WHO IS 
BROTHER STAIR
 AND WHAT IS 
THE OVERCOMER MINISTRY?

HAVE YOU HEARD BROTHER STAIR ON THE RADIO OR INTERNET?

DO YOU WANT TO KNOW WHAT HE IS REALLY LIKE?

ON THIS SITE YOU WILL FIND TESTIMONIES, NEWSPAPER ARTICLES AND COURT RECORDS THAT WILL 
HELP YOU DECIDE WHETHER YOU SHOULD BE LISTENING AND FOLLOWING THIS MAN OR NOT
!

                                                     The truth about false prophet R. G. Stair

 (Mat 24:4 KJV)  And Jesus answered and said unto them, Take heed that no man deceive you.      
(Mat 24:5 KJV)  For many shall come in my name, saying, I am Christ; and shall deceive many.  

Sis. Pearl and I critiqued Mr. Stairs deposition for you.
I hope this helps. Our comments are in red.


IN THE COURT OF COMMON PLEAS
FOR THE STATE OF SOUTH CAROLINA
COLLETON COUNTY
 
DEPOSITION OF RALPH GORDON STAIR
 
  GLENDON ALLABY, KATHRYN ALLABY, CORA PFUND, ERIC
  PFUND, GREG LINDSEY, LARRY HARTLEY, MICHAEL DUVAL,
  KATHLEEN DUVAL, PEARL BUTLER, TIMOTHY BUTLER and
  KEVIN NEVIN,
   Plaintiffs,
       vs. CASE NO. 04-CP-15-382
  R.G. STAIR and FAITH CATHEDRAL FELLOWSHIP, INC.,
  a/k/a OVERCOMER MINISTRIES,
 
 Defendants.
  ____________________________________________________
 
 
 
  DEPONENT:      RALPH GORDON STAIR
  DATE:          December 4, 2006
  TIME:          9:00 a.m.
  LOCATION:      PETERS MURDAUGH PARKER ELTZROTH &
                    DETRICK, PA
                 123 Walter Street
                 Walterboro, SC  29488
 
 
  REPORTED BY:   NANCY ENNIS TIERNEY, CSR (IL)
                 CLARK & ASSOCIATES
                 P.O. Box 73129
                 North Charleston, SC  29415
                 (843) 762-6294
  
                 A P P E A R A N C E S
 
  FOR THE PLAINTIFFS:
 
                 PETERS, MURDAUGH, PARKER, ELTZROTH
                    & DETRICK, P.A. SMITH
                 BY: BERT GLENN UTSEY, III
                 123 Walter Street
                 Walterboro, SC  29488
                 (843) 549-9544
 
 
 
  FOR THE DEFENDANTS:
                 LAW OFFICES OF MATHIAS G. CHAPLIN, P.A.
                 BY: MATHIAS G. CHAPLIN
                 206 E. Washington Street
                 Walterboro, SC  29488
                 (843) 549-9330
 
 
                  I N D E X
                                               Page
  Witness Sworn                                 4
  EXAMINATION
       By Mr. Utsey                             4
       By Mr. Chaplin                         225
       By Mr. Utsey                           229
 
 
 
  Certificate of Reporter                     250
  Deponent Correction Sheet                   251
 
 
                 E X H I B I T S
 
                                               Page
 
  Plaintiffs' Exhibit Number 1                 77
  Plaintiffs' Exhibit Number 2                106
  Plaintiffs' Exhibit Number 3                117
  Plaintiffs' Exhibit Number 4                163
  Plaintiffs' Exhibit Number 5                189
  Plaintiffs' Exhibit Number 6                200
  Plaintiffs' Exhibit Number 7                204
  Plaintiffs' Exhibit Number 8                214
 
 
                  RALPH GORDON STAIR, having first
  duly affirmed, testified as hereinafter set forth.


                 EXAMINATION BY MR. UTSEY:


