EXHIBITD

DEPOSITION OF:
Winston K. Blackmore
APPEARANCES
For the PlaintirT:
Ab.n W. Mortcmcn
Lance L. Milne
DEWSNUP. KJNG & OLSEN
36 Suu1h Slate Slrcct
Suile 1400
Sail Lake Cil)', ULa1J 84111
for the Defendant United ErTan Plnn Tn...Jjt, by and
through Bmce R. Wisan, Coon-Appointed
 
John Edward Han5Cn
SCALLEY READING BATES HANSEN & RASMUSSEN, P,C,
15 Wesl Soulh Temple
Suilc 600
Sail Lake Cily, Utah 8410 I
Jeffrey L. Shields
CALLISTER NEBEKER & McCULLOUGH
Zions Bank Built.Jing
1
Suite 900
I 0 Ea" SouLh T empk
SaiL Lako CiLy, ULah 64 133
Also Present: Ken 0\er
INDEX
WITNESS
WINSTON K. BLACKMORE
PAGE
Ex.ami n<itiun by Mr. H:ms:cn 4
Exan1inaLior. by Mr. Monc.:nscn J6
FUithcr Exam by Mr Han sen I 07
Funher Exam by Mr_ Monensen 107
Repo11crs, Inc.
INDEX TO EXHIBITS
EXHIBITS
No. l Declaration of Winston
Kaye Blackmore
PAGE
17
No. 2 Declaration of Winston 17
Blackmore
No. 3 Amended and Restated 36
Declaration of Trust of the
United Effort Plan Trust
No. 4 Second Supplemental Affidavit
of Proposed Trustee Winston
Kay Blackmore
-ooOoo-
Reponers, Inc.
Jill C. Dunford RPR, CSR
Page 2
Page 3
M.J., aka ELISSA WALL v. WARREN JEFFS
Page 4
1 February 28,2014 9:15a.m.
2 PROCEEDINGS
3 MR. HANSEN: Let the record reflect that
4 today is Friday, February 28th, 2014, and we are met here
5 at the law office ofScalley Reeding Hansen Rasmussen for
6 the deposition of Winston Blackmore. And I think we are
7 ready to begin this deposition. We are going to ask our
8 court reporter, Jill Dunford, to give the witness the
9 oath.
10 WINSTON K. BLACKMORE,
11 called as a witness herein, having been ftrst duly sworn
12 by the Certified Court Reporter to speak to the truth,
13 was examined and testified as follows:
14 EXAMINATION
15 (BY MR. HANSEN)
16 Q. Mr. Blackmore, would you please state your
17 full name for the reeord.
18 A. Winston K. Blackmore.
19 Q. And where do you reside?
20 A. l reside in Creston, British Columbia,
21 Canada.
22 Q. Have you ever given a deposition before?
23 A. Yes, I have.
24 Q. About how many times?
25 A. One, one other time.
Page 5
1 Q. Okay. But you have some familiarity with
2 this deposition process we're going through today?
3 A. Yes, I do.
4 Q. And you understand that the testimony you
5 give today is with regards to-- we have asked you to
6 testify today with regards to information you may have
7 relating to a lawsuit that's been filed in the state of
8 Utah titled "M.J. versus Warren Jeffs, eta!."
9 Do you understand?
10 A. Yes, I do.
11 Q. And do you understand that the testimony you
12 give today has the same requirement of truthfulness and
13 honesty, the same as if you were testifying at trial
14 before a judge and jury?
15 A. Yes, I do.
16 Q. And do you understand that the testimony you
17 give today may, in fact, ultimately be presented to the
18 jury at trial?
19 A. Yes.
20 Q. We have requested that we take this
21 deposition and you have voluntarily agreed to come to
22 Salt Lake City to give this deposition; is that correct?
23 A. Correct.
24 Q. Let me just ask a little bit of background
25 infom1ation.
2 (Pages 2 to 5)
REPORTERS, INC. (801) 746-5080
DEPOSITION OF:
Winston K. Blackmore
Page 6
1 Where were you born?
2 A. l was born right-- well, it was called
3 Lister then, Lister, B.C. in Canada, which is now
4 Creston.
5 Q. What year were you born?
6 A. 1956.
7 Q. Did you grow up in Canada?
8 A. In the same place on the same property I have
9 lived all my life.
10 Q. So a long-tenn resident?
11 A. Long-te1m.
12 Q. Let me ask specifically have you been
13 involved with the FLDS Church or polygamist community in
14 Canada?
15 A. Yes, T have.
16 Q. Could you tell us about your background with
17 regards to the FLDS Church or its predecessor
18 organization?
19 A. Well, l was born-- my father was a member of
20 the organization and I was born into his family, one of a
21 large family, and lived my whole life in our faith.
22 Q. And have you -- so you have been experienced
23 or knowledgeable about the FLDS Chureh your whole life;
24 is that correct?
25 A. The FLDS Church didn't even exist prior to
Page 7
1 19 -- the 1990s, but I have definitely been involved as a
2 member and later on as an officer.
3 Q. When you say the FLDS Church didn't exist
4 before the 1990s, could you explain to us a little bit
5 about, you know, the history of the FLDS Church or how it
6 evolved to become the FLDS Church?
7 A. We were never known as the FLDS Church when
8 we were children growing up. And until probably the
9 mid-'90s, '94, '95, when we started referring to
10 ourselves as the FLDS Church, somewhere in there, I don't
11 know exactly when it was, I discovered-- I discovered,
12 beeause I didn't know before that, that there was
13 actually a registration in 1991 of the FLDS Church. But
14 we didn't really know ourselves as that. And from what l
15 understand, we did that for some legal reason. We
16 incorporated the name for some legal reason.
17 Q. As you grew up, what was the religion called
18 or what did you call-- how did yot1 reference your group?
19 A. We actually referenced ourselves as members
20 of the Church of Jesus Christ of Latter-day Saints
21 personally, beeause my father went on a mission for the
22 Church and he studied on his mission, he studied the
23 basic doe trine of the Church.
24 When I was baptized, I was baptized a member of
25 the Church and confirmed a member of the Church ofJesus
Jill C. Dunford RPR, CSR
M.J., aka ELISSA WALL v. WARREN JEFFS
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Christ of Latter-day Saints, but we lived under -- in an
organization known-- well, referred to as The Work, The
Priesthood Work. It was a group of men who had a
commission to see to it that we praeticed all of the
original principles of our Mormon faith.
Q. And one of the principles that distinguished
your grOllp, The Work, as you were growing up from the
offieial church of Jesus Christ of Latter-day Saints was
the practiee of polygamy; is that 1ight?
A. Yes, it is.
Q. The praetiee of polygamy would have been a
fundamental principle or practiee of The Work or what
later became the FLDS Church. Would that be fair to say?
A. Yes, it is.
Q. And at some point I understand you beeame a
bishop up in Canada?
A. Well, first-- the first part of my ministry
was in 1980. I was aetually appointed by our then
president Leroy Johnson to be the Sunday School
Superintendent. And in 1984, he offieially ordained me a
bishop.
Q. Okay. You were a bishop of what size or what
congregation? Can you give us some understanding of
that?
A. The size --we got up to around a thousand
Page 9
people, but we were probably less than half of that to
begin with.
Q. But how broad of an area were you bishop
over?
A. Tlu-ee, three eonununities; a community in
Creston, a eommunity in Cardston, Albe11a, and also a
community in Rosemary, Alberta.
Q. What-- would I eall those FLDS communities
or what-- how would you characterize-- you're talking
about communities that were practicing yom same faith 01
religion; is that right?
A. Yes, I was, but they were-- these people
were all LDS, you know, that's where they were-- how
they were bam and became about who were just trying to
practice, you know, their original fundamental principles
of their faith.
Eventually we had a community in northem Idaho
and I was also bishop of that.
Q. Okay. Eventually the association of the
group became known as the FLDS; is that right?
A. Yes, it did.
Q. You served in the capacity of being an FLDS
bishop; is that right?
A. Yes.
Q. Were there any other FLDS bishops in Canada
3 (Pages 6 to 9)
REPORTERS, INC. (801) 746-5080
DEPOSITION OF:
Winston K. Blackmore
Page 10
1 or were you the bishop for all of the FLDS g roups in
2 Canada?
3 A. Twas the bishop for them and looked after
4 them.
5 Q. How long did you serve in the role o f being
6 an FLDS bishop -- the FLDS bishop in Canada?
7 A. From '84 to 2002.
8 Q. And can you tell us about your duties or
9 responsibilities as a bishop over these communities?
10 What would a bishop do in the FLDS Church?
11 A. Well , I received the tithes and the
12 offerings, established a storehouse. I looke d after the
1 3 widows and the fatherless. I looked after the dead. If
14 anyone died, I had responsibility to take care, see that
15 they were properly taken care of in their-- in their
16 death and I was --my responsibility was to pay for their
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service and see to it that they were -- the family wasn't
18 burdened.
19 As a-- I also basically looked after the
2 0 prope1t y, the Church's property, and was also a
21 husi nessman in the process, so ...
22 Q. What kind of business -- your work has been
23 as a businessman?
2 4 A. Yes, it has. We were into fanning. We had
25 an extensive farming operation and forestry. We
Page 11
1 manufactured fence posts, traded them, and marketed and
2 tn.Jcked them.
3 Q. Now, do you have any experience or
4 invol vement with the UEP Trust?
5 A. Well , I was a Trustee from-- o fficial
6 Trustee from 1984 -- or from-- I mean I guess I was
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unofficial from '84 to '86, beeause I did look after the
8 property.
9 Q. So if I understand right, you were bishop
10 beginning in I 984. Is that right?
1 1 A. Yes.
12 Q. And then I bave seen in the declaration where
13 you indicate you were appo inted as a Trustee of the UEP
14 Trust in 1986. Is that correct?
1 5 A. Yes, I was, first in February, and then on
1 6 the passing of President Johnson, I attended the first
17 Trustee meeting that I went to.
1 8 Q. That would have been in 1986?
19 A. Yes.
20 Q. So you served as a Trustee of the UEP Tmst
21 for how long?
22 A. Offi cially, from ' 86 to 2002, officially.
23 Q. And you say "officially." Tell us what
2 4 happened in 2002.
25 A. Well, in 2002, Warren Jeffs had me dismissed
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Ji ll C. Dunford RPR, CSR
M. J ., aka ELISSA WALL v . WARREN JEFFS
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from the Church and supposedly from my dut ies, but I
wasn't notified of the dismissal of my duties unti l later
on that year when I got an offi cial notiee. But nothing
really changed for me. I s ti ll did what I was doiog.
Q. Have you eontinued to serve as a bi shop in
Canada after 2002?
A. Yes, I sti ll do have quite a good-sized
congregation still.
Q. Your service as a bishop si nce 2002, has that
been in connection with the FLDS Church or has that been
separate from --
A. No, it's separate from 01em.
Q. So ifl understand correctly then, in 2002,
Warren Jeffs dismissed you as the FLDS bishop in Canada? .
A. Yes, he did.
Q. But you continued to serve those who were
wanting to be involved wi th your congregation from that
time forward?
A. Yes, I d id. ln fact, this is tbe 30th year.
Q. So you have been serving as the bishop up in
Canada for 30 years?
A. Thirty years.
Q. That' s a long time to be a bishop.
A. I wou ld li ke to retire-- I mean have
somebody else do it. It's not a fun job, as you know.
Page 13
Q. I want to ask you about being a Trustee in
the UEP. Did the UEP Trustees hold yearly meetings?
A. We generally had a meeting, it could have
been over a dinner meeting or at the attorney's office or
at-- down around our conference, our annual conferenee
in April. We had-- sometimes it was quick and someti mes
it was quite long.
Q. You are saying annual conferenee. Those
would be conferences of the FLDS Church, in April
conference of the FLDS Church; is that eorrect?
A. They would be after when we began to be
recognized as that at our conference.
Q. You are saying you had conferences before it
was recogni zed as the FLDS Chureh?
A. Yes, we did.
Q. Let me ask, when you participated in those
Board of Trustee meetings of the UEP, what types of
matters did you discuss?
A. We mostly discussed the status of the current
lawsuit. In fact, that was our predominant discussion.
We discussed where we were at in our cunent sui t. We
were fighting one from ' 87.
Q. You' re saying there was a lawsuit involving
the UEP Trust going back to 1987?
A. Yes, there was.
4 (Pages 10 t o 1 3)
REPORTERS, I NC. (801) 746- 5080
DEPOSI TION OF: M.J., aka ELISSA WALL v. WARREN J EFFS
Winston K. Blackmore
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Q. So when you talk about a ctUTent lawsuit, you 1
weren't talking about this M.J . -- 2
A. Oh, no. 3
Q. --litigation that we're here on today? 4
A. No, we were talking about a ten-year suit 5
that we were involved in. 6
Q. Generally, tell us the nature ofwbat that 7
lawsuit was about. 8
A. It was about property. There was a concem 9
for some of the people that did not -- there was a split 10
in 1982 in our -- among our people and that's where the 11
Centennial Park people came from and ours. Some of those 12
people were-- felt very threatened in their homes. It 13
was 44 different families that had homes on the UEP and 14
they felt threatened in their homes. 15
And so by 1987, I believe it was '87, it then -- 1 6
I was served in Canada as a Trustee to defend an action 17
from a group of people who were trying to be secure in 18
their homes. 19
Q. And that lawsuit went on for many years? 20
A. Ten, and it occupied pretty much all of our 21
time and our thinking and ow· money and our conversation. 22
It dominated our conversation. 23
Q. As a Trustee of the UEP Tntsl, were you 24
involved in deeisions with regards to arranged marriages 25
Page 15
by the FLDS Church? 1
MR. MORTENSEN: Object to the form. Go 2
ahead. 3
Q. (BY MR. HANSEN) He may state an objection 4
for the Judge to decide later, but you can go ahead and 5
answer. 6
MR. MORTENSEN: Sorry, I should have wamed 7
you. 8
THE WITNESS: I just need to know the rules 9
here. 10
Q. {BY MR. HANSEN) Right. Right. 1 1
A. So was I involved in-- yes, I was.
Q. The question would be was the UEP Trust
involved in decisions with regards to marriages --
MR. MORTENSEN: Objection to the forrn.
