, cbuld you while tell me

17
18

New were?

Bethany

they

19
20

April And

Russell April

was

21, was

Miss a hall

Chen

was

22.

Russell

monitor,

21 22
23

Yes. Were JoAnn And there any Miss other Chen, hall and monitors April Russell?

24
25

Madden, myself.

L_

._BAIN

_-----------_.
SIMPSQ:'II COURT REpORTERS

__ .-.----

I I
I
. .. _. __ ____J

&
--

SHREVEPORT, LoUISIANA

(318) 429-2160

._-_.

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. -_ .._.-

__ ._----_.
FORD

--

----

,THELMA

7/21/97
34

Q. four halls?
A. Q.

And

yourself.

In other

words,

were

there

2
3 4

Yes. Did JoAnn receive Madden, Miss Chen, or April for

5
6

Russell being

any extra

financial

compensation

hall A.
Q.

monitors? No. In other words, their compensation monitor and as what

7
8

9 10

included they did

A. Q.

their

services

as hall

in the school? Yes. Did they have any other monitor? duties besides

11
12
. -~

13 14
15

the

school A.
Q.

and being No. Now,

a hall

on the boys

side, Ray

besides Swan

being any

the

16 17
18 19

supervisor other

in the school,

did

have

responsibilities A.
Q.

at New about not

Bethany? that side. Mrs. Swan

I don't So you Brown

know would

know

whether

20
21

or Robert side? A. Q. running We've

had any

responsibilities

on that

22
23 24 25

I don't What

know

that. participated For Girls We've got in the in 1996? the hall
-

other

adults

of the New got people

Bethany

Home

in the

school.

L
BAJN

_
& SIMPSON
COURT REPORTERS

-----_.-SHREVEPORT, LOUISIANA

._-

(3 t 8) 429-2160

-----I ------------

;THELMA

FORD

7/21/97 35

monitors. A. Carter.
Q. A. Q. A. Q.

Was

there

anybody

cooking? Garcia, and Loraine

:2 3 4 5 6 7 8 9 10 11

Frank

and Julia

NOw, Yes. He's He's No,

is Frank

Garcia

a minister?

an ordained not he's

minister? no. And what was his

an ordained, not ordained. Home

role

at the New Bethany A.

Q.

For Girls? dorm. side?

Supervisor

in a boys

So he was on the boys Yes. And how about Julia

12
!

A. Q. role? A. did the

Q.

13

Garcia?

What

was

her

14
15

She woiked laundry. Is there for each One kitchen Besides that

in the kitchen.

Ms.

Carter

16
17

one

kitchen

for both

homes,

or

18
19 20

one

kitchen A.
Q.

side? for both Garcia, homes. any other adult

Julia worked did

21
22

staff

members A.

in the kitchen? help in the kitchen as a

The girls

23
24
25

home

-- as a project.
Q.

But not (Shakes

---------

any other head

adults

there?

A.
--BAIN

negatively)
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SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

(318) 429-2160

__ .._-----;THELMA FORD
1

._-----------7/21/97 36

Q.

Okay. Carter

Did either receive Bethany

Frank

or Julia

Garcia for what

2
3 4

or Loraine they did A.

Q.

any compensation Homes?

at the New

..

Yes. Besides the adults morning, that we've were talked there any Bethany or

6 7
8

about other

so far this adults

ln 1996

receiving

compensation on either

from New side

for responsibilities boys side? A. Q. given adults For No. Besides

the girls

9 10 11 12
f'

the people, morning,

the names were Home there

that any

you've other

me so far this living

13
14

at New Bethany

For Girls

or Home

Boys? A. Q. No. Going was back to 1970, roughly? that's when the Home

15 16 17
18

For

Girls A.
Q.

started

'70s. '70, Yes. And approximately. I'm not going to hold '71?

19 20 21 22 23
24

A. Q. you

to that. A.
Q.

Uh-huh. At what point did New Bethany Church come

25

into
L..
BAIN

existence?
__
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SIMPSON COURT REPORTERS

----------------SHREVEPORT, LOlJlSlANA

--

(318) 429-2160

.---------------THELMA FORD 7/21/97

._ ... 37

__

A.

