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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Western District of Washington
P.O. Box 1935
Tacoma, Washington 98401

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1  A.  Yes.
2  Q.  And those home schoolers are predominantly women; correct?
3  A.  The women are mostly the teachers in home schooling.
4  Q.  You sell The Teaching Home in book stores; correct?
5  A.  A few, yes.
6  Q.  And in 1994, you sold The Teaching Home in book stores?
7  A.  I believe so.
8  Q.  Now, for many years, you have offered trial issues of The
9  Teaching Home to potential subscribers, right, sort of courtesy
10  issues so they can check out the magazine before they decide to
11  subscribe; correct?
12  A.  Yes, it's called a trial subscription.
13  Q.  And you did that in 1994; is that right?
14  A.  Yes.
15  Q.  Mrs. Welch, the first you learned about Cheryl Lindsey's
16  relationship with Rick Seelhoff was in a message that you got
17  from Gregg Harris; right?
18  A.  A phone call, yes.
19  Q.  And Mr. Harris told you that he called Rick Seelhoff, that
20  he represented that he had found Rick's credit card at a hotel
21  in Ohio in an effort to get Rick to admit that, indeed, he was
22  in Ohio with Cheryl during the CHEO convention; correct?
23  A.  That sounds right.
24  Q.  And that was something Gregg Harris made up; correct?
25  A.  Yes.