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Asked 15
and answered. 1 6
Q. (BY MR. HANSEN) --performed in the FLDS 1 7
community. 18
A. The Trust wasn't. I mean I was as an 1 9
officer. 20
Q. YousaytheTrustwas not? 21
A. No. 22
Q. What do you mean? 23
A. The Tn1st is a land holding trust. My office 2 4
as a bishop was involved-- I was involved in making 2 5
Ji ll C. Dunford RPR, CSR
those deeisions on a bishop' s level.
Q. So as a bishop, you were involved in
marriages; is that right?
A. Yes, I was.
Page 16
Q. As bishop, have you participated or perfonned
a number of wedding ceremonies?
A. Yes, I have.
Q. In addition to the ones you performed, have
you attended ceremonies perfonned by others in the FLDS
community?
A. Yes,Ihave.
Q. In any of those ceremonies has there been any
reference to the UEP Trust that you can remember?
A. Not that I can remember, no.
Q. Do you as you look back over the years that
you were involved as a bishop and during the time that
you were a UEP Trustee, do you recaJI the UEP Trust ever
being involved in a marriage in the community?
MR. MORTENSEN: Obj eet to the form.
THE WITNESS: No. Repeal that so that-- is
the Tntst itself involved in the marriage?
Q. (BY MR. HANSEN) Yes.
A. No, the Trust wasn't.
Q. When you had Trustee meetings, would the
Board of Trustees discuss whether certain maniages
Page 17
should be performed or not perfonned?
A. No, they did not.
Q. Would those have been diseussions that would
be held by individuals in their FLDS Church
responsibilities?
II
MR. MORTENSEN: Object to the form. Calls
for a legal conclusion.
Q. (BY MR. HANSEN) I mean if there were
discussions about who was to be married and who was
getting man·i ed.
A. They were always discussed --
MR. MORTENSEN: Same objection.
THE WITNESS: --pri vately.
Q. (BY MR. HANSEN) Let me ask you about a
couple of documents that are titled "Declaration of
Winston Blackmore." I think we are going to have those
marked as exhibits now. I'll show you a copy.
(Exhibit Nos. I and 2 were
marked for identification.)
MR. HANSEN: I have a copy for everyone.
MR. MORTENSEN: Thanks.
Q. (BY MR. HANSEN) I show you what bas been
marked as Exhibit No. I and Exhibit No. 2. There's No. I
and No.2. These are copies of Exhibit No. 2.
MR. MORTENSEN: Thanks.
5 (Pages 14 to 17)
REPORTERS , INC. (801) 746-5080
I
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DEPOSITION OF: M.J ., aka ELISSA WALL v. WARREN JEFFS
Winston K. Blackmore
Page 18
1 Q. (BY MR. HANSEN) Let me ask you, 1
2 Mr. Blackmore, I have handed you these two documents. 2
3 And for distinguishing purposes, the Exhibit I up at the 3
4 top identifies-- well, they both say "Declaration of 4
5 Winston Kaye Blackmore"; is that eorreet? 5
6 A. That's con·ect. 6
7 Q. One is "Winston Kaye Blackmore" and the other 7
8 one is "Winston Blackmore"; correct? 8
9 A. That's what I see on there. 9
10 Q. Maybe that's one way we ean distinguish them. 10
11 Let me ask you, have you had a chance to 11
1 2 review-- have you seen these documents before? 12
13 A. Yes, I have. 13
1 4 Q. And have you reviewed them recently? 14
15 A. Yes, lhave. 15
16 Q. And your signature is contained on page 5 of 16
17 Exhibit No. I? 17
1 8 A. Yes. 18
1 9 Q. And it's also on the last page of Exhibit 19
2 0 No. 2; is that correct? 2 0
21 A. That' s correct. 21
22 Q. Do you remember being involved with these 22
2 3 documents? 2 3
24 A. Yes, I do. 24
2 5 Q. Let me ask you about the first document. 25
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Exhibit 1 indicates that it was signed on September 5th, 1
2007. 2
Can you tell us about the circumstances of having 3
your signature on that document? 4
A. Yes, I ean. 5
Q. Please tell us about it. 6
A. I got a call from Roger Hoole and -- 7
Q. And who is Roger Hoole? 8
A. I don't know who he was actually representing 9
before M.J. He never did tell me who M.J. was. But I 10
had met with Roger before a time or two and was quite 11
familiar with Roger. And he asked me if he could-- I 12
think they were in the country anyway, Greg and -- Roger 13
and his brother, Greg, and they wanted to drop by. They 14
did. 15
Q. Can we stop for a second?
A. Sure.
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MR. HANSEN: Have you got yours recording? 18
Can we go off the record for just a minute? 1 9
(Short pause.) 2 0
MR. HANSEN: Let's go back on the record and 21
I' ll just explain that. 22
We are back on the reeord and I'd like to just 23
explain that I jus t took a break from the record a minute 2 4
ago because I noticed that my video recording appears 2 5
Jill C. Dunford RPR, CSR
Page 20
that something had happened. It was not working up to
this point. But counsel for M.J. is likewise videotaping
this.
So Counsel , do we have an agreement that we can
MR. MORTENSEN: We'll share each other's
videos.
MR. HANSEN: --share eaeh other's videos?
Okay. Very good. Sorry for that interruption.
Q. (BY MR. HANSEN) Let us continue. You were
just going to explain to us about the circumstances
surrounding this declaration of Winston Kaye Blackmore
which is in front of you as Exhibit No. 1.
Mr. Blackmore, could you please explain further
what happened in that situation?
A. Yes, Roger called me and he asked if he and
Greg could drop in and have a conversation. And when we
did, we met in my office at my home. And some of my
family, he met-- we met with some of them.
They came a little bit late in the evening when
we were gathering for our evening prayers and whatnot, so
they came back in the morning.
But in the meantime, Roger told me, he said, "My
work with this case is done." That's just what he said.
Q. Meaning his work, not Winston's work?
Page 21
A. His work, his work is pretty much done. He
had done whatever he had done and he would like to set up
a fund of some sort for people who were trying to leave.
Because in our community, no one had any mechanism to
leave. There's people who wanted to leave and had no way
to go.
So I -- myself, I made an agreement of some sort
of mechanism that-- and he explained. His explanation 11
was that it could be a fund that was set up that would be
handled by the UEP, that a suceessful applieant could II
make an applieation to the Trustees of the UEP for some
means to go. And they would be -- if they were
suceessful, they could get this grant or whatever it was 11
that they could get.
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He had an affidavit prepared -- I mean a
statement prepared, which he read to me. And r told him
two or three times some of the stuff does not sound like II
me.
And so we went over it and the next morning he
eame baek with a draft of it. And he was -- he was in a
hurry to go. They were-- they bad missed their fl ight,
and they truly were.
Q. The flight from Canada to--
A. The flight out of Spokane. They were right
down to the time to do it.
6 (Pages 18 to 21 )
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REPORTERS, INC. (801) 746-5080
DEPOSITION OF: M.J., aka ELISSA WALL v. WARREN JEFFS
Wins t on K. Blackmore
Page 2 2
1 And so Roger asked me, "Could you just sign the 1
2 back of this? And you can phone me over the phone, go 2
3 over this." 3
4 I said, "I need to go over this with some of my 4
5 family and a couple:: of the brethren." Because I wanted 5
6 to go over it with Brother Johnson who was then our 6
7 bishop in the south and some of my family members to look 7
8 at it to see, you know, what stuek out towards them. 8
9 I also explained very plainly to Roger that 9
10 under-- the definition of underaged marriages is -- is 1 0
11 not-- I mean there' s under the age of what? Under the 11
12 age of majority or under the age of consent? 1 2
1 3 So -- and to me, when I showed this thing to my 1 3
1 4 family, their-- the whole context of it is mi sleading in 1 4
15 a way that we're not --we have not defined under the age 15
1 6 of eonsent or under the age of majority. Aud that 16
17 basically taints the whole statement. 1 7
1 8 And so -- also when I showed it to 8 is hop 18
1 9 Johnson, he basically pointed out to me that no one 19
20 ever-- I mean the United Effort Plan Trust was a trust 20
21 that we got a lot. That's what we did. That the Trust 21
2 2 did not build houses for people nor had any obligations. 2 2
2 3 We bad --we were assigned a lot and the responsibility 2 3
24 on building a home and managing that lot depended on the 2 4
2 5 individual who had the lot. 2 5
Page 23
1 And that was bas ically his input into there, plus 1
2 the fact that I managed the United Effort Plan property 2
3 in Canada. The president of the Trust and the president 3
4 of the Church didn't manage it. I did. 4
5 Q. As the bishop, you were managing it? 5
6 A. As the bishop of the property. So to be-- 6
7 basieally to have any kind of couneetion made there would 7
8 be totally false. 8
9 Q. So at the time that you signed the last page 9
10 of this declaration, Roger Hoole bad expressed to you 1 0
11 that you would have-- you made it elear that you had to 11
12 review the document? 1 2
13 A. Yes,Idid. 13
14 Q. And think about it, that it wasn't to be used 14
15 until it was detennined if there were changes that needed 15
1 6 to be made? 1 6
1 7 A. Roger told -- 1 7
18 MR. MORTENSEN: Objeetion. Leading. 18
19 THE WITNESS: Roger told me that if! did not 1 9
2 0 like that, he wouldn't even use it. And I called him 20
21 right away and I didn't get through to him. I left a 21
2 2 message twice. 2 2
2 3 Q. (BY MR. HANSEN) Why did you call him? 2 3
2 4 A. I ealled him to tell him that thi s was not 2 4
2 5 accurate. And I didn't hear anything back from him, and 2 5
Ji l l C. Dunford RPR, CSR
Page 24
so 1 thot1ght that he hadn't filed it.
Q. So when you reviewed this document the next
day and considered it, it was your opinion that this was
not accurate, it was not a coneet statement of your
knowledge or experienee; is that right?
MR. MORTENSEN: Objection. Leading.
THE WITNESS: That's right. And l told him
that on a voice message and I told him later in person.
Q. (BY MR. HANSEN) When did you find out that
Roger had used this declaration?
MR. MORTENSEN: Object to the fonn.
Q. (BY MR. HANSEN) At the time that you signed
it-- you understood that Roger wasn't going to do
anything with it until you and he had confirmed that it
was appropriate to use; is that right?
A. Yes, and when we confirmed --
MR. MORTENSEN: Objeet to the form.
THE WITNESS: -- it was appropriate to use,
when Roger confirmed it was appropriate to use, then I
was going to take and have it nota1ized before a notary
and theu send him the eopy of the notarized doeument.
And when I found out-- or months went by, maybe
six, maybe six months went by and I never heard another
thing from him until --
Q. (BY MR. HANSEN) Who advised you of that?
Page 25
A. Mr. Wisan phoned me and he was not happy. He
said -- he asked me, "What on earth did you do?" And I
was surprised to know -- he sent me a copy of this.
Q. Why were you surprised?
A. I was surprised because I wasn't aware that
it was used.
Q. Did that concern you that the affidavit had
been used when you had not approved it?
MR. MORTENSEN: Object to the form. It's a
declaration.
Q. (BY MR. HANSEN) Declaration.
A. What concerned me was that the purpose that
it was used was for something totally differeut than what
Roger had approached me about. He approached me abou
using this declaration to set up a fund to help people
that wanted to leave this community go, not to-- not to
do any other reason.
Q. And the second deelaration, the declaration
of Winston Blackmore, wbich has been marked as Exhibit
No. 2, that's a document you are familiar with as well?
A. Yes, I am.
Q. And do you recall the eireumstances around
the creation of that declaration?
A. Yes, I do. It was on -- it was after
Mr. Wisan called me and infom1ed me of the filing of this
7 (Pages 22 to 25)
REPORTERS, INC. (80 1 ) 746- 5080
DEPOSITI ON OF: M.J., a ka ELISSA WALL v. WARREN J EFFS
Winston K. Blackmore
Page 26
1 first one that --I told him that is not the intent. 1
2 That was not what our-- my understanding was. That was 2
3 not what Roger agreed with me to do. 3
4 He bad agreed that if there was anything in here 4
5 that I did not like, that that would be omitted from 5
6 there. I did not take it to a notary and have it swom 6
7 to, whieh was what the next step of our program was going 7
8 to be. And l had no opportunity to do that. And it 8
9 shocked me to discover that it was in something totally 9
10 different than our conversation. 10
11 Q. So it's fair to say you spoke with Mr. Wisan 11
12 about that first declaration, you continued to feel that 12
1 3 it was not a fair and accurate statement of your 13
14 testimony; is that correct? 14
15 MR. MORTEN SEN: Object to the form. 15
16 THE WITNESS: That is correct. 16
17 Q. (BY MR. HANSEN) So was the second 17
18 declaration, the declaration of Winston Blackmore 18
19 prepared to try to correct the record with regards to 1 9
2 0 your first declaration? 2 0
21 A. Yes, it was. 21
2 2 Q. And you have had a chance to review this 2 2
2 3 declaration; is that correct? 2 3
24 A. Ycs,Ihavc. 24
2 5 Q. Is this declaration a true and accurate 2 5
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statement of your knowledge and experience regarding the 1
issues contained therein? 2
A. It is regarding those issues. 3
Q. Okay. Do you mind reading the second 4
paragraph of that Exhibit No. 2, which is your 5
declaration? It's dated July 18, 2008. Could you read 6
for us Exhibit 2? 7
A. Sentence two? 8
Q. Excuse me, sentence No.2. 9
A. In Exhibit 2? 10
Q. Right. 11
A. "ln February of 1986, I became a Tn1stee of 12
the UEP Tmst (the 'Trust' or the 'UEP'), and served in 13
that capacity until mid-2002. I also served from August 1 4
of I 984 until May of 2002, as the FLDS Bishop of Canada. 15
Even today, I continue to perfonn the duties of a bishop 16
for hundreds of fundamentalist Mormons (I am no longer 17
affiliated with the FLDS Church, having been 18
disfellowshipped by Warren Jeffs after the death of his 19
father, Rulon Jeffs)." 20
Q. And that's a statement contained in sentence 21
No.2 that you have just read; is that an accurate 22
statement? 2 3
A. Yes, it is. 2 4
Q. And still true today? 25
J i ll C. Dunford RPR, CSR
Page 28
A. Still true.
Q. Some of these other things you have talked
about. I'll move fotward.
Do you mind reading paragraph No. 10? Yeah, it
is paragraph marked No. l 0 of that declaration.