I can't Would was

recall

the year. been soon after the Home been more

Q. For Girls

it have

3 4
5
6 7

started,

or would

it have

recently? A.
Q.

Soon And

after. I'm just a little going bit. to see Do you Home if we can think bei~g '80s? it was opened or

narrow within ten

it down five

8 9 10 11 12 13 14
15

years or was Not

of the Girls it in the In the

years, A.
Q.

'70s or '70s. than

'80s.

In the Main

'70s. Baptist

Other Church

the connection Texas,

to the West are there

of Henderson, have

any other

churches formal

that

a -- I'm with New And

going Bethany

to use

the words

relationship Home

Church

and New Bethany not any

For Girls? to ask you the

16 17 18 19 20 21 22 23

I guess, question, that you A.

Q.

it's probably but have is there a long Like

a good church

way that

consider with?

standing 1,000

relationship 1,300. of that

Yes. What's They And

the nature support us.

relationship?

A.
Q.

in the sense

that

you

tell

them your

what's calling and

going

on and what they

your

mission you

is, what

r>.

24

is, and then by possibly

support

financially to the Home

--------!

25

also

sending

volunteers

_BAIN

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SIMPSON COURT REPORTI.RS

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I

THELMA

FORD

7/21/97
38

1
2
3

to help
A. Q.

work? For 27 years, Other that than yes. relationship, have are there with?

that

4 5 6
7 8 9

any

churches

you-all

a relationship

Do you other

consider church A.
Q.

yourself

to be a ministry of some other

of some church?

or a satellite sure what how

I'm not I guess that

to answer

that. out in you used? is:

I'm trying Main Baptist

to find Church

You

said
l

the West was

10
11

Henderson
A.

Texas

-- I forgot

the term

Mothering. Mothering. mothering Yes. When When

Did

12
13 14 15 16

Q.

the West

Main

Baptist point?

Church

stop
A. Q.

New Bethany New Bethany Bethany

at some was Church

organized. was

the New

organized?
A.

17
18

But

they

still
They/re

support still

us. a supporter?

Q. A.
Q.

Right. Yes. Now,

19
20

my question

is:

In that church --

21
22 23
.'
'\

relationship A.
Q.

such Uh-huh.

as a mothering

or a sponsoring
l

church church

or something does that at

24 25

like this

that

is there for New

another Bethany?

that

point

--------BAIN

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SIMPSON COURT REPORTERS

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(318) 429-2160

-----_.

THELMA

FORD

7/21/97

39

A. Q.

No. Is New Bethany affiliated -between

2 3 4 5 6 7 8 9 10

(Off-the-record Mr. MR. MR. a discovery Hodge and

discussion the Go plaintiff) ahead. to

I
!

BERNSTEIN: HODGE:

I hate and

interrupt. trying to

I It's
!giVe
One It's

deposition,

we're

you
of

the answers
strong

that

you're
is

looking
in We

for

there.
Texas. to

their

supporters Texas.

Denton, just

a church that

in Denton, to you. MR.

wanted

11 12
13

disclose

BERNSTEIN: Baptist

Sure. Church in Denton, Texas

A. is one of

Maranatha our big

14 15
16 17 18

supporting Bernstein} with any

churches. is the New Bethany

Q.
Church

{By Mr.

affiliated A. No ..

organized

denomination?

Q.
Bethany I know would Within Baptist? A.

Religiously, Church for me.

would Do you

you

describe

the

New

19 20 21 22 23 24
) \

consider

yourself and I

you assume that

consider you

yourself

a Christian,

consider

yourself you

Protestant. consider yourself

division, true? We're

I gather

Is that Yes.

Independent Baptists.

Baptists. And that's pretty

25

Q.

Independent

RAIN

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SIMPSON COURT REPORlCRS

SHREVEPORT, LoUISIANA

(31 S) 429-2160

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I'" _ .. _ 'THELMA

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

FORD

-.-7/21/97
40

1 2
3 4

much

how

you

describe

yourself

as Independent

Baptists?
A. Q.

