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 September 1, 1998 Trial Volume 2

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 2 September 1, 1998 Pages 210-445


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Tacoma, Washington 98401

366

1  Q.  Were you present when she got back from the CHEO convention
2  and met again began with you and your husband?
3  A.  Yes.
4  Q.  There did your husband first ask her if she had had a --
if
5  Rick had been there with her at the CHEO convention?
6  A.  Joe spoke to her separately. I also asked her that at the
7  beginning.
8  Q.  What was her first response?
9  A.  No, that he wasn't there.
10  Q.  Then was she confronted with information that you knew he
11  was there?
12  A.Yes.
13  Q.  At that point did she finally admit to it?
14  A.  Yes.
15  Q.  Do you view confronting someone and then having them admit
16  to it to be a confession?
17  A.  No.
18  Q.  As part of the church discipline, is it normal to notify the
19  Body of Christ?
20      MS. DUFFY: Object to the form -- I object to the
21  relevance, Your Honor.
22      THE COURT: Counsel, tell me where we are going with
23  that?
24  Are we going to go through again whether or not she read
25  that letter to the congregation?

367

1      MR. LACHENMEIER: No. Whether she expected it to be
2  more widely distributed.
3      THE COURT: Well, that will speak for itself.
4  Why don't you get into the question as to what the testimony
5  has been, as to what she actually did and maybe the reason for
6  doing that. That may be more relevant here.
7      MR. LACHENMEIER: All right.
8  BY MR. LACHENMEIER:
9  Q.  What was your reason for providing that letter to Sue Welch
10  that talked about the letter of discipline?
11  A.  When we were asked to give a copy of the -- to send a copy
12  of the letter of church discipline to Sue and to Gregg and to
13  Michael, we had to make the decision whether to go ahead and
14  notify the Body of Christ.
15  And generally notifying the Body of Christ wouldn't be
16  warranted, but in Cheryl's situation, because she administered
17  publicly, we felt it was our moral obligation and duty to inform
18  the Body of Christ to whom she was accountable because she was a
19  public figure.
20  Q.  In terms of the discussions with my client about notifying
21  advertisers or subscribers, to the best of your knowledge
22  neither you nor my client notified advertisers or subscribers;
23  isn't that right?
24  A.  Well, I know we didn't. I don't know that Sue did or not.
25  Q.  Isn't it true that all my client asked to do was to notify