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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P.O. Box 1935
Tacoma, Washington 98401

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1  testified to, at least the extent of Pastor Williams I believe
2  we are talking about.
3        MR. LACHENMEIER: Yes.
4       THE COURT: Let's just see if we can move it along. A
5  lot of things have been covered here I think sufficiently, but
6  let's move it along.
7       MR. LACHENMEIER: All right.
8  BY MR. LACHENMEIER:
9  Q.  What I really want to know is why did you feel compelled to get involved in this at all?
11  A.  Because we had recommended Cheryl in our publication and to
12  the state organizations that we had a working agreement with.
13  I also applied the "do unto others" rule. And I felt that I
14  put myself in their place, and I felt that if I were them and
15  had invited Cheryl to speak and then found out the situation,
16  and that I had known about it and hadn't said anything to them,
17  that I would be justifiably unhappy and feel that I had had a
18  responsibility to them, in light of what I just explained, to
19  let them know, and them to make their own decision whether this
20  mattered to them or not.
21  Q.  All right. Just briefly, in terms of your own religious
22  background, what does the Body of Christ mean to you?
23  A.  All believers, regardless of denomination or location.
24  Q.  In terms of a person with the ministry, the Body of Christ
25  impacted by that ministry would be whom?

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1      MS. DUFFY: Objection.
2      THE COURT: Counsel, why are we going into that? All
3  we know need to know here is her reason for doing what she did.
4      MR. LACHENMEIER: I thought she was going to be allowed
5  to testify why she did it.
6      THE COURT: Yes. That's what I am saying. She can
7  tell you why she did it. Now you want her to explain something
8  beyond that, it sounds to me.
9  BY MR. LACHENMEIER:
10  Q.  Let's go to the letter that the pastor testified that he
11  prepared for the church discipline. First of all, did you have
12  anything to do with the writing of the church discipline letter?
13  A.  No, I did not.
14  Q.  Counsel was referring you to portions of deposition with
15  some references to "I feel" or "I need",, something like that.
16  To the best of your recollection, did that relate to the
17  letter of discipline or the cover letter?
18  A.  I don't remember, but I do know for sure that I had nothing
19  to say about the letter of discipline, only the cover letter.
20  Q.  Why was it that you wanted -- did you want the cover letter
21  to come from the minister?
22  A.  Yes. I was attempting to remove myself so that I
23  wouldn't -- it was a church matter. According to Matthew 18, it
24  was their responsibility to tell the Body of Christ, tell the
25  church.

623

1  I did not want to have to answer any questions to anyone. I
2  wanted everything to be -- none of it to be hearsay through me.
3   I wanted everything to be verified from the proper source, which
4   I felt was Cheryl's pastor who had firsthand knowledge. And so
5  that's why I didn't even write the cover letter.
6  I don't know how -- how long an explanation I should give
7  here, so --
8  Q.  Let's talk about the cover letter and the letter. How was
9  it that there ended up being a tape?
10  A.  I don't remember for sure. Irene read that to me and I
11  played it for Michael Boutot.
12  Q.  Actually, I want to know mechanically how did there end up
13  to be a tape?
14  A.  Okay. At that time we had an answering machine that allowed
15  me to tape. Occasionally I would tape an interview. I think I
16  just did it two or three times. I taped an interview with --
17  for an article.
18  Q.  So you had the ability to tape phone conversations?
19  A.  Yes.
20  Q.  To help you with your publishing and editing and stuff like
21  that?
22  A.  Yes.
23  Q.  In this case, for whatever reason, you had her -- you taped
24  it?
25  A.   Yes.