Independent Independent that Baptists An sets or

Baptists. Baptists. Independent Okay. Baptists What do you from

5 6
7

appreciate Southern A. have

apart

Independent an account We support we should,

Baptist

Church of

does

not

8
9

to give

to any kind

headquarters. we feel like

our own missionaries Southern Baptists

when have

10
11 12

where

their tells

certain them who

organizations to support.

they

support. tells

Someone us who to

No one

13
14

support.
Q.

In other Baptist Right. -- have ministries and

words,

Southern --

Baptists

have

15
16 17

the

Southern A.
Q.

Association

their

annual out

convention, of the don't

and

have

18
19

their

own

working

headquarters, that? A.
Q.

Independent

Baptists

do

20
21

Correct. What are the core Baptist

MR.

22
23 24 25

religious What

principles

of

the

Independent

beliefs?

I
I
1 BAIN

HODGE:

Indigenous

to this

church?
_

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&

SIMPSON COURT REPORThRS

(31 H) 429-2160

------------

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r- .. --

- l
41

THELMA

FORD

7/21/97

1 2 3 4 5
6

MR. say New A.

Q.

BERNSTEIN:

Yeah

-- well,

let's

Bethany.

At New Bethany? the pastor And answer he'll that. get his
!

I'd prefer (By Mr. I want

Bernstein)

chance. A. Q. principles Bethany

A. Q.

y?ur ask

understanding the question

of it though. again. beliefs or 1

Please What

I
as New

do you

see as the central Baptist

8
9 10 11 12 13 14 15 16 17 18 19 20 21
22

for the

Independent

Church

Church

exists? fundamental. Do you consider yourself a

We're Okay.

fundamentalist A. Q. A.
Q.

church?

Yes. And "fundamentalist" means what to you?

Separated. What way other -- and

I

guess,

probably

the

easiest teachings

-- what

do you

consider

the

important as an

or beliefs Baptist

of New Bethany Church? James Bible

Church

Independent A. church

We are a King

believing

only.
Q.

So you believe

that

the King

James

Bible

23
24

is A.
Q.
l
BAIN

Uh-huh. -- the appropriate

, _
SHREVEPORT,LoUISIANA

25

. __ . &
SIMPSON COURT REpORTERS

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I'~~'ELMA -FORD .-- --7

/~~i-;'7--'-'--'_ '_"'-'----- _. -42

-"--1

I
1

I
I
I
I beliefs Church?

A. Q.

Yes. -- Bible? of Independent Okay. Any other teachings or

2 3 4

Baptist

Church

or New Bethany

5
6 7 8 9 10 11 12 13

MR. HODGE: to focus core on the core beliefs.

Right

now,

you not

just just

want the

If it's

beliefs,

I'm going

to object broad

to the

form

of the asking

question

-- that

it's overly

if you're or

for a detailed principles as.

listing

of their their

beliefs

or whatever

church

refers

to them

MR. struggle beliefs A.

Q.

BERNSTEIN:

That's but

kind the

of my

is how is what Would

to refer

to them, for.

core

14
15 16

I'm looking you repeat Bernstein)

the question, What do you

please? consider, to be

(By Mr.

17 18 19
20 21 22 23

as a member the core A.

of the New

Bethany

Baptist or guiding the King

Church,

beliefs Just written.

instruction.

or teachings by accepting It has all And guideline.

principles? version We use under it

James

I as

it's
our

the answers.

I
1

for

of course,

we fall

that

fundamental
Q.

So you would church

consider would

whatever New

identifies Bethany

24 25

Ia
II

fundamentalist Church?
_

identify

Baptist

Il._.

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------(31R) 429-2160

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FORD

7/21/97
43

-,
I I
of King James what

A.
Q.

Yes. And that the teachings

2 3 4 5 6

Bible you

are the

believe A.
Q.

teachings

of the church?

That

I I

or follow? Yes. Have you ever had any reason Home to believe was

7
-8 9 10

that

a child

at the New Bethany

For Girls

mistreated?
A. Q.

No. Have was you ever conduct Home had any occasion an adult that to believe and would James children be Bible?