A. The same one?
Q. Yes.
A. "I emphatically declare that any underage
marriages that occurred amongst FLDS people were not on
account of any doctrine of the FLDS Church or Mannon
Fundamentalism. Underage marriage is not and never has
been fundamental to our faith, nor has the doctJine or
practice of underage matTiage ever been taught to our
people. By stating in my earlier declaration that
underage marriage is a 'practice' among the FLDS people,
I did not mean to imply that underage matTiage was
common, regular, everyday, or ordinary amongst the F L   ~
people. Historically, it did happen, but was a rare
anomaly."
Q. What was written in that sentence No. 10, is
that a true statement?
A. It is a true s tatement.
Q. Let me ask-- let me ask about the firSt
sentence there where it says, "I emphatically declare
that any underaged marriages that occun·ed amongst the
Page 29
FLDS people were not on account of any doctrine of Llle
FLDS Church or Mormon Fundamentalism."
Let me ask you, are you aware of any doctrine --
that underage marriage as being a doctrine of the FLDS
Church?
MR. MORTENSEN: Object to the fonn.
THE WITNESS: Jam not aware of any. There's
no doctrine.
Q. (BY MR. HANSEN) And you have been involved
in this religi on and Mannon Fundamentalism for your whole
life; correct?
A. Yes. My mom was 16 when she married my dad
who was 27 in the Cardston Temple.
Q. And as far as it being a doctrine of the
Chmch --
A. No.
Q. - -underage marriage, it's never been a
doctrine?
A. No, il has not been a doctrine.
Q. I guess you state that again in paragraph
No. 11 . Would you mind reading paragraph No. l I?
A. "l completely disavow any statement in my
September 5, 2007 declaration which could be read to
support the proposition that underage marriage has ever
been a doctrine or practice of the FLDS Church, or within
II
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8 (Pages 26 to 29)
REPORTERS, I NC. (801) 746-5080
DEPOSITION OF: M.J., aka ELISSA WALL v. WARREN JEFFS
Wi nston K. Blackmore
Page 30
1 the scope of a UEP Trustee's duties." 1
2 Q. Was that a true statement? 2
3 A. Yes, it is. 3
4 Q. Okay. And underage marriages were never 4
5 something within the duties of a UEP Trustee, were they? 5
6 MR. MORTENSEN: Object to form. 6
7 Q. (BY MR. HANSEN) I guess that's what you say 7
8 in paragraph l I. 8
9 MR. MORTENSEN: Same objection. 9
10 Q. (BY MR. HANSEN) Am I reading that right? 10
11 A. Underage -- not a Trustee. 11
12 Q. You also make mention --I'll have you tum 12
13 to paragraph 17 of your affidavit. Would you mind 13
14 reading that paragraph? 14
15 A. "Prior to the second session of the FLDS 15
16 general conference of April 1998, our leader and 16
1 7 keyholder, President Rulon Jeffs, announced to a small 17
18 group of priesthood brethren, that included me, Sam 18
19 Barlow, LeRoy Jeffs, and Wendell Nielsen, that the State 19
2 0 of Utah had enacted a new law regarding underage 2 0
21 marriage, and that the Church fully intended to comply 21
2 2 with that law. President Jeffs publicly declared the 2 2
2 3 Church's intent to comply with that law to the 2 3
2 4 congregation in a later session of that same conference, 2 4
25 which I attended." 2 5
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Q. Paragraph 17 of your deelaration, is that a 1
true and accurate statement? 2
A. Yes, it is. 3
Q. Do you have recollection of being in this 4
meeting that you talk about here? 5
A. Yes,Iwas. 6
Q. Tell us what you remember. 7
A. The circumstances that we spoke of prior to 8
that had to do with the State of Utah raising the age of 9
consent, the age which parents could consent to have 10
their children be manied. 1 1
And I think it was rai sed -- if I remember right, 12
it was raised from the age of 14 to the age of 16. And 13
his declaration was that, "We are not going to 14
pa11icipate in any maniages that are not according to 15
the law of consent, parental consent." 1 6
Q. And that was in February of 1998 when-- 17
A. No. 1 8
Q. -- when that meeting -- excuse me, it was 1 9
April conference? 20
A. Apiilofl998. 21
Q. Where would that meeting-- was that down in 22
the-- 2 3
A. That was his residence in Short Creek in 2 4
Colorado City -- or Hildale. 2 5
= · · · = · · · ~ = ~ · =   = = = =   =   =   = ..
Jill C. Dunford RPR, CSR
Page 32
MR. MORTENSEN: Whose residence?
THE WITNESS: In Rulon Jeffs' residence.
Q. (BY MR. HANSEN) And at that time what was
Rulon Jeffs' position in the Church?
A. He was the President of the Church.
Q. And he made that statement to a small group
of you who were priesthood holders in that meeting you
are referencing in paragraph-- at the beginning of
paragraph 17; is that right?
A. Yes.
Q. You mentioned -- in the last sentence you
say, "President Jeffs publicly declared the Church's
intent to comply with that law to the congregation in a
later session of that same conference, which I attended."
A. I attended all of the sessions.
Q. Okay. So you are saying there were two
different occasions where you heard Rulon Jeffs--
A. Yes, I did.
Q. --make that declaration that the FLDS Church
would be complying with the laws of the State of Utah
with regards to marriages complying with the laws of the
State of Utah; is that correct?
MR. MORTENSEN: Object to the form.
Misstates his testimony.
Q. (BY MR. HANSEN) As far as the age of
Page 33
consent?
A. The age of consent.
Q. l11at same year, Rulon Jeffs had some health
issues; is that correct, in '98?
A. Yes, he did. He had a stroke in August of
'98.
Q. And you are up in Canada. The Church is
headquartered -- the FLDS Church was headquartered down
in Hildale?
A. Yes.
Q. From your interaction, did you observe any
changes in the leadership of the FLDS Church as a result
of Rulon Jeffs' stroke and his illnesses?
A. Well, from the time that he had his stroke
and was unable to do anything really, the
responsibility -- the bishops pretty much had to do their
jobs the best that they could without any contact with
him.
And when we were able to contact with him, he
definitely was not in any sort of position health-wise to
discuss things with him.
His son, Warrell, who was caretaker of his father
through that time began to help his father remember
different things. And he announced several times, "I'm
my father's memory." I didn't agree with that, but
9 (Pages 30 to 33)
REPORTERS, INC. ( 801) 7 4 6-5080
DEPOSI TION OF : M.J., aka ELISSA WALL v. WARREN JEFFS
Winston K. Blackmore
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Page 34
that's what happened. 1
Q. Were you involved in any way in spring of 2
2001 with the maniage of Elissa Wall and Allen Steed? 3
A. No, I wasn't. 4
Q. Did Warren Jeffs or Rulon Jeffs ever talk to 5
you about that man·iage taking place? 6
A. No. 7
Q. Was the marriage of Elissa Wall and Allen 8
Steed, before it happened, was it ever addressed in any 9
meeting of the UEP Trustees? 10
A. No, it wasn't. 11
Q. After the marriage took plaee -- the wedding 12
took place and Allen Steed and Elissa Wall were still in 13
the arranged marriage, did you ever have any diseussion 14
with Wan·en Jeffs or Rulon Jeffs or anyone else in the 15
FLDS Church about Elissa Wall and her marriage to Allen 16
Steed? 1 7
A. No, I didn't. I didn't know anything about 18
Page 36
Church was coucerned.
MR. HANSEN: ] think that' s all the questions
I have. Thank you for your time, Mr. Blackmore.
THE WITNESS: Okay.
EXAMINATION
(BY MR. MORTEN SEN)
Q. Mr. Blackmore, I have a few questions I'd
like to ask.
Just for the record, I'm Alan Mortensen with
Lance Milne. We represent Elissa Wall in this matter.
You have referred to the UEP Trust as a land
holding trust only; is that eorrect?
A. TI1at's all I ever knew it to be.
Q. Okay. Let me hand you a copy that of the
Trust.
MR. HANSEN: Do you want it marked?
MR. MORTENSEN: Yeah, let' s mark it as
Exhibit 3.
19 it. 1 9 (Exhibit No.3 was marked for identification.)
20 Q. Were you aware of Elissa WaH's complaints or 20 MR. HANSEN: Do you have a copy for me?
2 1 fntstrations or disagreement with the marriage? 21 MR. MORTENSEN: I do. Oh, is that--
22 A. At what time? 22 Q. (BY MR. MORTENSEN) Mr. Blackmore, have you
2 3 Q. At the time that it was going on. 2 3 seen--
24 A. No. 2 4 MR. HANSEN: We can give him the marked copy
25 Q. As a Trustee of the UEP Trust, did you ever 2 5 and I'll take that one.
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Page 35
take any action to force Elissa Wall to be in an illegal 1
matTiage with Allen Steed? 2
A. No, l didn' t. 3
Q. Do you have knowledge with regards to the 4
actions of other Trustees of the UEP Trust acting in 5
their capacity as Trustees o f the UEP Trust to compel 6
this marriage of Elissa Wall and Allen Steed? 7
MR. MORTENSEN: Object to the fonn. 8
THE WITNESS: No, J don't. 9
Q. (BY MR. HANSEN) Was there a difference in 10
the administration of the UEP Trust and the 11
administration of the FLDS Church matters? 1 2
A. Oh .. yes. 13
Q. Why do you say-- can you explain to me when 14
you say, "Oh, yes"? 15
A. Well, the UEP Trust is a land holding trust. 16
And the matters that we took care of for them were to 1 7
preserve its integrity, preserve the case, the court case 18
that we were fighting, and to deal with lots and taxes. 1 9
And, you know, the president in most cases, he 20
didn't even want to hear about it. He wanted --he told 2 1
me two or three times in my whole tenure that I tried to 22
talk to him about UEP in Canada, "Just go do, do what you 23
need to do and don' t bother me about that. " And, you 2 4
know, he certainly didn't act that way as far as the 2 5
J i ll C. Dunford RPR, CSR
Page 37
Q. (BY MR. MORTENSEN) Mr. Blackmore, have you
seen this document before?
not?
A. Yes, I have.
Q. And your signature is on this document, is it
A. Yes, it is.
Q. On page --
A. Fi ve.
Q. -- 5. And do you recall signing this?
A. Yes, I do.
Q. You have testified that you were a bishop--
you have been a bishop for almost 30 years; COITect?
A. Yes, correct, 30.
Q. A bishop is a priesthood office within the
priesthood fundamentalists in the FLDS Church; con·ect?
A. Yes, it is.
Q. As part of that priesthood office, you
administered the UEP Trust in Canada?
A. Yes, J did.
Q. And if! understand your testimony correctly, II
Rulon Jeffs, the prophet -- he was also the prophet, was II
be not?
A. Yes, he was.
Q. And as prophet, he would be the person that
could receive revelation on who marries who; correct?
10 (Pages 34 to 37)
REPORTERS, I NC. (801) 746-5080
DEPOSITION OF: M.J . , aka ELISSA WALL v. WARREN JEFFS
Winston K. Blackmore
Page 38
1 A. Con ect. 1
2 Q. And he's the only person that was authorized 2
3 to instn•ct people on who to marry; is that conect? 3
4 A. That's not correct. 4
5 Q. Who else within the FLDS priesthood structure 5
6 could instruct people to marry? 6
7 MR. HANSEN: I'll obj ect that it is vague as 7
8 to time. 8
9 Q. (BY MR. MORTENSEN) Let's go baek to 1998 to 9
10 the time period that Rulon Jeffs died. Who was 10
11 authorized to instruct people to get ma•Tied? 11
12 A. I was. 12
13 Q. As a bishop? 13
14 A. As a bishop. 14
15 Q. Soyoueould-- 1 5
16 A. I could consult with the parents and the 16
1 7 people. 1 7
18 Q. Okay. So you were authorized as a bishop, 18
1 9 which is a priesthood office -- 19
20 A. That's right. 20
21 Q. -- to have people enter into polygamist 21
2 2 maniages? 2 2
23 A. Yes, I was. 23
2 4 Q. As a bishop, during that pre-200 1 time 2 4
2 5 period, did you ever -- well, you instructed people that 2 5
Page 39
1 were under the age of 18 to marry; correct? 1
2 A. I never instruct-- I visited with people who 2
3 were under the age of 18 and I also visited wi th them 3
4 with their parents. 4
5 Q. So you instructed people under the age of !8 5
6 to get married? 6
7 A. Well, 1 gave them permission if that's what 7
8 they chose to do, what it came to. 8
9 Q. And you would defer to their parents to give 9
10 parental consent? 1 0
11 A. Yes. 11
12 Q. And you had the right as the bishop if that 12
13 fami ly was living on FLDS or UEP Trust property to eviet 1 3
14 them if they didn't follow your instruetions, did you 1 4
15 not? 1 5
16 MR. HANSEN: Objection. Vague. Overly 16
17 broad. 17
18 THE WITNESS: I never evicted anyone, so .. 18
19 Q. (BY MR. MORTENSEN) That wasn't my question. 1 9
20 My question was you had the authority to have people move 20
21 off of the UEP Trust property if-- 21
22 MR. HANSEN: Objection. Laek of foundation. 22
23 Calls for speculation. Misstates the facts. 23
24 Q. (BY MR. MORTENSEN) --if you felt that they 24
25 were not following your instruetions? 25
· ·- - --
Jill C. Dunford RPR, CSR
Page 40
A. You know, that never did ever come up for me
that I can recall.
Q. You have never kicked anyone off of UEP
property up in Canada?
A. No, I haven't.
Q. Has-- did you ever-- were you ever
instructed by Rulon Jeffs to have people leave UEP
property up in Canada?
A. Not to my recollection.
Q. All right. Let's tum to Exhibit 1 --or
Exhibit 3. When you signed this document, you agreed '
with it, did you not?
A. Actually we didn't even read the document
until it was read to us the next day. We met for a
signing session and that's what we met for.
Q. So you signed this without reading it?
A. Yes, I did.
Q. But you have since read it; correct?
A. Oh, yes, I have read it.
Q. And you don't disagree with anything in it,
do you?
A. The only thing that I disagree with is I know
that Rulon Jeffs would have never signed it.
Q. So you don't think Rulon Jeffs' signature is
his?
Page 41
A. lt is his. I saw him sign it. But he-- he
had a stroke. Warren introduced him as his father being
reduced to the capacity of a child in our meeting. We
signed, we did our signature, and it went.
