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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419

1  So our card decks, if someone bought an ad in one of the
2  card decks they would reach over 200,000 families during the
3  year and each issue of the magazine goes to 75,000.
4  Q.  I want to call your attention again to the May/June issue of
5  The Teaching Home, that's the Michael Farris issue, the one
6  where he's on the cover. And take a look at the third page.
7  A.  There's two inserted pages here from an envelope, so what
8  page? Do you mean our table of contents?
9  Q.  No, it's the one beyond that.
10  A.  Our list of advertisers, our purpose, we believe?
11  Q.  It's that same page, but that's not what I want to focus on
12  here.
13  Are you with me, are you on that page?
14  A. Yes.
15  Q. On this page you list a directory of certain home schooling
16  organizations; is that right?
17  A. Well, I wouldn't call it a directory.
18  Q. How would you characterize that, Mrs. Welch?
19  A. These are the Christian state organizations with whom we had
20  a working agreement and who had a newsletter in the center of
21  the magazine that's under the heading State Newsletter Editors.
22  Q. This is in 1994, these were the organizations that you had
23  an arrangement with; correct?
24  A. If that's correct. I can't verify it with this, I have no
25  date on this page.

420

1  Q.  But the cover, though, is of May/June 1994?
2  A.  It's cut off of my copy. But I believe you, if that's what
3  it says.
4  Q.  I am sure your counsel would interject -
5  A.  I am not questioning you. I am just telling you.
6      THE COURT: Get to the question.
7  BY MS. DUFFY:
8  Q.  So in June of 1994, these were the home schooling
9  organizations that you were representing, that you had an
10  arrangement with; is that right?
11  A.  Yes.
12  Q.  Let's just take a look at some of them.
13  You have foreign newsletter editors in Australia; is that
14  right?
15  A.  We printed these newsletters. At that time we had no
16  working arrangements with foreign organizations.
17  Q.  You had that same sort of arrangement for an outfit in
18  Puerto Rico; is that correct?
19  A.  What same arrangement?
20  Q.  You didn't have a working agreement, but you published some
21  sort of -
22  A.  Puerto Rico might have been an exception, because it's not
23  exactly foreign. It was treated more like a state.
24  Q.  Okay. So you did have an arrangement with Puerto Rico?
25  A.  I would have to check my records to confirm, but we