       Q.   Can you give me your full name, please?
       A.   Ralph Gordon Stair.
       Q.   Mr. Stair, we are going to take your
  deposition here today.  Have you ever provided a
  deposition before in any other cases?
       A.   Yes.
       Q.   On how many occasions?
       A.   One time.
       Q.   Do you generally understand how this
  process works?
       A.   Very well.
       Q.   I am going to go over a few points that
  I normally cover with folks before we begin.  You
  may know some or all of this, but I think it's
  helpful sometimes to tell people what to expect
  and how this process works.  It makes it go a
  little more smoothly and quickly, hopefully.
            I am going to ask you some questions,
  and you are going to give me answers to the best
  of your knowledge and to the best of your
  ability.  And, of course, your answers need to be
   truthful, as you affirmed you would do.
            The purpose here is for me to
  investigate, or what we lawyers call discover,
  different parts of this case.
            Under our laws, I can't talk to you
  except for two occasions, one is here in the
  deposition with your attorney present and the
  other is if we go to trial and you are on the
  witness stand.
            So it's important for me to take this
  time to understand the knowledge you have about
  these cases and to investigate the case from that
  perspective.
       A.   All right.
       Q.   I explain that to you now so that you
  will understand I'm not taking your deposition for
  any other purpose, and particularly not for any
  improper type purpose.  I am not just here out of
  curiosity to delve into your private life, for
  example.
            I'm not here to try to ask what I would
  characterize as trick questions or try to get you
  to say something that is not accurate.  It doesn't
  do me any good and it doesn't do you any good.
  It's simply an investigation tool.
             And I also give that introduction so
  that you will know that if I ask you a question
  that you find to be confusing, or one that you
  would rather me rephrase or repeat before you
  answer it, please let me know and I will be happy
  to do that.
            Because it's not my intention to try and
  confuse you with questions, but I know that we
  lawyers sometimes will talk too much and make what
  could otherwise be a simple question more
  complicated than it needs to be.
            A couple of ground rules that will help
  with ensuring that your testimony is recorded
  accurately and transcribed accurately when our
  court reporter prepares the transcript.
            It's difficult for her to type two
  people speaking at the same time, and so it will
  be important for me to wait until you finish your
  answer before I ask you a question and for you to
  wait for me to finish asking a question before you
  begin answering it.
            Now, in my experience I will probably
  ask you a question before you are finished
  answering, and you will probably answer a question
  before I'm finished asking.
             If that happens, you stop me or I will
  stop you.  I want you to understand it's not
  because I'm being rude if I do that.  It's because
  I want to make sure that everything is accurate on
  the record.
            Fair enough?
       A.   Sure.
       Q.   Another thing is if you and I were just
  talking on the street, we might have a
  conversation where one of us shakes or nods our
  head or says uh-huh or huh-huh, or something like
  that, that might not be entirely clear if it were
  transcribed.
            So in response to a question, if your
  answer is yes or no, you need to say yes or no
  rather than shaking your head.  And if you forget
  to do that, I might remind you.  Again, it's not
  because I'm trying to be rude.  It's just because
  I want to make sure that your testimony is
  accurate for the record.
       A.   Sure.  Yes.
       Q.   If you need to take a break at any time
  during the deposition, let me know, a rest room
  break, coffee break, whatever, and I will be happy
  to accommodate you.
             I will tell you that under our rules, if
  you have any conversations with anyone during a
  break, including with your attorney, that when we
  resume I'm entitled to ask you about the
  conversations, even if those conversations might
  otherwise be attorney-client privileged.
            Under our rules, once a deposition
  starts, then the witness is sort of on his own as
  far as what he's going to say and testify and
  can't get assistance from his attorney unless it's
  with respect to a question of whether to claim
  attorney-client privilege to a particular
  question.
            Do you feel like you understand that?
       A.   Oh, yes.
       Q.   If you have any questions about the
  deposition itself, or about the process that we
  are using here, I will need for you to address
  those questions to me and I will do my best to
  answer those before we go on.
            Fair enough?
       A.   Uh-huh.
       Q.   Any other questions that you have before
  we get started?
        A.   Not that I know of.
        Q.   Are you feeling well enough to give your
  deposition today?
       A.   Oh, yes.
       Q.   Are you taking any medication or under
  the influence of anything that would affect your
  ability to hear, understand and respond truthfully
  to my questions here today?
       A.   No.
       Q.   Let me get some background information
  on you.
            What is your date of birth?
       A.   3rd of May, '33.
       Q.   Have you ever gone by any other names?
       A.   No.  Brother Stair.
       Q.   Okay.  Well, I understand, yeah, title.
       A.   No.
       Q.   Are you married?
       A.   Yes.