Q. You at no time went to Warren Jeffs and Rulon
Jeffs and said, "Take my name off that document"?
A. No, 1 didn't.
Q. You were an adult and had that capacity to do
such if you disagreed with it once you read it the next
day; correct?
A. Yeah.
Q. But you never did that?
A. I did not, no.
Q. Okay. In the second paragraph it says, "The
United Effort Plan Trust is a s piritual step toward
living the Holy United Order."
The Holy United Order is a doctrine of the FLDS
Church, is it not?
A. It's a doctrine of the LDS Church and in the
Doctrine and Covenants.
Q. That wasn't my question, sir.
A. Yes, as a mainstream-- I mean as a
fundamental M01mon, yes, it is a part of their faith.
Q. And at the time it was part of the FLDS
doctrine; correct?
11 (Pa ges 38 to 41)
REPORTERS, I NC . (801) 746-5080
DEPOSITION OF: M.J., aka ELISSA WALL v . WARREN JEFFS
Wins ton K. Blackmore
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Page 42
A. CotTect. 1
Q. It says, ''It ex ists-- on the next sentence 2
-- "lt exists to preserve and advance the religious 3
doctrines and goals of the fundamentalist Church of Jesus 4
Christ of Latter-Day Saints, previously known as 'The 5
Priesthood Work,' or 'The Work' (the 'Church')." 6
You agree with that sentence, don't you? 7
A. Yes, I do. 8
Q. So the United Effort Plan exists to preserve 9
and advance the religious doctrines and goals of the 1 0
Fundamentalist Church of Jesus Christ of Latter-day 11
Saints? 12
MR. HANSEN: I'll object that the document 13
speaks for itself. 14
MR. MORTENSEN: Mr. Blackmore can speak. 15
Q. (BY MR. MORTENSEN) So I'd like you to speak. 16
A. Just get it over to where we are again. 17
Q. The second paragraph, second sentence. 18
MR. HANSEN: On page 1. 19
THE WITNESS: I'm on a different one. 20
Q. (BY MR. MORTENSEN) Where it says the UEP 21
Trust exists to preserve and advance the religious 2 2
doctrines and goals of the Fundamentalist Church of Jesus 2 3
Christ of Latter-Day Saints, previously known as "The 2 4
Priesthood Work," or ''The Work" (the "Chureh"). 2 5
Page 43
You agree with that, don't you?
MR. HANSEN: You agree that that's what the
document says?
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Q. (BY MR. MORTENSEN) No, you agree with that
1
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5 statement.
MR. HANSEN: Then I'm going to object. Vague 6
and ambiguous as to time. You are saying back in 1998?
Q. (BY MR. MORTENSEN) At the time you signed
it, you agreed with that; eorrect?
A. We didn't even go through it, but I signed
the document.
Q. And you agree with that statement, don't you?
A. I don't entirely agree with it.
Q. What part don't you agree with?
A. The FLDS Church didn't even exist when the
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United Effort Plan Trust was organized. 16
Q. Okay. So if it read it exists to preserve 17
and advance the religious doctrines and goals known as 18
the Priesthood Work, you would agree with that? 1 9
MR. HANSEN: Objection. I think that 20
mischaracterizes his testimony, misstates his testimony. 21
THE WlTNESS: I wouldn't entirely agree with 22
that, no. 23
Q. (BY MR. MORTENSEN) What part don't you agree 211
that on? 25
Ji ll C. Dunford RPR, CSR
Page 44
A I don't agree -- with being a Trustee
appointed under the original declaration of the Trust,
that's what I was appointed under. The original
declaration of trust, there was no reference at all to
the Church.
I'm a person who believes that we should have
never changed the Tmst. And we never would have had
President Jeffs not been incapacitated.
Q. Did you ever tell that-- make that known to
President Jeffs?
A. We couldn't--
MR. HANSEN: Which President Jeffs?
MR. MORTENSEN: The one he refetTed to.
THE WITNESS: President Jeffs, in 1998 when
we signed this thing, was not in any capacity to make
that known. But I know for a fact that Tmman Barlow
would not have signed it. Craig Jessop would not have
signed it. I would not have signed it. LeRoy Jeffs
would not have signed it had we, you know, had his
father, had Rulon Jeffs, being of his capacity, he would
not have signed it. He would not have changed the
declaration as it stands today. And I made it no secret II
among a lot of people that I did not like the fact that II
we had to sign this thing.
Q. (BY MR. MORTENSEN) But you signed it?
Page 45
A. But I signed it, yes.
Q. And you made no -- you didn't stand up in
general conference or priesthood session of general
conference and object to it, did you?
A. No, I had no --
MR. HANSEN: I'm going to object.
Argumentative. Asked and answered.
MR. MORTENSEN: I haven't asked him about
general conference.
THE WITNESS: No one had that opportunity.
Q. (BY MR. MORTENSEN) They don' t give you the
oppornmity, do they?
A. No.
Q. Then it says, "The United Effort Plan is
under the direction of the President of the Church, who
holds the keys of Priesthood authority .. . continued from
Joseph Smith to Brigham Young, John Taylor, John Woolley,
Lorin C. Woolley, John Barlow, Leroy Johnson, and Rulon
Jeffs. "
You agree with that, don't you?
A. I think they missed some people, but t hat's
my opinion.
Q. Okay. So the United Effort Plan was under
the President of the Church who holds the keys of the
Priesthood authority?
12 (Pages 42 to 45)
II
REPORTERS , INC. ( 801) 7 4 6-5080
DEPOSITION OF: M. J ., aka ELI SSA WALL v. WARREN JEFFS
Wi nston K. Blackmore
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Page 46
MR. HANSEN: Asked and answered.
Q. (BY MR. MORTENSEN) Do you agree with that?
A. l agree.
Q. All1ight. And then it goes on to state that
the laws -- "The doctrines and laws of the Priesthood and
the Church are found in the Book of Mormon, the Doctrine
and Covenants, the Pearl of Great Price, the Holy Bible,
the sennons of the holders of the keys of Priesthood
authority, and present and future revelations received
through the holder of those keys; and are the guiding
tenets by which the Trustees of the United Effort Plan
Trust shall act."
You agreed with that when you signed it, did you
not?
MR. HANSEN: Objection. Asked and answered.
It misstates his prior testimony.
Q. (BY MR. MORTENSEN) Go ahead and answer.
A. 1 don't agree with it entirely.
Q. So you signed it without agreeing to it?
A. I think five people signed it without
agreeing to it.
Q. I want to know if you signed it without
agreeing to it?
A. I didn't know what was in it to agree to it
when I signed it and then I certainly didn't agree with
Page
it after.
Q. Who presented it to you to s ign?
A. It was just a signing session. We were all
present.
Q. Okay.
A. We went to the home of President Jeffs.
Q. Rulon Jeffs?
A. Rulon Jeffs. President Jeffs, there's only
one to me.
47
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A. So that's Rulon Jeffs. And we went to there, 1 1
we signed and notarized, and went from there. 1 2
Q. On the last paragraph of the first page it 13
says, "Rulon T. Jeffs hold the keys of Priesthood 14
authority and so serves as the President of the Church." 15
You agree with that statement, don't you? 16
A. Yes, I do. 17
Q. Then continuing on to the next page, 18
continuing that paragraph, it s tates, "This Amended" -- 19
second to the last paragraph-- or sentence in the 20
carry-over paragraph, it says, "This Amended and Restated 21
Declaration of Trust has also been approved by the 2 2
Priesthood and sustained by the Church membership." 2 3
Do you recall that at that conference that this 2 4
trust was approved by-- 2 5
Jill C. Dunford RPR, CSR
Page 48
A. Sorry, could you show me where that was
again?
Q. The second page, first full sentence where it
says, "This Amended and Restated Declaration of Trost has
also been approved by the Priesthood and sustained by the
Church membership."
A. That was totally inaccurate when we signed
it. No one bad ever even heard of it.
Q. All I want to know is it was the Amended and
Restated Declaration of Trust, that it was approved and
voted on by the Priesthood at that conference?
MR. HANSEN: Objection. Asked and answered.
THE WITNESS: Pardon me?
MR. HANSEN: You have given your answer. I'm
just objecting to him reasking the same question that you
have answered.
THE WITNESS: The time-- I'm going to
restate my answer. The time we signed this, it was not
presented to the people nor was it accepted by the
people.
Q. (BY MR. MORTENSEN) Would you look al
Exhibit 2. Exhibit 2 is what you claim to be the
accurate dcelaration that you provided in this matter;
correct?
A. Correct. I thought you are referring to me
Page 49
some part of it.
Q. Look at paragraph 16. In the second sentence
you state, and you have testified under oath here today II
that it was true and accurate, "While it is true that the II
1998 Declaration of Trust was presented, read, and
approved at a meeting I attended, the meeting in question
was an FLDS priesthood meeting." Correct?
A. Correct.
Q. So the Declaration of Trust was presented to
the FLDS priesthood holders at the pri esthood meeting?
A. Yes, it was.
Q. And you had an opportllnity to vote on it?
A. Yes, we did .
Q. And you as a priesthood member had an
opportllnity to vote on it?
A. Yes, l did.
Q. And you didn't vote no, did you?
A. I raised my hand with everybody else.
Q. Even though you disagreed with it?
A. Yes.
Q. How many bishops were there at the time in
the FLDS Church in 1998 when this was presented? [[
A. There was myself and Bishop Fred Jessop and
LeRoy Jeffs was an acting bishop for Salt Lake and four
of us all were present.
13 (Pages 46 to 49)
REPORTERS, INC. (801) 746-5080
DEPOSITION OF:
Wi nston K. Bl ackmore
Page 50
1 Q. The re was four bishops, and you were one of
2 the four?
3 A. Yes, I was.
4 Q. And you didn't vote against this Decl aration
5 of Trust?
6 A. No.
7 Q. Back on Exhibit 3, page 2, the last
8 paragraph, the Trust document states, "The United Effort
9 Plan is the effort and striving on the part of Church
10 members toward the Holy United Order. This central
11 principle of the Church requires the gathering together
12 of faithful Church members on consecrated and sacred
13 lands to establish as one pure people the Kingdom of God
14 on Earth under the guidance of Priesthood leadershi p."
15 Do you see where that --
1 6 A. Yes.
17 Q. And you agree with that, don't you?
18 A. I don't believe that that's what the United
19 Order is personally.
20 Q. So you di sagree with that statement?
21 A. I di sagree with that statement.
2 2 Q. On page 3, second full paragraph on Exhibit
23 3, it states, "The privilege to participate in the United
2 4 Effort Plan and live upon the lands and in the buildings
25 of the United Effort Plan Trust is granted, and may be
Page 51
1 revoked, by the Board of Trustees."
2 Do you see that?
3 A. Yes, I see it.
4 Q. And the Board of Trustees were all Priesthood
5 authorities, were they not?
6 MR. HANSEN: Objeetion. Overly broad.
7 Vague.
8 Q. (BY MR. MORTENSEN) I'll go through it then.
9 One of the Trustees was Rulon Jeffs ; correct?
10 A. Yes.
11 Q. And he was the Prophet?
12 A. Right.
13 Q. And the President of the Church?
14 A. Right.
1 5 Q. And both of those are Priesthood -- are
16 Priesthood positions; correct?
17 A. Correet.
18 Q. All right. Wasn't it-- I believe you
19 testified in your deelaration that the President of the
20 Church was historically also the Trustee of the Trust, of
21 the UEP Trust?
22
A. Yes.
23 Q. So those two positions always ran
2 4 simultaneotJS with each other?
25 A. As far as I know, they did.
... -
--
J i ll C. Dunford RPR, CSR
M.J., aka ELISSA WALL v . WARREN JEFFS
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Page 52
Q. Again, on the second paragraph, "Those who
seek that privilege commit themselves and their families
to li ve their lives according to the principles of the
United Effort Plan and the Church, and they and their
families consent to be governed by the Priesthood
leadership and the Board of Trustees."
Do you agree with that statement?
A. On page 2 or 3?
Q. Page 3, second paragraph, full paragraph.
(Witness reviewed exhibit. )
MR. HANSEN: Reading in the middle of the
paragraph.
THE WITNESS: "Those who seek"--
(Witness reviewed exhibit.)
THE WITNESS: That's not always the case,
because in our 1987 lawsuit, which we ultimately lost
ptior to this, 44 fami li es were given the privi lege to
stay on their -- in their homes that were not a part of
this Pdesthood group on United Effort Plan Trust
property.
Q. (BY MR. MORTENSEN) That wasn't my question.
My question was you agree with this statement when you
signed it?
A. I don't agree with it, no, I don't agree with
it now.
Page 53
Q. Okay. Then on the third paragraph full
paragraph on page 3 of Exhibit 3, it states in the second
sentence, "Use of Trust property must be within rules and
standards set by the Board ofTmstecs."
What rules and standards were there?
A. In our country -- and really, I can only
speak for that -- we had to eomply with the local
government, local government zoni ng and standards for
water and sewer and taxes, land t axes.
Q. And were those the only rules and standards
that you set as the Board of Trustees for the people in
Canada?
A. They were the only ones we ever followed that
I know of.
Q. Are they written down?
A. No.
Q. Were they -- so they were never provided to
people that were on the Trust property?
A. Not to my recollection. I can't recall.
Q. It says, "The Board of Trustees may require
indi viduals and their families to relocate to different
locations on the United Effort Plan Trust property or to
share a location with others."
Is that your understanding as what the Board of
Tn1stees could do?