11 12 13
14 15 16

that

there

between

at the New Bethany contrary A.

Q.

For Girls

to the teachings No. Have you ever were

of the King

been

-- were

you

aware

of

whether Bethany Carolina? your

or not there Home For Boys there

any problems

at the New South around it, to

17 18 19 20 21 22
23

in Walterboro, any controversy

Was

knowledge? A.
Q.

Not How

to about

don't

know. to the New you aware Bethany of the

with

regard

Home

For Boys

in Longstreet? was any

Were

whether New

or not there Home

controversy

around

24
25

Bethany

For Boys MR. HARPER: ----

in Longstreet?
I'm
-----

going

to object

to

__ - -----_
BAIN

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SIMPSON COURT REPORTERS

SHREVEPORT, LOUISIANA

----

THELMA

FORD

7/21/97 44

the

form

of question.

Define

what

controversy

2
3

means. MR. Let's go back.

Q.

BERNSTEIN:

Okay.

That's

fair.

4
5 6

(By Mr.

Bernstein)

Is the New still open?

Bethany

Home

For Boys A.
Q.

in Longstreet

7
8

No. When was the New Bethany Home For Boys in

Longstreet
A.

closed?
I

10
11

cannot there

answer

that. member at the New named Reverend

Q. Bethany Larry

Was

a staff

12 13
14 15

Horne For Boys Rapier?

in Longstreet

A. Q.

Yes. Did he participate Bethany No. Was he prosecuted with being a staff for criminal member charges New in Horne For Girls as a staff at any member at

16 17 18 19 20 21 22 23 24

the New A.
Q.

time?

connection Bethany

at The to your

Horne For Boys

in Longstreet,

knowledge?
A. Q.

Yes. And do you know the result of that

prosecution?

'--

25

L
BAIN

A.

Yes.
I

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45

THELMA

FORD

7/21/97

Q.

And what He spent Going

was

that? in jail. of New time Bethany recall

2
3 4

A. Q.

a few days

back when

to beginning was the first agency?

iHome
any

For Girls, contact A.

Q.

you

5
6 7 8 9

with When

a state we began. was out

And what She came Do you No. Do you

the nature and looked who that

of that

contact?

A. Q. A. Q. looked

at the buildings. was?

remember

10
11

remember

why

she came

out

and

12
13 14 15 16 17 18 19 20

at the buildings?
A. Q.

No. Do you question recall about -- I'm going she came. to ask you

another A.
Q.

when

Uh-huh. Do you recall having whether made she came a complaint there out as a

I result
I

of somebody a child

to them in Home for

about

there,

or was

she out

I I I

connection Girls? A. licensing

Q.

with

licensing

the New

Bethany

21 22
23
24

Out

there

with

the connection

with

i
I

of New Bethany. Licensing. up New Bethany At that Home time, when you were you

25

I starting I ---_._-_.l..

For Girls,

were

------------_._REpORTERS

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&

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I

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46

7/21/97

1 2
3
4

working Home

with

the State

to try to license

New

Bethany

For Girls?
A. Q.

Yes. And were Home No. Do you know No. At the time you referred Home that she came out, out when the at why you weren't? you able to be licensed as the

5
6 7 8 9

New

Bethany
A. Q.

For Girls

in Louisiana?

A.
Q.

10 11 12
/

lady New

that Bethany

to as coming

to look with

For Girls have

in connection with

licensing, you with have her A.

Q. A.

did you any

any dealings with

her or did meetings

-\ 13 14
15

conversation that her. you done

her or any people?

or was Just Were

by other

16 17 18 19 20 21 22 23
24 ,\

in the meetings know. That's

with

her? time

I don't

been

a long

ago.
Q.

What and

I'm going

to want your

to do is go with the the

through state past

ask you about Would forward, you

dealings

agencies. and come

rather

I start 1996

from

or start

with

and go

backwards? A.
Q.
-_. ---_.-._BAIN

It doesn't Okay.
-

matter. New Bethany Home For Girls

25

After

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----7/21/97 47

sought become

to go be licensed, incorporated? A.
Q.

is that

back

when

you-all

Yes. And you were an officer of the

5
6

corporation?
A. Q.

