UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT TACOMA

CHERYL LINDSEY SEELHOFF, a married woman, Plaintiff, Tacoma, Washington vs. PAT and SUE WELCH, husband and wife, Defendants.

Docket No. C97-5383FDB Tacoma, Washington August 31, 1998 Trial Volume 1

TRANSCRIPT OF PROCEEDINGS BEFORE THE HONORABLE FRANKLIN D. BURGESS UNITED STATES DISTRICT JUDGE, and a Jury.

APPEARANCES: For the Plaintiff:	BARBARA J. DUFFY GWENDOLYN PAYTON KLEIN Lane Powell Spears Lubersky 1420 Fifth Avenue, Suite 4100 Seattle, Washington 98101-2338
For the Defendants:	RUDY R. LACHENMEIER LORI DeDOBBELAERE Lachenmeier, Enloe & Rall 9600 S.W. Capitol Highway Portland, Oregon 97219
Court Reporter:	Teri Hendrix Union Station Courthouse, Room 3100 1717 Pacific Avenue Tacoma, Washington 98402 (253) 593-6545

Proceedings recorded by mechanical stenography, transcript produced by Reporter on computer.

Excerpt from transcripts Volume 1 August 31, 1998 Pages 1-209


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Tacoma, Washington 98401

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1  and Roland?
2  A. Well, I had trouble getting out a full length magazine
3  because of John and Roland being gone and for some other
4  reasons. But I didn't have trouble getting this particular one
5  out that I got out. I got it out.
6  Q.  The CHEO convention was coming up?
7  A.  That's correct.
8  Q.  Where was the CHEO convention being held?
9  A.  In Ohio.
10  Q.  Did you go to that convention in Ohio?
11  A.  Yes, I did.
12  Q.  Did you go with anybody else?
13  A.  Yes, I did.
14  Q.  Who was that?
15  A.  I went with Rick Seelhoff.
16  Q.  Okay. Tell me about -- why did you go to the CHEO
17  convention? Why did you speak at that convention?
18  A.  I had made the arrangements to go the year prior. I had
19  been advertising in the magazine for an entire year. I knew
20  that there were subscribers coming from Maine and California and
21  a lot of other places to hear me, and I just felt that I would
22  give it my best shot for their sake.
23  Q.  After the time that you confessed your relationship to Joe
24  and Irene Williams and before you left for the CHEO convention,
25  did you have any other conversations with Joe and Irene

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1  Williams?
2  A.  Yes.
3  Q.  Tell me about those.
4  A.  On occasion  the situation was that my ex-husband had
5  returned to Washington.and was living with Irene and Joe
6  Williams. Joe Williams was one of my ex-husband's and mine's
7  closest friends.  For that reason, on occasion, I would bring
8  the children by to visit with their dad.
9    When I would bring the children by, which happened on'
10  probably two or three occasions, Joe and Irene would sometimes
11  take an opportunity to engage me in conversation in those times.
12    Do you want all the times I talked to them?
13  Q.  No, I don't.
14    Just tell me in general terms: Did you ever, prior to the
15  time you went to the CHEO convention, did you ever ask Joe or
16  Irene Williams for advice as to whether you should go?
17  A.  No.
18  Q.  When you went to the CHEO convention -- when was the CHEO
19  convention?
20  A.  It was June 24th and 25th of 1994.
21  Q.  Did you go straight from Washington to the CHEO convention?
22  A.  No.
23  Q.  Did you stop off anywhere?
24  A.  We went to Minneapolis.
25  Q.  Why did you go to Minneapolis?

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1  A.  It was a time of incredible intensity, a crisis for me. And
2  my now husband Rick's pastor made himself available to us and
3  his mother made herself available to us, to stay with her and to
4  just receive some counsel and a welcome for a couple of days
5  before we went on to CHEO.
6  Q.  Tell me about the CHEO convention. How did things go at the
7  CHEO convention? You gave a keynote address; is that right?
8  A.  Yes, I was scheduled to give seven workshops and I did give
9  seven workshops.
10  Q.  And during the time that you were at the CHEO convention or
11  away for the CHEO convention, did you have any conversations
12  with Joe or Irene Williams?
13  A.  When we were in Minnesota, I had a conversation with Joe and
14  Irene Williams when we were in Minneapolis.
15  Do you want me to describe that?
16  Q.  Yes, tell me about that conversation.
17  A.  I had called my daughter -- when we left the state of
18  Washington, I left my children in the charge of my older
19  daughter, who was at that time 18, but they were staying with
20  another family, not involved with Calvary Chapel, some friends,
21  a home schooling family.
22  I would call regularly to check on them to see how they were
23  doing and everything, and I happened to be talking to my
24  daughter when I was in Minneapolis, my 18 year old daughter at
25  the time. And while I was talking to her, there was a call

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1  waiting. The person that they were staying with had call
2  waiting on their phone. Evidently Irene Williams was calling my
3  daughter at the Cookson's house and said that she needed to
4  speak with me urgently. So Jennifer got back on the line with
5  me and said "Irene Williams just called me and said she needs to
6  speak with you urgently." So I said okay.
7  I didn't know what it was about. I hadn't spoken to her for
8  a while. So I called her back to see what was going on. When I
9  called her back, it was the eve of my flight to the CHEO
10  convention. She said she thought I should tell the chairman of
11  CHEO that I was involved in an adulterous relationship and that
12  I was separated from my husband and that if I did not tell him,
13  that she would.
14  Q.  On this topic of telling the folks at CHEO about your
15  relationship with Rick Seelhoff, did you talk to Pastor Williams
16  about this at all?
17  A.  Yes.
18  Q.  Tell me about that conversation.
19  A.  I spoke with Pastor Williams. He did not agree with what
20  his wife was doing. He did not agree that it was right to
21  deliver this type of ultimatum, but she felt strongly about it.
22  And so they were in disagreement, but she felt that this was
23  what she wanted to do.
24  Q.  Did you have any conversations with Pastor Williams or his
25  wife as to why it was they were suggesting this to you? Did you

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1  mention the fact that you had withdrawn from the church at all
2  in any of these conversations?
3  A.  Yes, I did and we argued. I argued with Irene. I said I
4  did not believe she had any right to interfere with my trip to
5  Ohio, especially given the fact that I was no longer a member of
6  their church and not connected with the church in any way.
7  Q.  To your knowledge, did Joe Williams or Irene Williams ever
8  tell anybody at CHEO about your relationship with Rick Seelhoff?
9  A.  Not to my knowledge.
10  Q.  While you were at CHEO, did you have any other conversations
11  about this topic with anybody else about Rick Seelhoff?
12  A.  While I was at CHEO?
13  Q.  Yes.
14  A.  No.
15  Q.  You mentioned Gregg Harris of the Christian Life Workshop
16  was offering the men's keynote address. Did you have occasion
17  to talk to Gregg Harris at all at the CHEO convention?
18  A.  Yes.
19  Q.  Tell me about that. What did you talk with him about?
20  A.  Gregg Harris called me in my hotel room and asked me whether
21  I would have breakfast with him and I agreed. And we had
22  breakfast the morning before the keynote speeches, and it was a
23  very strange conversation.
24  I felt that someone had talked to him, had contacted him and
25  told him what had happened, but he did not admit to that. He