14 ( Pages 50 to 53)
REPORTERS , I NC . (801) 746-5080
DEPOSITION OF : M.J., a ka ELISSA WALL v. WARREN JEFFS
Winston K. Blackmore
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MR. HANSEN: I'll object. Vague, ambiguous, 1
unclear. 2
THE WITNESS: I'm trying to see whether or 3
not that was anything that ever applied to me or applied 4
to us there. Btlt from time to time, I did have-- if 5
there was -- if someone died and they were in a great big 6
house, we swapped houses to relocate people to the best 7
of their comfort and ability. B
Q. (BY MR. MORTENSEN) And you would do that as 9
the bishop? 1 0
A. I would do that as the bishop and consulting 11
with some of the other el ders there. 12
Q. And being an elder is also a priesthood 1 3
position; correct? 1 4
A. Yes, itis. 1 5
MR. HANSEN: Alan, when it's a comfortable 16
time-- 1 7
MR.MORTENSEN: Yeah,whydon'twetakea 1B
break. 19
MR. HANSEN: --I'd like to take a 2 0
five-minute break. 21
Let's go off the record and we'll take a five- or 2 2
ten-minute break. 2 3
(Short recess.) 24
MR. HANSEN: For the record, it's about 2 5
Page 55
1 10:40 a.m. on Feb1uary 28th. 1
2 MR. MORTENSEN: Ready to go back on? 2
3 Q. (BY MR. MORTENSEN) Mr. Blackmore, we took a 3
4 break. Did you meet with anybody during the break? 4
5 A. No. 5
6 Q. You didn't meet -- first of all, let me ask 6
7 you, is Mr. Hansen your attomey for the deposition here 7
B today? B
9 A. Yes, he is, I guess. I mean he called me to 9
10 the deposition. 1 0
11 MR. HANSEN: I mean I asked him to come and 11
12 appear in this deposition. There's no formal 12
13 representation. 13
14 THE WITNESS: No. 14
15 MR. HANSEN: Mr. Blackmore has come down as a 15
16 ci tizen of Canada that was asked to come and give 16
17 testimony. 17
1B THE WITNESS: Yeah. 18
19 Q. (BY MR. MORTENSEN) Let me just go througb a 1 9
20 couple of housekeeping items and make sure-- clear up a 20
21 couple of questions I have from direct examination. 21
22 You testified that you were baptized into the LOS 22
23 Church; correct? 23
24 A. Yes. 2 4
2 5 Q. But you were ex-communicated; correct? 2 5
J ill C. Dunford RPR, CSR
Page 56
A. I have never been ex-communicated from the
Church .
Q. Was your father?
A. My father was, I think.
Q. So as far as you know, you're s till a member
on the records of the LOS Church?
A. No, I don't think I was on the records. But
that' s what I was baptized and confirmed a member of is
the LOS Church.
Q. You don't know ifthe LDS Church has a
record, a membership record, for you?
A. I don't know what they do.
Q. During the time period that President Rulon
Jeffs was the president of the UEP T rus t, you testified
that you had annual meetings?
A. Pretty much. We got together at conference.
Q. Were there notes taken?
A. I didn't take any, so I don' t know.
Q. Were you ever provided notes?
A. No.
Q. Were you ever provided minutes?
A. No, I wasn't.
Q. As part of your meetings, were you ever asked
to approve minutes or approve these meetings?
A. I don't -- I can' t recall.
Page 57
Q. If you were provided minutes, would you have
kept copies of those minutes?
MR. HANSEN: Objection. Calls for
speculation. Lack of foundat ion.
so --
Q. (BY MR. MORTENSEN) You ean answer.
A. You know, I can't think of any that I have
Q. My question is --
MR. HANSEN: That's my objection. If he
doesn't have any --
MR. MORTENSEN: John, you can lodge your
objection, but I don't want you giving speaking
objections and --
MR. HANSEN: I'm just nying to clarify.
MR. MORTENSEN: -coaching \he witness.
MR. HANSEN: If you don't want to hear it,
I'll hold my tongue.
MR. MORTENSEN: Please.
Q. (BY MR. MORTENSEN) I f there had been minutes
provided to yo11, is that something that you think and
believe you would have kept?
A. If! had any meeting-- any minutes, I would
have sunendered them in 2002.
Q. Do you recall providing any in this case?
A. In?
15 (Pages 54 to 57)
REPORTERS, INC. (80 1) 74 6-5080
DEPOSITION OF: M.J., aka ELISSA WALL v. WARREN JEFFS
Winston K. Blackmore
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Page 58
Q. Do you recall providing any to the law firm 1
of Callister Nebeker & McCullough? 2
A. Any minutes? 3
Q. Any minutes. 4
A. I can' t remember. 5
Q. While President Rulon Jeffs was the President 6
of the UEP Trust, did you ever lodge any objection to 7
anything that he was doing as the President? 8
MR. HANSEN: Objection. Overly broad. 9
Vague. 10
THE WITNESS: To him, personally? 11
Q. (BY MR. MORTENSEN) Yes. 1 2
A. Not to him, personally. 13
Q. Did you lodge objections to other people? 14
A. I objected to Warren Jeffs. 15
Q. And who did you lodge that objection with? 16
A. Straight to Warren Jeffs. 1 7
Q. You told Warren Jeffs that you didn't-- you 18
didn't approve of what he was doing as tbe UEP Trust 19
Trustee? 20
A. I told him I didn't approve of what he was 21
doing as representing a memory ofhis father. 22
Q. Both-- and he was representing tbe memory of 23
his father both as the UEP President and as the President 24
of the Church; eorreet?
25
Page 59
MR. HANSEN: Objection. Laek offoundation. 1
Calls for speculation. Vague and ambiguous. 2
THE WITNESS: I don't think that he ever 3
objected to anything that I was doing in Canada, so my 4
objection to Warren was what he was doing with his 5
father. I ean't reeall anything other than that. 6
Q. (BY MR. MORTENSEN) His father at the time 7
was the UEP President, the President of the FLDS Chureh, 8
and the prophet? 9
A. Yes. 10
Q. And you told Mr. Jeffs that you didn't agree 11
with what was going on with him being the mouthpiece of 12
his father; eorrect? 13
A. I told Warren that, yes, correct. 14
Q. But you never told Rulon that? 15
A. You couldn't get to Rulon unless you went 16
through Wanen. 1 7
Q. And how did Warren respond to that? 18
A. He didn't like it. 19
Q. And when did you tell him that? 2 0
A. I told him that several times. We had 21
several different arguments and I told him that. 2 2
Q. Did you ever take any-- did you ever talk to 2 3
any of the other Trustees about your displeasure with 2 4
Wa1Ten Jeffs? 2 5
Jill C. Dunford RPR, CSR
A. A time or two I did.
Q. Who did you talk to?
A. Truman Barlow.
Page 60
Q. Did you ever take any legal action to try to
remove Mr. -- to remove Warren Jeffs as the Trustee of
the UEP Trust?
A. No, I didn't.
Q. Why not?
A. Because that would have been Church-assisted
suicide.
Q. Have you talked --you had mentioned in your
previous testimony that at some point in time you--
well, strike that.
At some point in time did you hecomc aware that
Elissa Wall was not happy in her arranged marriage with
Allen Steed?
MR. HANSEN: Objection as to time. Vague and
ambiguous as to time. Are you going to narrow the time
dowu?
Q. (BY MR. MORTENSEN) Yeah. when did you become
aware of that?
A. I only mel Elissa Wall last year.
Q. Okay.
A. And I-- I honestly can't recall at whatever
time. If l would have heard anything, it would not have
Page 61
been from her.
Q. Do you reeall hearing it from anybody else?
A. You know, I just don't know. There's times
you become aware of stuff, but what that timeline is, I
don't know.
Q. Let me ask you to tum baek to Exhibit I, if
you would.
A. Pardon me? What again?
Q. Exhibit I. It's the Declaration of Winston
Kaye Blackmore.
A. Okay.
Q. I want to understand your testimony.
Do you disagree with the substance of Exhibit 1
or do you disagree with the pretext in which it was
presented to you?
A. l disagree with both of those, not having the
opportunity to conect it.
Q. All right. Is there anything in paragraph 2
on page 2 of the Declaration of Winston Kaye Blackmore
that you disagree with?
(Witness reviewed exhibit.) '
A. My birthday. I
Q. Is that wrong?
A. Lister used to be Lister and now it's Creston
and we haven't moved anywhere.
16 (Pages 58 to 61)
REPORTERS, INC. (801) 746-5080
DEPOSI TION OF: M.J. , aka ELI SSA WALL v . WARREN JEFFS
Winston K. Blackmore
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Page 62
Q. And then paragraph 3, do you disagree with 1
anything in that paragraph? 2
(Witness reviewed exhibit.) 3
A. No. 4
Q. Paragraph 4, do you disagree with anything in 5
that paragraph? 6
(Witness reviewed exhibit.) 7
A. It's close enough. I mean I think it was 8
later than that, but. .. 9
Q. Paragraph 5, do you disagree with anything in 1 0
that paragraph? 1 1
A. No. 12
Q. Paragraph 6, do you disagree with anything in 13
that paragraph? 14
A. No. 15
Q. Paragraph 7, do you disagree with anything in 1 6
that paragraph? 17
A. Yes, Ido. 18
Q. What do you disagree with? 1 9
(Wi tness reviewed exhibit.) 20
A. I disagree that-- I think that the Trust 21
itself was a land holding trust and the Church itself was 22
an ecclesiastical group to administer the Church to the 2 3
people. 24
Q. Paragraph-- or sentence 2 of that where it 2 5
Page 63
says, "Historically, the President of the Church always
served simultaneously as t he President of the Board of
Trustees of the Trust (although the titles for these
offices may have been different)."
You agree with that, don't you?
A. Yes. The President of the Church always
served si multaneously, except for a small period of time
where on the death of President Johnson.
Q. Right. There would be --
A. A vice president. He was the president.
Q. Paragraph 8, do you disagree with anything in
that paragraph?
(Witness reviewed exhibit.)
A. I disagree that -- yes, I do disagree.
Q. What do you disagree with?
A. I disagree that the Church and the Trust was
inseparable, because they were two different, distinct
things.
Q. And are you talking about the-- what version
of the Trust are you talking about there?
A. The - I'm talking about the one that I was a
Tn.1stee of.
Q. The November 3rd, 1998 Trust?
A. The 1942.
Q. How about the 1998 Restated Trust?
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Page 64
A. I al ready explained that I don't even agree
with the 1998 Declaration of Trust.
Q. How about paragraph 12 where it states,
"Every President of the Churchffmst of who might have
been aware; namely Presidents Rulon T. Jeffs, Leroy S.
Johnson and John Y. Barlow, has perfonned man·iages
involving underage girls"?
A. I object to that, because not below the age
of consent.
Q. So do you make any distinction between
underage girls and age of consent?
MR. HANSEN: I'm going to object. You didn't
read the first sentence of that paragraph where it
references --
MR. MORTENSEN: All right, I'll read--
MR. HANSEN: A.11d then you asked him about the
paragraph, so it's misleading.
MR. MORTENSEN: Okay, that's fair.
Q. (BY MR. MORTENSEN) "Historically, these
marriages have included underage (before the age of
consent) girls, including some as young as fourteen.
Every President of the Church/Trust of whom I have been
aware, namely Presidents Rulon T. Jeffs, Leroy S. Johnson
and John Y. Barlow, has perfonned marriages involving
underage girls. "
Page 65
A. Under the age of majority, not under the age
of consent. That's my objection to that.
Q. Okay. And what is your understanding as to
from the time period that you became bishop until the law
in Utah was changed, what was your understanding as to
the age of consent?
A. r believe that the law of Utah changed the
age of consent from 14 to 16. That that age-- prior to
that, the law in Utah was, at least to my understanding,
that with parental consent, a 14-year-old could be
manied.
After that law, it was 16, a 16-year-old had to
have both parents' consent.
Q. Okay. So are you -- you are aware that
Presidents Rulon T. Jeffs, Leroy S. Johnson, and John H.
Barl ow had performed marriages of girls under the age of
16; correct?
A. No, actually I'm not. It may have been --
someone may have told me, but I am not aware of that.
Q. You don't have any firsthand k.J1owledge?
A. I don't have any knowledge of that, no.
Q. Have other people told you that?
A. I've heard it from other people, but I didn't
believe it.
Q. Have you ever perfonned any marriages of
17 (Pages 62 t o 65)
II
li
REPORTERS, INC . (801 ) 746- 5080
DEPOSITION OF: M.J ., aka ELISSA WALL v. WARREN JEFFS
Winston K. Blackmore
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Page 66
girls that are under the age of 16? 1
A. No, I haven't. 2
Q. Have you ever man·ied someone who is under 3
the age of 16? 4
A. Yes, I have. 5
Q. When was that? 6
A. Ob, heck, I can't recall, but I know that it 7
was not -- at the time the laws were not changed for the 8
age of consent. They had their parents' consent. 9
Q. Who was the person? 10
A. Lorraine Johnson. 11
Q. And how old was she? 12
A. She was 15, just about 16. 13
Q. Are you still married to her? 14
A. Yes, I am. 15
Q. So she was l 5 years old? 16
A. Just about 16. 1 7
Q. She was 15 years old when you married her? 18
A. Yeah. 1 9
Q. What year did you many her? 20
A. Oh, brother, you are going to get me really 21
in trouble, because I can't remember. I'd have to phone 2 2
her. 2 3
Q. How old were you? 2 4
A. It would have probably been 200 I or 2002. 2 5
Page 67
Q. And you are cun·ently 58? 1
A. Seven. 2
Q. Fifty-seven? 3
A. Yeah. 4
Q. So you were in your late 30s? 5
A. Yeah, I probably was if I'm 57. 6
Q. Who married you? 7
A. President Jeffs. 8
Q. And where were you married? 9
A. Nevada, I think. On, no, in Canada, I 1 0
beli eve it was in Canada. 11
Q. You were married to Lorraine Johnson who was 12
15 in Canada by President-- 13
A. No, it was in-- it was in Utah. 14
Q. Where in Utah? 15
A. Probably right here in Salt Lake City. 16
Q. Do you remember? 17
A. I could sure find that out, but ... 18
Q. Did you get written --first of all, who were 19
Lorraine Johnson's parents? 20
A. Ray Johnson and Kathy Ann Johnson. 21
Q. And did you get thei r consent? 22
A. They were the ones who were drivi ng the 23
program. 24
Q. Did they put a consent in writing? 25
Jill C. Dunford RPR, CSR
Page 68
A. I don't think so, but they were present.
Q. Did you go to the courthouse and get a
marriage license?
A. No, we didn't.
Q. Did you go to the marriage -- to the
courthouse and take Lorraine Johnson to the clerk of the
court so the clerk of the comt could determine whether
your marriage with a 15-year-old was appropriate under
Utah law?
A. No.
Q. Did you ever see Lorraine Johnson's birth
certificate prior to ma1Tying her?
A. No, I hadn't.
Q. Have you eveJ seen her driver's license?
A. No.
Q. Did you ever get written consent by Ray or
Kathy Johnson?