Yes.
I

7 8 9

think

you were and

-- were

you president? vice president?

You

said A.
Q.

assistant, Yes. Vice

do you mean

10 11 12

president. Ford.

And

who was

president?

A.
Q.

Brother

And who were

the other

officers?

Do you

13
14 15

recall?
A.

I sure Does

can't,

no. still function as a

Q. corporation? A.
Q.

that

corporation

16 17
18

As far as I know. Do you know Home who the officers or directors in 1996,

19 20
21 22 23 24 25

of New let's

Bethany

For Girls

are or were

say besides A.
Q.

yourself no. did New

and Reverend

Ford?

I don't, In 1996,

Bethany That's Hodge

-- I'm getting just the way tell Does --you New

._._--' (318) 429-2160

sidetracked lawyers some

on something. and John and

do things,

will

that

lawyers

do this

some

don't.
-_. ------

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&

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THELMA

FORD

7/21/97

--------1

1 2
3 4 5

Bethany sort

Home

For Girls

have

a governing to say like

board a board

of any of

that

would

correspond board?

deacons
A. Q.

or a church

..
NO.

So the management solely Yes, with

of New Bethany Ford?

Home

For

6
7

Girls

rests
A. Q. A. Q. A. Q. A. Q.

Reverend

and members. And members of the church?

8
9

And members. Uh-huh. And who

Outstanding are

members. members?

10 11

the outstanding Robert Brown.

Frank

Garcia.

12
/

Any others? No. How many members does New Bethany Baptist

13
14

15
16

Church

have? A.
Q.

Thirteen When yo~

now. say ~now," I gather there was a

17 18 19
20

change? A.
Q.

Yes. And what was the change? gone. say "everybody's gone,
II

21 22 23
24 25

A.
Q.

Everybody's And when are gone? And And you

the

children A.
Q.

the workers. the workers. Are the workers ---are the

BAIN

& SIMPSON COURT

REPORTERS

SHREVEPORT,LotJISIANA

- -----(318) 429-2160

7/21/97
49

:people A.
Q. A. Q.

2
3 4 5

Uh-huh. -- that Yes. So let me go through Madden New that list. still You said we've named so far?

6
7 8
9

that

JoAnn

a n d+ Ro b e r t; Brown

are

involved A.
Q.

with

Bethany?

Yes. Miss Chen and April Russell have gone off

10 11 12 13
14

to school? A.
Q.

Yes.
I

forgot Are

to ask you they still

about

Reverend with

Swan New

and

his wife.

associated

Bethany? A.
Q.

15 16 17 18 19 20 21 22 23
24

No. Where are they? don't know.

A. Q. A. Q.
Garcia?

I really And

Loraine still

Carter? there. there. And ~rank and Julia

She's She

is still

A.
Q. A. Q.

Correct. They're Yes. So besides the children that left, the still there?

25

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(318) 429-2160

SHREVEPORT, LotJISIA:-;A

-_._-----THELMA FORD 7/21/97 50

church 1996

members would have Swan

that been

are

gone

now

that

were

there

in and

2
3 4 5 6
7

Miss wife still

Chen and

and

April

Russell Carter?

Reverend A. Q. others

and

his is is

Loraine

Loraine Loraine gone? Yes. So Church that would

there. Thank you. But the

there.

have A. Q.

would have

have had

meant about

that 17

New

Bethany

9 10
11

Baptist members? A. Q. A. Q. New

adult

Yes. In early 1996?

12
I

13 14 15 16 17 18 19 20 21 22 23 24 25 Sunday Church? size

Yes. What's Baptist I don't I know their the largest has or most members that

Bethany

Church know. some

ever

had?

A.
Q. of

Baptist in keep

Churches of of

count

the School School

attendance Do you-all Bethany did. do

terms track

Sunday Sunday

attendance. attendance at

New we

Baptist

Church?

A.
Q.

Yes, And

what

you

recall New

as

being

a typical Baptist

School

attendance

for

Bethany

A.

200.

