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 2, 1998 Trial Volume 3

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 3 September 2, 1998 Pages 446-683


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Tacoma, Washington 98401

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1  Q.  At some point after that did you come to believe that?
2  A.  Yes, I did.
3  Q.  When was that?
4  A.  My recollection to the first time I was made aware of that
5  was on July 1, 1994, after our convention -- convention had
6   concluded.
7  Q.  Mr. Boutot, the court reporter has handed you what she's
8  marked as Exhibit 112 to your deposition and I'll just tell you,
9  these are documents that were produced to us by your counsel.
10  What I would like you to do is take a moment and read through
11  it, and I'm going to ask you a few questions about the documents
12  that have been marked as Exhibit 112.
13  I am going to ask you a few questions about it -- let me
14  just ask you this. Are all the pages of Exhibit 112 in your
15   handwriting?
16  A.  Yes, they are.
17  Q.  Tell me in general terms, Mr. Boutot, describe for me the
18  circumstances under which you put these handwritten notes
19   together?
20  A.  On July 1, we had received a call at home from Sue Welch
21  advising us of matters pertaining to Cheryl Lindsey, and because
22  of the information received, I felt it necessary to begin
23  documenting the matter, should the need arise for me to refer
24  back to discussions pertaining to this matter.
25  Q.  So is it fair to say that you put these notes together at or

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1  about the time that you were experiencing the events that they
2  refer to?
3  A.  Yes, ma'am.
4  Q.  Is it fair to say that these notes, Exhibit 112f are notes
5  of telephone conversations?
6  A.  Yes, ma'am.
7  Q. And were these notes of telephone conversations made
8  contemporaneous with the conversation?
9  A.  To the best of my recollection, yes.
10  Q.  So, in other words, while you were talking to an individual,
11  you were jotting down notes of the conversation during that
12  conversation, is that fair?
13  A.  With the exception of the last page on July 5, next to the
14  last page, 11:25, 1 simply documented a call from Cheryl's mom.
15  I noted "see separate notes," which was documented afterwards,
16  afterwards. I'm not sure how many days had gone by or if it was
17  days, but it was not contemporaneously with the discussion of
18  Cheryl's mother.
19  Q.  With that exception, the others were?
20  A.  The other notes were contemporaneous, yes.
21  Q.  These telephone notes, were these in a file of some short?
22  A.  Yes, ma'am.
23  Q.  What was the name of that file?
24  A.  On the tab I wrote Cheryl Lindsey or Cheryl and Claude
25  Lindsey, I believe.