A. No.
Q. And it was Rulon Jeffs that marri ed you?
A. Yes, it was .
Q. So you are aware that President Rulon Jeffs
participated in your marriage to someone that was under
the age of majority?
A. Perhaps, yeah.
Q. Perhaps?
A. Yeah.
Q. You do know that, don't you?
Page 69
A. He-- he gave us his Church blessing, his
blessing on it.
Q. As the prophet of the FLDS Church or t he
Priesthood Work?
A. He was doing the bidding of her parents, so
that's what be did.
Q. But the prophet has to sanction any marriage;
correct?
A. No, not every marriage. He did sanction that
one.
Q. He perfonned it?
A. Yeah, he perfonned it.
Q. And your dad also-- your mom was 16?
A. Yeah.
Q. And where were they married?
A. The Cardston Temple.
Q. Was that your dad's first wife?
A. Yeah.
Q. Let me have you look at Exhibit 2, the
Declaration of Winston Blackmore.
On paragraph 5 -- frrst of all, let me ask, this
affidavit --or this declaration was prepared on behalf
of Jeffrey Shields, the attomey for the United Eff01t
18 {Pages 66 to 69)
REPORTERS, INC. (801) 746- 5080
DEPOSITION OF: M.J., aka ELISSA WALL v. WARREN JEFFS
Winston K. Blackmore
Page 70
1 Plan Trust; conect? 1
2 A. Correct. 2
3 Q. In paragraph 5 it states, "Roger explained to 3
4 me that some of the potential beneficiaries of the fund 4
5 of the young women'' ·- 5
6 MR. HANSEN: You need to be careful about 6
7 writing on the exhibit. That's the Court exhibit. 7
8 Q. (BY MR. MORTENSEN) If you want a copy you 8
9 can write on, we can-- 9
10 A. Sorry. 10
11 MR. MORTENSEN: No, you're fine. 11
12 MR. HANSEN: I don't think he's done mueh. 12
13 Ifyou need a notepad, to ahead and have that. 13
14 Q. (BY MR. MORTENSEN) In paragraph 5 it says, 14
15 "Roger explained to me that some of the potential 15
16 beneficiaries of the fund would be young women who were 16
17 seeking to escape or avoid an underage marriage. To help 17
18 justify their efforts to create the fund, and highlight 18
19 tbe need for such assistance, they asked me if I would 1 9
2 0 give a statement to the effect that underage marriages 2 0
21 had occurred among our people. Because I was aware of 21
2 2 such oceurrenecs, I agreed." 2 2
2 3 You were aware of underage marriages happening 2 3
24 amongst your people; correct? 24
25 MR. HANSEN: I'll objeet. Vague and 25
Page 71
1 ambiguous as to the term "underage marriage." 1
2 MR. MORTENSEN: I'm using the term he used. 2
3 MR. HANSEN: He used it when? 3
4 MR. MORTENSEN: In his affidavit or his 4
5 declaration. 5
6 MR. HANSEN: He's already said that's what 6
7 Roger Hoole prepared, he doesn't agree with it. It's an 7
8 inaccuracy. So my objeetion's appropriate. 8
9 Q. (BY MR. MORTENSEN) Based on paragraph 5 of 9
10 the declaration, you state on the last sentence you were 10
11 aware of such occunences -- because you were aware of 11
12 such occunences, you agreed to sign that declaration; 12
13 eorrect? 13
14 A. Let's just repeat it again, beeause I'm still 14
15 trying to calculate how old Lmnine was. 15
16 Q. Yourbrainisgoingfuzzy? 16
17 A. And it was in 1999. 17
18 Q. We won't give her the transcript. 18
19 A. Okay. Okay. So go baek here again. 19
2 0 Q. Okay. On paragraph 5, read through that and 2 0
21 tell me-- 21
22 A. " ... who were seeking to eseape or avoid an 22
2 3 underage maiTiage ... " 2 3
2 4 (Witness reviewed exhibit.) 2 4
25 A. Okay. 25
Jill C. Dunford RPR, CSR
Page 72
Q. You were aware that there were underage
marriages that were occurring amongst your people?
A. Yeah.
Q. And because of that, you agreed that a fund
to help these girls escape would be a good thing?
A. Or anybody, and l explained to him anybody.
Because at the time in our community there was a couple
that wanted to move and they had no money, no means, no
way to move.
So I met with those people and asked them what it
would take for them to move and they figured that it
would take tbem at least $10,000 to move their things and
25 to re-establish themselves in ground work.
So what I did at that time was search around
among the people to see ifthere's anyone who wanted to
take their presence on the property for $35,000 and we
found a person willing to do that. And so that figure
was a figure that satisfied me, that figure of $35,000.
Q. But you were aware that there were-- that
there were underage marriages occulTing amongst the FLDS
people?
A. Yes, underage. Eighteen is underage in--
Q. In Canada?
A. Yeah.
Q. In Canada, if they're under the age of 19,
Page 73
they have to -- they also have to go before a court
and--
A. Not a court.
Q. -- get permission?
A. They just go and they have to have one
parent-- both parents sign for their marriage license.
Q. Right. They have to have a parental consent
form that they lodge with the court?
A. Yeah.
Q. Have you ever seen your people do that before
getting married?
A. Oh, yes.
Q. Underage-- that are under the age of
consent?
A. Yeah --under the age of-- not parental
concept. Yeah, they do. They go and get-- if a
16-year-old girl is going to go many somebody, then 1
have seen them go and they take their parents in there
and they have them sign on a marriage license and ...
Q. That's for the first marriage?
A. Yeah, that's for the first marriage.
Q. On the second marriage, they can't do that,
can they?
A. No, but we don't even participate in under
the age of 18 in second marriages.
19 (Pages 70 to 73)
REPORTERS, INC. (801) 746-5080
DEPOSITION OF: M.J., aka ELISSA WALL v . WARREN JEFFS
Wi n s t on K. Blackmore
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Page 74
Q. And as the bishop of the Fundamentalist 1
movement in Bountiful, you have prohibited anyone from 2
under the age of 18 of being married; eorrect? 3
A. A plural marriage. 4
Q. Plural marriage? 5
A. Yes. 6
Q. You don't think that would be conect? 7
MR. HANSEN: Objection. Vague. Unclear. 8
THE WITNESS: I would think what would be 9
correct? 10
Q. (BY MR. MORTENSEN) Entering into plural 11
maniage under the age of 18 would be a proper-- or 12
under the age of 19 would be proper. 13
MR. HANSEN: Objeetion. Vague. 14
THE WITNESS: British Columbia is the only 15
jurisdiction in North America that has 19. So l don't 16
manage whal they do in Idaho or Alberta. 1 7
But my advi ce, I encourage someone if they want 18
to be someone's plural wife-- and they do, there's lots 19
of people that do-- they get 18, they get their parents, 20
and then they come talk. 21
Q. (BY MR. MORTENSEN) And they eome talk to you 22
as the bishop? 2 3
A. They eome and talk to me if they want to have 24
me approve it. 2 5
Page 75
Q. And for you to approve it, they have to be at 1
least 18? 2
A. Eighteen. 3
Q. But that always hasn't been the case; 4
coJTect? 5
A. No, it hasn' t. 6
Q. That changed after Warren Jeffs? 7
A. In 2002. 8
Q. Prior to that, though, you as the bishop 9
would perfonn plural marriages to girls that are under 10
the age of 19? 11
A. I have to think of who and where, but I would 12
have. I would have had the occasion. 13
Q. You don't deny that you did that? 1 4
A. No, I don't deny that. 15
Q. And you don't deny that before you would do 16
that the parents didn't bring wi th them a signed consent 17
fonn from the government or British Columbia? 18
A. I don't. 1 9
Q. Do you know who the youngest plural bride 20
that you have ever maJTied? 2 1
A. Lorraine. 22
Q. Pardon? 23
A. Lorraine.
Q. How about perfonn ing the marriage?
24
25
Jill C. Dunford RPR, CSR
Page 76
A. Oh, I have not ever performed anybody-- any
marriages for anybody that was under the age of 18 that I
knew of. But that wasn't my -- it became in 2002, I make
people show me thei r marriage license-- I mean not their
marriage license, but their age.
Q. Birth certificate or some proof of age?
A. Yes.
Q. Pri or to 2002, you never did that; COJTect?
A. No, I never asked them to provide it.
Q. Have you done anything-- here you state that
you were aware that underage marriages were occurring
amongst your people; correct?
A. Yes. So long as-- do you want me to put
this di sclaimer every time that under the age of-- they
had their parents' consent, underage with their parents'
consent.
Q. After 2002, were you aware of people within
the FLDS community that were being married that were
underage?
A. I'll tell you from 2000 on, I closed off my
phone. I looked a different direetion. I didn't look at
the news. I couldn't have cared less. And I did that
for several years before people finally came and started
hunting me out. But I have lost a piece of that history
because I didn't want to know it.
Pa ge 77
Q. On paragraph I 0 on Exhibit 2, on the last [
sentence you state, "Historically, it did happen, but was
a rare anomaly."
Do you see where I'm referring to?
A. Yeah.
Q. Let me ask you, your father -- your father
married a I 6-year-old; cotTect?
A. Yeah.
Q. And you married a 15-year-old?
A. Well, I never touched anybody before they
were 16.
Q. When you say "touched," is that having
conjugal --
A. L1 any way.
Q. Conjugal relationship?
A. I never had any conjugal relationship. I
mean I held a hand, but I would not touch anybody before
they were ...
Q. Okay. So you married someone that was 15?
A. Yeah, 15 and eight, nine, ten months,
somewhere in there.
Q. And you are aware that President Rulon Jeffs
married someone who was underage?
A. That would j ust be hearsay to me.
Q. Do you have an understanding of that?
20 ( Pages 74 to 77)
REPORTERS , INC. (801 ) 7 4 6-5080
DEPOSITION OF:
Winston K. Blackmore
Page 78
1 A. Only on hearsay. It was beyond my ti me. I
2 had no real contact with any marriages that I had to do
3 with that witnessed or were involved with him, the people
4 were well-- well older than 20.
5 Q. In paragraph 12 it says, " ... in no maniage
6 ceremony was the UEP T1ust ever mentioned."
7 Do you see where I'm referring to?
8 A. Okay, I'm there.
9 Q. It says, "I have perfonned and/or attended
10 many FLDS marriages (! estimate the number to be
11 approximately 200), and in no marriage ceremony was the
12 UEP Trust ever mentioned."
13 The marriage ceremony is a written out ceremony
14 that' s perfonned by a priesthood officer; correct?
15 A. That's correct.
16 Q. Have you had a chance to read through
17 Exhibit 2?
18 A. Yeah.
19 Q. So the jury can be-- if your testimony is
20 presented to the jury, they can rely on paragraph-- or
21 on Exhibit 2 to be a tme and accurate copy of what your
22 testimony is; correct?
23 A. Yes.
24 Q. Since 2002, have you had conversations with
25 Willie Jessop?
Page 79
1 A. Yes, I have.
2 Q. How often do you speak with Willie Jessop?
3 A. I went on a bike ride with him last year. I
4 talked to him once or twice a year prior to that.
5 Q. Has he provided you any documents regarding
6 the Elissa Wall matter?
7
A. No.
8 Q. Has he provided you any kind ofPowerPoint?
9 A. No.
10 Q. Has he talked to you about Elissa Wall?
11 A. Only to one extent, and that is is to not
12 have anything to do with that and -- but Willie Jessop
13 does not tell me what to do. He's a person that I speak
14 to every now and then, but we generally don't talk about
15 that.
16 Q. Willie Jessop is in the FLDS Church; is that
17 correct?
18 A. Is he in it?
19 Q. He is a member of the FLDS Church?
20 A. He used to be. I don't know what his current
21 status is.
22 Q. All right. Did Warren Jeffs ever assign you
23 to perfom1 any marriages up in Canada?
24 A. No.
25 Q. But Rulon Jeffs did?
Ji ll C. Dunford RPR, CSR
M.J., aka ELISSA WALL v. WARREN JEFFS
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Page 80
A. Yes.
Q. You told us about Lorraine Johnson. Are
there any other women that you took as plural wives that
were under the age of 19?
A. Yes.
Q. Who are those or what is -- what are -- more
than one?
A. Are you the media? I mean do I have to
display my personal family life here? I mean they were
in the 1990 era, earlier than 1990 era. It would be two
or three of them, but ...
Q. What are their names?
A. Marcia Chatwin and Hannony Quinton.
Q. Marcia Chatwin?
A. Yeah.
Q. And who is the second one?
A. Harmony Quinton.
Q. And when did you marry Marcia?
A. It would have been before 1 9 -- it would have
been probably 1994.
Q. How old was Marcia?
A. She was just about 18.
Q. Was she 17?
A. Seventeen.
Q. W11ere did you marry her?
A. Down in Hildale.
Page 81
Q. Did you get any written consent from her
parents?
A. No, they were both there.
Q. Did you go to the clerk of tl1e court or the
county clerk and get a marriage license?
A. No, I didn't.
Q. Did you ever see her birth certificate prior
to marrying her?
A. No.
Q. And then Harmony --
A. Quinton.
Q. -- Quinton. When did you marry Hannony
Quinton?
A. Ninety-four as well -- oh, no, sooner than
that, probably-- I don't know. It was in the early
'90s, maybe just a year before that, '93 maybe.
Q. And how old was Hannony?
A. She was 16.
Q. And where did you marry her?
A. In Salt Lake City.
Q. Did you go to the clerk of the court and get
a license?