--BAIN

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(318) 429-2160

&

SIMPSON COURT REpORTERS

SIIREVEPORT, LoUISIANA

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THELMA

FORD

7/21/97
51

Q. The 17 that A. Q. attendance Boys and A. Q. School class A. Q. A. Q. A. Q. church

And

ot those
talking

200,

how

many

are

adults?

2
3
4

we're Yes. And would the

about?

balance children Home

of

the at

Sunday

School Home For

5 6
7

be

New

Bethany

New

Bethany

For

Girls?

That's And at

correct. is a regularly-scheduled Baptist Church? Sunday

8 9 10

there New

Bethany

Correct. There Yes. And No. In 1996, were there regularly-scheduled there is now? was in 1996?

11

."\

12 13 14
15

16 17
18

services? A. Q. A. Yes. And when did those occur? Sunday, and Sunday

19 20
21

Wednesday special Special Colleges different

night, days nights coming singing

night;

and Q. A.

-- special being? through, groups

nights.

22 23 24
(

putting coming

on through,

programs, visitors. Q.
L___

.-\
25

And
. __ .

are
_. _

there

regularly-scheduled

BAIN

&

SIMPSON COURT REPORTERS

SHREVEPORT,

LOUISIA."A

(318) 429-2160

THELMA

FORD

7/21/97
52

.,./

serVlces A.
Q.

currently Yes. And are and

at New

Bethany

Baptist

Church?

2
3

they

still

on Wednesday

night,

4
5 6

Sunday

morning, A.

Sunday

night?

Correct. MR. BERNSTEIN: Why don't we take a

7 8
9

short

break. (Recess)
Q.

(By Mr. that

Bernstein)

And

Mrs. we

Ford, took your

I that

10 11 12 13
14

understand either

during

the break

just

individually of some

or in conversation, things has been

recollection there's give with me. some And

refreshed you need

and to is

supplemental I guess the

answers first

that

one

I understand

15
16

regard
A.

to the governing Yes. Okay. We do have And who

board? a board of directors. of

17 18 19
20

Q. directors? A.
Q.

is on the board

L. L. Morris Can you Morris, D-A-R -spell

in Denton, his last

Texas. name?

21 22
23
24
x,

A.
Q. A. Q. A.
----BAIN

M-O-R-R-I-S.

W. T. Darnell.

D-A-R-N-E-L-L, And where And he's

Darnell.

is he? in Sulphur,
-----

25

Louisiana.
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(3tH) 429-2160

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SIMPSON COURT REPORTERS

SHREVEPORT, LoUISIANA

~--- -------------------------,

THELMA
,/

FORD

7/21/97 53

---"\

Q. A. Q. A. Q.

And

any others?
I

2 3 4 5

I'm sorry. But Yes, there there

cannot

think

of the others.

are more? is. question that

I

The other some

understand

6
7 8 9 10
11

you've members?

got

more' information

for me on is staff

A.
Q. A.

Yes. And

There who was

was

another

staff.

that?

Desni

Kwak. spell these for me? and did she was

25.

Q.
A. Q. A.

Can you

,......

_.

12

D-E-S-N-I, And what

Kwak,

K-W-A-K,

13 14 15
16 17

responsibilities

she have?

School And Yes. And was

and dormitory. she a monitor on the school side?

Q.
A. Q.

then

what

did

she do? side. role in the

18
19

A.
Q.

She monitored And then what

the boys was her

20
21 22

dormitory? A.
Q.

Just
I

hall.

Hall

dormitory without

supervisor. but on

think

it goes

saying,

23
24

the

girls A.
Q.

side? Yes. And then what else was there?

-----SHREVEPORT, LoUISIANA

25

- ----------BAIN

--

&

SIMPSON COllRT REPORTERS

(3IH) 429,2160

7/21/97

54
.'

-.\ 1

A. Q. A. the rigid Q. Bethany A. Q. boys and A. Q. Bethany would be A. Q. Girls, with which there in in

Back Yes. We

to

license.

2
3

did

apply we of

for

a license. it. did you

Because

of

4
5

guidelines, What 1996? Ten And girls? Boys So and to 18. ages

cancelled children

have

at

New

6
7 8

that

would

be

on

the

girls

side,

or

9
10 11
,"""

girls. child old that and you the had oldest at New

the

youngest
10 years

.....

12

1996

was

13 14 15 16 17
18 19 20 21

18? Correct. In
I

terms

of

the

New

Bethany you're

Home

For

understand

is what have you

familiar a girl

in Arcadia, 10?

ever

had

younger A. Q. you have

than

Yes. And had at what New was the youngest Home For age Girls child in that

Bethany

22 23
24
~,

Arcadia? A. Q. Girls,
I _

Five. The do children they come at to New be Bethany there? Home For

'

25

how

-----------------_.---BAIN

---SHREVEPORT, LoUISIANA

---(31H) 429-2160

&

SIMPSON COURT REpORTERS

--_._----

---_._--------------,
7/21/97
55

THELMA
./
\

FORD

A. Q.

Parents When call you

and say

juvenile

officers. what happens? trouble about Do with

~parents,~ say,

3
4
5 6

parents my

you up and and I've

I'm having good

13 year

old,

heard

things

you?

Is that A.
Q.

how

that

starts?

That's

correct. hear about New Bethany

1I

7
8 9 10 11

How do the parents

Home

For Girls?
A.

From

someone

else. hear or
I

Q. other

Do they

typically

about mean,

it from do you know? is:

parents one

or ministers, thing that's

12 13 14
15

Is there Do you-all
A. Q.

guess

my question

advertise? No. What does a parent have to do to get

16

their

child
A. Q.

in New Bethany Fill out

Home

For Girls?

17
18

the applications. you: Do you have getting anything a child to in

Let me ask the process Home Yes. And what's

19
20

do with New

of a parent

Bethany
A. Q.

For Girls?

21
22 23
24 "'. '_
,

your

role

in that the

process? child. coming to

A.
Q.

I am the one In other Home

..

than

accepts

words,

for somebody you

-----

25

New

Bethany
--

For Girls,

make

the decision

_---------

_.. _J
(31 R) 429-2160

BAIN

& SIMPSON

COURT REPORTERS

SHREVEPORT, LoUISIANA

--------_.

THELMA
/,\

FORD

7/21/97 56

1
2
3

whether
A. Q.

they

get

in or not?

Yes. Do you have For Boys? Yes. Are you whether also the one gets that into makes the New the Bethany anything to do with New

4
5
6

Bethany A. Q. decision Home

7 8
9

somebody

For Boys A. Q.

in Arcadia?

Yes. Did you that have anything to do with

I

10 11 12
13 14

-- what the

do you same

call

process? you or --

So that

can use

terminology

do, do you

call

it admissions

or application, A.

(No verbal

response) discussion the plaintiff) Do you understand? to get the between

15 16 17
18

(Off-the-record Mr. Hodge

Q.

and

(By Mr.
I

Bernstein)

A. right words.
Q.

understand. Yes, that intake would the way school?

I'm trying study.

19
20

And

be the process through

of a parent that

21 22 23
24

calling they

up and all into Yes. Intake very

---

the decision

come
A.

the

Q. not asking

study.

Have

you

done

any

-- I'm Did
-

25

good

questions
----_.

right
---

now.
----

you
---

t.
BAIN

-----_.

&

SIMPSON COURT RcPOR~RS

SHREVEPORT,LoUISIANA

(318) 429-2160

_
1 2 3
4

_.

__ ._----FORD

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THELMA

7/21/97 57

have Home in

anything For Boys

to

do

with

intake or

for the

the New

New

Bethany Home

~n Longstreet or Alabama?

Bethany

South A. Q.

Carolina No. So the

5 6
7 8 9

only be

involvement regard to

that the

you've two New

had

with

intake Homes A. Q.

would

with

Bethany

located

in Arcadia,

Louisiana?

Correct. And let's go fills back out to an the part about you That's

10
11

said the

that first A. Q.

a parent step? Yes. And an then

application.

12
/-,,~

13
14 15

what

happens

after

the

parent

fills

out A.

application? mail and when what me the you kind tests. of ~edical tests do they have the results of their tests,

They

16 17 18 19 20 21 22 23
24

their

physicals, Q. And

applications. say of "the tests results is that? of the

their

tests," A.