A. No.
Q. Did you get written consent from her parents?
;
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21 (Pages 78 to 81)
REPORTERS, INC. (801) 746-5080
DEPOSITION OF: M.J., aka ELISSA WALL v. WARREN JEFFS
Winston K. Blac kmo re
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Page 82
A. They were in attendance. 1
Q. Just so the juty is clear, you never got 2
written consent? 3
A. Not written consent, no. They were 4
attending. 5
Q. Did you ever see her birth certificate-- 6
A. No. 7
Q. --before you manied her? 8
A. No, I didn't. 9
Q. Any other-- any other plural wives that were 10
under the age of 19? 11
A. I don't think -- oh, Susan was. 12
Q. Susan? 13
A. Susan Gallup. 1 4
Q. When did you marry Susan Gallup? 15
A. Probably '91. 1 6
Q. Pardon? 1 7
A. Probabl y '9 1. 18
Q. How old was Susan? 19
A. Sixteen, just about 17, about 16. 20
Q. When is her birthday? 21
A. Idon'tknow. 22
Q. Do you know what day you married her? 2 3
A. No. 24
Q. And you married her in Salt Lake City? 2 5
Page 8 3
A. Yep. 1
Q. Who married you? 2
A. President Jeffs, Rulon Jeffs. 3
Q. Who married you and Hannony Quinton? 4
A. He did. 5
Q. Rulon Jeffs? 6
A. Yeah. 7
Q. And who maiTied you and Marcia? 8
A. He did, Rulon Jeffs. 9
Q. So Rulon Jeffs would have married all four of 10
your plural wives that are under the age of 19? 11
A. Yes. 12
Q. And all of these four plural wives were also 13
under the age of 18? 14
A. I didn't hear you. 1 5
Q. My first question was 19 and now I'm just 16
lowering it down to 18. 17
A. Yeah, yeah, they were. 18
Q. Did you ever go to petition juvenile court 1 9
here in Utah to marry any of these women? 20
A. No. 21
Q. And you understand, don't you, under the laws 2 2
of Utah, tbat if you had gone to a clerk to obtain a 2 3
maiTiage license, you would have been denied one? 2 4
A. There was never any intention to go and I did 2 5
Jill C. Dunford RPR, CSR
Page 8 4
not understand that, no.
Q. You were married legally to Jane Blackmore at
the time?
A. Yeah.
Q. And under the laws of Utah, you would have
been denied a maniage license with these four women that
were under the age of 18?
MR. HANSEN: Objection. Foundation. Calls
for speculation.
Q. (BY MR. MORTENSEN) Did you have that
understanding?
A. I never even thought of that.
Q. You didn't research that before you
married--
A. No, l didn't.
Q. --any of these young women?
A. No. No, I haven' t.
Q. I take it that at least with regard to you
manying someone under the age of 18 is not an anomaly?
A. Not under the age of 18.
Q. It's happened four times?
A. Yeah, witb both parents in attendance.
Q. But without sanction or protection from the
State of Utah?
A. No.
Page 85
Q. Or protection or sanction from the Province
of British Columbia?
A. The Provinee of British Columbia, I had no
eoncem about them and I know nothing about your mles.
Q. You don't believe that you are subject to the
mles of Utah?
A. Yeah, I do.
Q. You are subject to them?
A. Yes, I am.
Q. But you didn't make any inquiries of what
they were before you married these four underage women?
A. Not those.
Q. Did you marry a Christina Gallup?
A Oh, yeah. Yes, I did.
Q. And she was 15 years old, was she not?
A. She was just about 15, but she's no longer in
my life, so ...
Q. But you took Christina Gallup as a plural
wife; correct?
A. That's right.
Q. When she was 15?
A. Yeah.
Q. And she's left you?
A. Yeah.
Q. When did she leave you?
22 ( Pages 82 to 85)
II
REPORTERS , INC. (801) 7 46-5080
DEPOSITION OF : M.J., aka ELISSA WALL v . WARREN JEFFS
Winston K. Blackmore
Page 86 Page 88
1 A. Two or three years ago. 1 British Columbia?
2 Q. How about Maryanne Gallup? 2 A. No.
3 A. Well, Maryanne Gallup was 16, but she-- we 3 Q. Did you take a signed consent fonn fr om her
4 never had anything to do with each other and we later-- 4 parents?
II
5 we redid our vows and I think she was 19, 18 or 19. 5 A. No, but they were present.
6 Q. The first time you entered into a plural 6 Q. And who married you and Ms. Fischer? Ill.
7
marriage with her was when she was 16 years old?
7 A. President Jeffs.
8 A. Yes. 8 Q. How about Shalina Palmer?
9 Q. And who perfomled that wedding? 9 A. I already told you about her, didn't (?
10 A. Leroy Johnson. 10 Q. I don't believe so.
11 Q. And where was that done? 11 MR. HANSEN: What's the name?
12 A. Salt Lake City.
12 MR. MORTENSEN: Shalina Palmer.
13 Q. And what about Christina Gallup when she was 13 Q. (BY MR. MORTENSEN) You married her; correct? .
14 15, who performed that wedding? 14 A. Yeah.
15 A. Leroy Johnson.
15 Q. Where did you marry her?
16 Q. And what was Mr. Johnson's position with 16 A. Down here in Salt Lake.
17 the--
17 Q. She was 15 years old?
18 A. He was the President of the Church. 18 A. I think she was 16.
19 Q. And he was the prophet? 19 Q. Is it possible she was 15?
20 A. Yeah. 20 MR. HANSEN: Objection. Calls for
21 Q. And are Maryanne, Chri stina, and Susan, are 21 speculation.
22 they all sisters?
22 THE WITNESS: Could have been.
23 A. Yes, they are. 23 MR. HANSEN: Misstates his testimony.
24 Q. How about Edwin Barlow?
24 Q. (BY MR. MORTENSEN) You never checked her
25 A. Excuse me? 25 berth certificate before?
Page 87 Page 89
1 Q. Did you marry-- excuse me-- an Edith 1 A. No. No, I didn't.
2 Barlow. 2 Q. And who perfonned that wedding?
3 A. Who? 3 A. Jeffs, President Jeffs.
4 Q. Edith Barlow. 4 Q. How about Catherine Broadbent?
5 A. Oh, Edith, yeah. 5 A. Yeah.
6 Q. She was 17 when you married her, was she not? 6 Q. You married her?
7 A. I think she was 18. She might have been, but 7 A. Yeah.
8 I think she was 18. 8 Q. She was 17 at the time?
9 Q. It's possible she was 17? 9 A. I think she was 18.
10 A. It's possible that she was. 10 Q. Did you independently verify her age before
11 Q. And where did you marry her? 11 you manied her?
12 A. Salt Lake City. 12 A. No, I didn't.
13 Q. And when did yolt marry her? 13 Q. Again, where did you marry her?
14 A. I'm going to say '95. 14 A. It would have been down in Salt Lake.
15 Q. Did President Jeffs-- 15 Q. And did President Jeffs marry you and --
16 A. Yeah. 16 A. Yeah.
17 Q. -- conduct that maniage? 17 Q. -- Catherine Broadbent?
18 A. (Witness nodded.) 18 A. Yes, he did.
19 Q. And Janelle Fischer, you married her? 19 Q. At the time -- so it sounds like all of your
20 A. Yes, I beli eve she was 18. 20 plural marriages with women that were under the age of 19
21 Q. Is it possible she was 17? 21 or 18 were pe1f01med by President Rulon Jeffs?
22 A. Could be, but I don't think so. 22 A. Yes.
I
23 Q. Where did you marry her? 23 Q. And isn't it-- with the exception of I guess
24 A. In Canada. 24 President Johnson performed one?
25 Q. Did you go to get a marriage license from 25 A. Two.
-
. . - ..
23 (Pages 86 to 89)
Jill C. Dunford RPR, CSR REPORTERS , I NC . (801) 746- 5080
DEPOSITION OF: M.J., aka ELISSA WALL v. WARREN JEFFS
Winston K. Blackmore
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Page 90
Q. Two? And at the time that the maniages --
that the two maniages that Leroy Jolmson perfom1ed, he
was also the President of the UEP Trust; eorreet?
A. Yes, he was.
Q. And at the time that Rulon Jeffs manied you
and these women that we have talked about, he was also
the President of the UEP Trust?
A. Yes,hewas.
Q. Are there any other women that were under the
age of 18 that you took as a plural wife that we haven't
discussed?
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A. Not that I can reeall. 12
Q. Did you perform a wedding between Sharon Oler 13
and Kendall Jolmson?
A. No, I didn' t.
Q. Did you perform a wedding between Marjorie
Oler and Kendall Johnson?
A. No, I did not.
Q. Did you perfonn a wedding of Camille Steed to
Bob Barlow?
A. Who?
Q. Bob Barlow.
A. No.
Q. Did you perform a wedding of Lucille Musser
to Rulon Fischer?
Page 91
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A. No. 1
Q. Were you present at any of those weddings? 2
A. No. 3
Q. Do you know Esther Ruth Chatwin? 4
A. If Ruth is the middle name, I don't know. I 5
know Esther Chatwin. 6
Q. Does she live up in Bountiful? 7
A. Yeah. 8
Q. And who is she married to? 9
A. Daniel Blackmore. 10
Q. Is that your son? 11
A. No. 12
Q. How are you related to Daniel Blackmore? 13
A. He's my nephew. 14
Q. Did you perform that wedding? 15
A. No, I didn't. 16
Q. Is she part of the FLDS Group or is she part 17
of the group that -- 18
A. She's no t a part of any group. 19
Q. Has she entered into auy plural marriages? 20
A. No. 21
Q. Or is she a plural wife is a better question? 22
A. I don't think so. I think she's at the 23
university, a doctor. 2 4
Q. So she's up in Calgary? 2 5
Jill C. Dunford RPR, CSR
A. No, she's in St. George.
Q. So she doesn't live in Bountiful?
A. She did, but she doesn't.
Page 92
Q. Are you aware of any of the circumstances
involving her marriage?
A. No, I'm not.
I
Q. I take it that you have never gone to the
Canadian authorities to report any kind of concem that
you have had about an underaged bride in your flock?
J
A. Not in my flock.
Q. Have you gone to Canadian authorities that
are over other underaged brides?
A. I wouldn't know any of the circumstances
regarding them, so J haven't.
Q. So that would be no?
A.   h a ~ s no.
Q. Have you attended any of the marriages of
WmTen Jeffs?
MR. HANSEN: Marriages that he's performed?
MR. MORTENSEN: Just been in attendance.
THE WITNESS: You know, I may have been, but
I can't recall what they would be.
MR. HANSEN: I guess my question is are you
asking about maniagcs that Warren Jeffs personally
participated in or the weddings that Warren Jeffs
Page 93
performed?
MR. MORTENSEN: The weddings that Warren
Jeffs participated in as the groom.
THE WITNESS: As the groom?
Q. (BY MR. MORTENSEN) As the husband.
A. Man, I just immediatel y can't remember.
Q. Do you have any knowl edge of Shirley Steed
marrying Wanen Jeffs?
A. I do not know who Shirley Steed is.
Q. Do you know who Maryanne Jessop Jeffs is?
A. I can't picture Maryarme Jessop Jeffs.
Q. Do you have any knowledge about her maniage
to W anen Jeffs?
A. No.
Q. Do you have any knowledge about the marriage
of Brenda Fischer to Warren Jeffs?
A. No.
Q. Do you have any knowledge about Loretta Jane
Barlow being manicd to Warren Jeffs?
A. No.
Q. Do you have know knowledge about Rita Keatc
being married to Warren Jeffs?
A. No.
Q. Do you have any knowledge of Lilly Blackn1ore
being married to Warren Jeffs?
24 (Pages 90 to 93)
REPORTERS, I NC. (801) 746-5080
i
DEPOSITION OF: M. J ., aka ELISSA WALL v. WARREN JEFFS
Winston K. Blackmore
Page 94
1 A. Only after the·- after the fact, just the 1
2 last couple of days. 2
3 Q. So you learned about that? 3
4 A. The last couple of days. 4
5 Q. Who did you learn it from? 5
6 A. Just conversation, just listening to 6
7 different people talking about it. 7
8 Q. Who has been talking about it? 8
9 A. Ken and I. 9
10 Q. Who? 10
11 A. Ken and I. 11
12 Q. SoKenOlerisawareofit? 12
13 A. He apparently has heard about it. I have not 13
14 heard about any of those things. 14
15 Q. And what did Mr. Oler tell you about that 15
16 maniage? 1 6
17 A. Not a whole bunch. 17
18 Q. Did you talk about the fact that she was 18
19 under the age of 18? 19
20 A. No. I think we were talking about that she 2 0
21 left their community. 21
22 Q. Left the FLDS conununity? 22
2 3 A. Left the FLDS community. 2 3
24 Q. How about Millie Steed being married to 24
2 5 Warren Jeffs? Do you have any infonnation about that? 2 5
1
2
3
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5
6
7
8
9
10
11
12
13
14
15
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Page 95
A . No. 1
Q. Are you aware of that? 2
A. I don't know who Millie Steed is. 3
Q. Did you panicipate at all in the marriage of 4
Isaac Johnson to Lorraine Johnson? 5
A. No. 6
Q. When I say "participate," let's try to shot1 7
circuit this. When I say "par1icipate," were you 8
present, did you sanction it, or did you marry them? 9
A. No, I-- and I have got to tell you that I 10
have had no contact with any of these people for more 11
than 12 years. So I don't even know some of the names 12
that you're talking about. 13
Q. Do you know Lonaine Johnson? 14
A. I matTied Lorraine Johnson. We have already 15
talked about that. 16
Q. Okay. Maybe it's a different person married 1 7
to Isaae Johnson back on September 26 of 1996. 18
A. No, I don't. I don' t know Lorraine Johnson. 19
Q. Was-- 20
A. I can't recall . 21
Q. Was your Lorraine married prior to-- 22
A. No. 23
Q. -- you marrying her? After? 2 4
A. Pardon me? 2 5
Jill C. Dunford RPR, CSR
Q. She is still with you?
A. Yes.
Page 96
Q. How about Celesta Darger to Lehi Jacob Steed?
A. No.
Q. Did you participate in that?
A. I have no idea who those people are.
Q. Ruth Mariette Stubbs to Ronnie Hans Holm?
A. No.
Q. How about Isabel Darger to Marcus Wyman
Jeffs?
A. (Witness shook head.)
Q. How about Mallory Jane Fischer to Daniel
Allred Jeff Steed?
A. (Witness shook head.)
Q. Louisa Johnson to Dale Evans Barlow?
A. No.
Q. LaRay Steed to Daniel Rober1 Barlow?
A. No.
Q. How about Jennifer Lenore Richter to Edson
Frederick Dart?
A. No.
Q. How about Leroy Jeremiah Jessop to Mary Jean
Jessop?
A. No.
Q. Mary Lee Jessop to David Edson Peine,
P-e-i-n-e?
A. Oh, Peine (pronouneing.)
Q. Peine.
A. No, l don't.
Q. Do you know David Peine?
A. No, I don't.
Page 97
Q. How about Susan White to Guy Lee Barlow?
A. No, I don' t.
Q. When again was it that President Jeffs, Rulon
Jeffs, said that the FLDS people were going to obey the
law of Utah with regard to underage marriage?