Medical What

Q.
' to have? A. Q. A. Q.

kind

AIDS. What Herpes So they else? 2, RPR, TB, and-a physical. of the
----_.(318) 429-2160

25

mail

you

the

results

----.--

-------SIiREVEPORT, LoUISIANA

RAIN

& SIMPSON

COURT REPOR1T:RS

....

..

_-_._

.._-----

--

--_._-_ .. -.._._---58

THELMA

FORD

7/21/97

medical with the

A. Q. A.

tests

and physical

along

with

-- is that

2
3 4 5 6

application? With Okay.

I

the application. What happens call. next? Take the child. the the

return

their

Q. child medical A.
Q.

So you make

the decision

to take and

based

on the written

application

s
9

tests? Correct. And prior A.

Q.

10
11

you

do not

interview

the child

or

parents

to taking

the child?

12 13 14 15 16 17 18 19 20 21 22
23

No. Do the parents before No, not have to make any financial

arrangements A.
Q.

the child -could to you, results back

is accepted?

So a parent my child

call and

you up and they send

say, you

want

to send

the

written and then A. pay.

Q. A. Q.

application, you call

of the medical and say yes

tests,

them There

or no? can pay, they

Yes.

is a -- if they

And how Whatever I guess scale?

is it determined they that's say. what

if

they

can

pay?

24

I would

call

25
I

sliding
1.- _._._.

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SIMPSON COURT REPORTERS

- .. -- -- (318) 429-2160
... - ...__ ...- .---

BAIN

SHREVEPORT, LoUISIANA

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

-----.--

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...

-_.

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

r ..---. ---'--'I THELMA FORD

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7/21/97 59

A.

Uh-huh. What
$350

l
,
I

2
3 4

Q.

is the sliding a month.

$350

scale?

A.
Q.

The

a month

that

we

talked

about

5
6

earlier? A.
Q.

Uh-huh. Okay. earlier, while So the that

$350

7 8 9
10 11

a month all

that

you

described expenses A.
Q.

covers at the

the child's

they're

school?

Correct. So that meals, covers room not only the school, clothes; but

12
13

also sorts

covers

and board,

those

of things?
A. Q.

14 15 16 17 18
19

Not The

clothes.
$350

a month

covers

what? the -between

A.

The board,

the school,

(Off-the-record Mr.
A.

discussion the plaintiff) and

Hodge

and

Okay.

$350

for the tuition, -- room

churches food.

20 21 22
23

take

care Q.

of the board (By Mr.

and board, Now, that's attorney?

I

and your

Bernstein) with that

answer

after A.

consulting -- well, That's

I

your is my

Yes there. it.

just

got is

24 25

confused it.

the way had all

it works. that --

That

That's

just

BAIN

&

SIMPSON COURT REpORTERS

SHREVEPORT, LoUISIANA

(3IH) 429-2160 .

- ----- _--_.

- -----

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THELMA

FORD

7/21/97 60

Q.
A. Q.

So the $350 School

a month

is for what?

2 3

tuition. pays that depending on their

So a parent to pay?

4
5 6
7

ability
A. Q.

Yes. So if they and are on welfare, rich, they they pay

$350

don't a

pay

anything; month? A.
Q.

if they're

8 9

Correct. And in 1996, Home how many children Let's did you say in

10
11

have Mayor

at New Bethany June

A.

For Girls?

12 13
14 15

of 1996? Girls Well,

200

and boys? okay,

or

Q. A.
Q.

both. less. records

Boys

and girls.

more

16 17 18 19
20

Do you keep like

on the children and

in

terms like

of things that?
A. Q.

school

and health

things

Their

files. child that attends New Bethany has a

So each

21 22
23
24

Home file?

For Boys

or Home

For Girls

in Arcadia

A.
Q. A. L_._
BAIN

Yes. What's That in that file?

25

application.
-_.
_.

&

SIMPSON COURT REPORTERS

SHREVEPORT, LOUISIANA

--_._-(318) 429-2160