A. I believe it was right after that law was--
MR. HANSEN: Can we stop for a second? My
video has to go to a new segment.
(Short pause.)
MR. HANSEN: Okay, we're back on.
THE WITNESS: It was right after that law was
adopted in the legislature here.
Q. (BY MR. MORTENSEN) Okay. And was the -- was
the decision made that people under the age of 18 wou Jd
not be allowed to enter into marriages within the FLDS
eommunity or was the decision made that it would require
parental eonsent for such to happen?
A. I think that the parents were always a part
of the decision-making process. But if I remember right,
1:
25 (Pages 94 to 97)
REPORTERS, INC. (801) 746-5080
DEPOSITION OF: M.J., aka ELISSA WALL v. WARREN JEFFS
Winston K. Blackmore
Page 98
1 the law that we are talking about was one that rai sed the 1
2 age of parental consent to 16. 2
3 Q. So the decision was made that anyone under 3
4 the age -- that 16 and under could not enter into a 4
5 plural marriage without parental consent? 5
6 A They had to be 16 and over, not 16 and under, 6
7 16 and over. 7
B Q. Was there any discussion about going to -- 8
9 complying with the portion of the law that states you 9
10 need to go to get a maniage license? 10
11 A. No. 11
12 Q. Was there any discussion about requiring the 12
13 parents to go to the clerk of the-- the county clerk to 13
14 give their consent to the marriage being -- 14
15 A. No. 15
16 Q. Why wasn't that done? 16
17 A l have no idea. 17
1B MR. MORTENSEN: Why don't we take a 18
19 five-minute break and try to finish up. 19
20 MR. HANSEN: Off the videotape. 20
21 (Short recess.) 21
22 MR. HANSEN: I'm going to tum my video on 22
23 now. 23
24 MR. MORTENSEN: We can go back on the record. 24
25 Q. (BY MR. MORTENSEN) Mr. Blackmore, you 25
Page 99
1 cunently Jive on UEP property; is that correct? 1
2 A That's correct. 2
3 Q. And so does your family? 3
4 A. Yes, they do. 4
5 Q. And you have been working with Mr. -- with 5
6 Mr. Shields in the probate of the UEP Trust; correct? 6
7 A. Will you explain the probate of the UEP 7
8 Trust. I have been working with Bruce Wisan. 8
9 Q. Okay. And how many times a week do you talk 9
10 to Mr. Wisan? 10
11 A. l probably talk to him four or five times a 11
12 year. 12
1 3 Q. Do you know his phone number? 13
14 A Yeah, l know his phone number. 14
15 Q. Right offhand? 15
16 A Yeah. 16
1 7 Q. What is it? 1 7
18 A. (801) 328-2011 . 18
19 Q. And you know that from talking to him two or 19
2 0 three -- three or four times a year? 2 0
21 A. Yeah, I do. It's a fairly simple one. It's 21
22 on all of our tax notices . 22
2 3 Q. Now, I believe you testified that you had 23
2 4 man·ied Lorraine Johuson back in 1999? 2 4
2 5 A l think it was around there. I mean that's a 2 5
Jill C. Dunford RPR, CSR
Page 100
closer guesstimate than 2001.
Q. Okay. 1991 --or 1999. And the President
Rulon Jeffs married you?
A Yeah.
Q. So that would have been after the time that
the -- that the amended trust had been signed; correct?
A. Yes.
Q. After he had had a stroke?
A. Yes.
Q. You know who Debbie Palmer is, don't you?
A Yes, I do.
Q. Who is she?
A. l went to school with her all the time. She
was married to my father.
Q. And s he's left the Fundamentalist Mormon
movement, has she not?
A. Yes, she has.
Q. Do you remember telling CBC and the bishop of
Bountiful Special that Debbie Palmer was taking mental
treatments?
A. I don't-- I never watched any of those
things.
Q. Do you remember telling him that?
A. l don't remember.
Q. You are aware of that, though, aren't you?
A. That she was?
Q. Yeah.
Page 101
A. I know that she was on some depression drugs.
Q. And you know that because you had access to
her medical records?
A. No, because she told me.
Q. Are you aware of what properties that the UEP
Trust owns?
A. Not anywhere other than Canada. r know what
they own in Canada.
Q. You don't have any understanding as to what
the UEP Trust owns --
THE WITNESS: Everywhere else?
MR. HANSEN: Objection. Vague. Overly
broad.
Q. (BY MR. MORTENSEN) Is n't it true that
the UEP Trust owns the Caliente Hot Springs Motel in
Nevada?
A Oh, 1 don't know that.
Q. Were you ever married there?
A. l was once, but don't ask me who to, because
l can't remember which one it was to.
Q. So an FLDS marriage was perfonned as you as
the groom at the Caliente Hot Springs Motel?
A. Y ~ h   II
26 (Pages 98 t o 1 01)
REPORTERS, INC. (801) 746-5080
DEPOSITI ON OF: M.J., aka ELI SSA WALL v. WARREN JEFFS
Winston K. Blackmore
Page 102
1 Q. And Rulon Jeffs perfonned that maniage? 1
2 A. Yes, he did. 2
3 Q. And he would have been the UEP -- the 3
4 President of the UEP Trust at that time? 4
5 A. Yes. 5
6 Q. Did you have any discussions with your 6
7 ex-wife Jane Blackmore about coming down for a deposit ion 7
8 today? 8
9 A. No, I didn't. 9
10 Q. Were you aware that-- are you aware of any 10
11 conversati ons with her about eoming for a deposi ti on 11
12 today? 12
13 MR. HANSEN: Objection. Overly broad. 1 3
14 Vague. 1 4
15 THE WITNESS: I'm aware of a couple of three 1 5
16 weeks ago that we talked about -- I didn't talk to her 1 6
17 about it. 1 7
18 Q. (BY MR. MORTENSEN) W110 talked to her about 18
Page 104
people to put their names forward to be potential
trustees of the UEP, I put mine forward. Roger
encouraged me to do that and I di d.
Q. And is this affidavi t --this is your
affidavit; correct?
A. Yes, although I'm not fa miliar with it other
than just rereading it from a long time ago. It appears
to be, yes.
Q. Is that your signature on page 8?
(Witness reviewed exhibit.)
A. Yes, it is.
Q. And it appears to be notarized by a Utah
notary?
A. Yes, it does.
Q. Do you know Marta Barlow, a notary?
A. I think that she was a notary that worked
for-- wi th Roger at the time.
Q. You don't have any personal connection with
19 it? 19 her?
20 A. I talked to my son about it, our son.
21 Q. And do you know, do you have any
22 understanding as to why s he didn't come?
2 3 A. My only understanding is that it was-- had
2 4 to do with her health.
25 Q. What is your understanding with regard to her
Page 103
1 health?
2 A. That she's -- I mean she's not feel ing well
3 and able to do that.
4
Q. Have you ever compared Warren Jeffs to
5 Hitler?
6 A. If I didn't, I should have, but I may have.
7
Q. Would you have compared him to Hitler in the
8 North Star?
9 A. I probably could have. If I didn't, I should
10 have.
11 Q. Mark this as Exhibit 4.
12 (Exhibit No. 4 was marked for identification.)
13 Q. Mr. Blackmore, do you recognize this
14 document?
15 A. You are going to have to refresh me a
16 minute.
17 Q. Okay. Take a moment and read through it.
18 {Witness reviewed exhibit.}
19 A. Okay, I have read it.
20 Q. And --
21 MR. HANSEN: Is your camera working?
22 MR. MORTENSEN: It is.
23 Q. (BY MR. MORTENSEN) What is this doeument?
24 A. I think that it's one that when the Judge, I
25 think it was Judge Denise Lindberg, was trying to get
-.
Jill C. Dunfor d RPR, CSR
20 A. No, I don't.
2 1 Q. AI! right. On paragraph 20, could you read
?. 2 that for the jury?
2 3 A. "Because my family lives on land owned by the
2 4 UEP Tmsl, they -- like so many others here in Bountiful
2 5 and in Hildaie, Utah, Colorado City, Arizona and
1
2
3
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5
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7
8
9
10
11
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13
14
15
16
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18
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20
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22
23
24
25
Page 105
elsewhere -- will be directly impacted by the necessary
actions this Court, the Special Fiduciary and the new UEP
board of trustees will take in regard to the Trust and
its people. "
Q. Is it your understanding that this current
lawsuit with El issa Wall against the UEP Trust coul d have
a direet impact upon your family?
A. I don't think that it could have a direct
impact on us, btlt it could, I suppose.
Q. Could it have a direct impact on UEP
property, family members that you have down in Short
Creek?
MR. HANSEN: Objection. Calls for
speculation. Laek of foundation.
Q. (BY MR. MORTENSEN) Go ahead and answer.
A. In any conversation I ever had with Roger, he
always told me that nobody' s house was going to be at
risk with the -- with the M.J. case. That his clients
had determined that they were not going to put in
jeopardy anybody's households. So that's the
understanding that I have.
Q. All right. Let me ask you, are you familiar
with the book In Light and Truth by President Rulon
Jeffs?
A. No, I'm not.
27 (Pages 102 to 105)
REPORTERS , INC. (801 ) 746-5080
DEPOSITI ON OF:
Winston K. Blackmore
Page 106
1 Q. You have never seen it, never seen that
2 document?
3 A. I have seen it. I have seen the book, but 1
4 have never read it.
5 Q. Do you know whether it would be considered
6 doctrine within the FLDS community?
7 A. You know, I don't know.
8 Q. You don't have an opinion one way or the
9 other?
10 A. I don' t have any clue. I haven't read it.
11 Q. And back to Exhibit 4, you were-- you were
12 seeking, were you not, in front of Judge Lindberg to
13 become a trustee of the UEP Trust?
M.J., a ka ELI SSA WALL v . WARREN JEFFS
Page 108
1 are a spiritual leader in the Priesthood Work; is that
2 con·ect?
3 A. That's COITeCt.
4 MR. MORTENSEN: No further questions.
5 MR. HANSEN: We're done.
6 Mr. Blackmore, you have the right to read and
7 review this tes timony and if there arc any changes that
8 need to be made, you can correct it. You can do that or
9 you can waive that. It's your option.
10 THE WITNESS: That is right now?
11 MR. HANSEN: You just have to tell her ifyou
12 -- she will type up a transcript of the deposition and
13 would send it to you if you would like to read and review
14 A. Yeah, Roger encouraged me to put my name in 1 4 it.
15 there to be a trustee. 1 5
1 6 Q. And did you agree with that? 1 6
17 A. I did, yes. 1 7
18 Q. Could you read paragraph 14 where you discuss 18
19 the qualifications to be a trustee? 19
20 A "I believe that I am qualified to serve as a 20
21 trustee of the UEP Trust, not only because I am a 21
22 beneficiary of the Trust and was a trustee from 1986 22
2 3 through 2002, but also because I have extensive business 2 3
24 experience and have worked closely with hundreds of 24
2 5 Fundamentalist Mormons, both through the company that I 2 5
Page 107
1 run, and also as a spiritual leader i.n the Priesthood 1
2 Work, the FLDS Church and currently as a Fundamentalist
2
3 Mannon."
3
4 MR. MORTENSEN: That's all the questions I
4
5 have for now.
5
6 FURTHER EXAMINATION
6
7
7 (BY MR. HANSEN)
8
8 Q. With regards to the last s tatement, was it
9
9 your understanding that as they were creating this new
10
10 trust, they were interested in individuals who had a
11
11 background, experience, and perhaps were practicing 12
12 Fundamentali st Monnons? 1 3
13 A. I think that the -- the interest that they
14
14 had in me was the fact that Canada is far removed from
15
15 the rest of the property, the UEP property in Canada.
1 6
16 And without someone to contact there, I feel like, you
17
17 know, what the coneem was is that I could be some sort
18
19
18 of I iaison with the property there. That's how l
20
19 remember it.
20 MR. HANSEN: I don't have any further
21
21 questions.
22 FURTHER EXAMINATION 22
23 {BY MR. MORTENSEN) 23
24 Q. Based on your affidavit, however, one of your 24
25 qualifications you set forth to the Court was that you
25
Jill C. Dunford RPR, CSR
THE WITNESS: I'd like to.
MR. HANSEN: She'll need your address. She
can follow up with you on that. So the witness will read
and review.
(The dep ositi on was concluded at 12:10 p.m.)
-ooOoo-
CE RTIFICATE
I, JILL C. DUNFORD, Registered
Professional Reporter, certifY:
Page 109
That the foregoing deposition of WINSTON
K. BLACKMORE was laken before me pursuant to Notice at
the time and place therein set forth, at which time the
witness was put under oath by me;
That the testimony of the witness and
all objections made at the time of the examination were
recorded stenographically by me and were thereafter
transcribed under my direction;
I FURTHER CERTIFY that I am neither
counsel for nor related to any party to said action nor
in any way interested in the outcome thereof.
Certified and dated this __ day
of _ _ ,20 l4.
JILL C. DUNFORD, CSR, RPR, RMR
Certified Shorthand Reporter
for the State of Utah
2 8 (Pages 106 to 1 09)
REPORTERS, I NC. (801 ) 746- 5080
DEPOSITION OF: M.J., aka ELI SSA WALL v. WARREN J EFFS
Winston K. Bl a ckmore
Page 110
1 WITNESS SIGNATURE CERTIFICATION
2
3
STATE OF UTAH )
4 ) ss.
COUNTY OF )
5
6
7 WINSTON K. BLACKMORE deposes and says: That h
8 is the witness referred to in t he foregoing deposition;
9 that he has read the same and knows the contents thereof;
10 that the same are true of his own knowledge.
11
12 WINSTON K. BLACKMORE
13
14 SUBSCRIBED and SWORN to before me this
__ day
15 of • 20
16
17 Notary Publie
1 8 Residing at
19
20
21 My eommission expires:
22
23
24
25
Page 111
1 CORRE C TION S
I!
2
Deposition of: WINSTON K. BLACKM:ORE
3 Taken: February 28, 2014
Reporter: Ji ll C. Dunford, Reporters, Inc.
I
q
(80 I) 746-5080
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29 (Pages 110 to 111)
Jill C. Dunf ord RPR, CSR REPORTERS, INC. ( 801) 7 46-508 0

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