       Q.   And your wife's name?
       A.   Teresa Grace.
       Q.   Is Grace her maiden name or is that a
  middle name?
       A.   That's her middle name.  Her maiden name
  is Erconolino.
       Q.   Can you spell that?  I'm putting you on
   the spot, I know.
       A.   I'm sorry.  I don't know if I can do
  that or not.  E-c -- Erco -- E-r-c-o-n-o-l-i-n-o,
  somewhere like that.
            MR. CHAPLIN:  You can clarify it later
  today.
       Q.   How long have you-all been married?
       A.   I think about 25 years.  I'm not sure of
  the exact date.
       Q.   Is that your only marriage?
       A.   No.
       Q.   Who was your previous marriage to?
       A.   Jeraldine -- let's see.  What is her
  name?  It's been so long.  I remember her middle
  name.
       Q.   That's okay.  What was her maiden name?
       A.   Hilbert, H-i-l-b-e-r-t.
            MR. CHAPLIN:  I apologize.  I am going
  to ask you just to give me one second here and put
  this fire out because it's involving a judge, and
  then I won't have to bother you anymore.  It will
  just take two minutes.
            MR. UTSEY:  Sure.
             (A recess was taken.)
       Q.   Before we took a break you were telling
   me about the fact that you were previously married
  to Jeraldine Hilbert?
       A.   Yes.
       Q.   And that marriage ended how?  Did she
  pass away or did you-all get divorced or what?
       A.   No.  She just divorced me.
       Q.   And approximately when was that?
       A.   Well, like I say, about 25, 30 years
  ago, something like that.
       Q.   Oh, okay.  And in what state was that?
       A.   That was in Georgia.
       Q.   Do you remember what county?
       A.   No.
       Q.   And what were the grounds for divorce?
       A.   There wasn't any.  She just divorced.
       Q.   It wasn't as if anybody accused anybody
  of any wrongdoing or anything?
       A.   No.
       Q.   Fair enough.  Are those your only two
  marriages, or did you have any marriages before
  that?
       A.   That's it.
       Q.   Any children?
       A.   Yeah.  I have five from the first wife
  and one from the second.
        Q.   Let me get their names and ages, please.
       A.   Oh, man.  You are asking me questions
  that I don't know if I can give you the answers
  to.
       Q.   I thought these were the layups.
       A.   Well, I don't know how old each one of
  them are.
       Q.   Give me -- I assume they are all over
  the age of 18 if you had been married to her 25 --
       A.   Definitely.  All of my children from her
  are -- the oldest is probably at least 50s and
  then down to 40s.  Probably the youngest one is
  somewhere, I would say, in his 30s.
            And then I have a young daughter with my
  second wife, and she is 20.
       Q.   What is her name?
       A.   Naomi.  Her last name is Bowles,
  B-o-w-l-e-s.  She is married now.
       Q.   Where does she live?
       A.   Up near Columbia.
       Q.   Do any of your children live in Colleton
  County?
       A.   No.
       Q.   Other than your wife, do you have any
  other relatives who reside in Colleton County?
        A.   No.
       Q.   How about any relatives through your
  wife's side of her family?
       A.   No.
       Q.   Where is your wife from originally?
       A.   New Jersey.
       Q.   How long have you been in the Colleton
  County area?
       A.   At least 25, 30 years.  Almost 30 years
  I would say, 25 for sure.
       Q.   Before that where were you?
       A.   I lived in Savannah for awhile, and I
  pastored a church in New York and one in Boston.
       Q.   Where are you from originally?
       A.   Bethlehem, Pennsylvania.
       Q.   When did you leave that area?
       A.   Oh, many years ago.  I would say at
  least 40 years ago, maybe longer than that.
       Q.   So the states you have lived in include
  Pennsylvania, South Carolina, New York, Georgia?
       A.   I lived in Georgia.  I lived in Alabama
  for a long time years ago when I first started to
  pastor.
       Q.   Any others?
       A.   Where I lived?
        Q.   Yes, sir.
       A.   I lived in California for awhile.
       Q.   Anywhere else?
       A.   Of course, you know, for many years I
  was a traveling evangelist so I was in a lot of
  states, and I would sometimes stay in those states
  for who knows how long, as far as living.  I can't
  say I lived in most of them, no.
       Q.   I guess I'm looking more for your
  residence rather than --
       A.   I would say Georgia, Alabama, New York
  and California would be the states I lived in.
       Q.   And then when you were doing this
  out-of-town evangelism, how long would you stay if
  you said you had a protracted stay?
       A.   Sometimes months and sometimes weeks.
       Q.   Now, the case here is pending in
  Colleton County, and one of the things that the
  lawyers for both sides will do is to try and make
  sure that we have a jury that doesn't have any
  connections to either the plaintiffs or the
  defendants in the case.
            That is why I asked you about your
  relatives that may be in the county.  But also,
  obviously, I would also like to understand who are
   members of your congregation or your ministry?
       A.   We don't have any membership.
       Q.   Do you have folks that associate
  themselves with -- am I using the term correctly
  to say congregation, or do you call it fellowship
  or --
       A.   We have people who come to our meetings,
  yes, but they are not members.  They just attend
  our services, and that could be some from here,
  some from locally.  People drive in from various
  areas.
       Q.   Do you have folks who live on the
  grounds?
       A.   Sure.
       Q.   Are there any lists of such people that
  can be produced?
       A.   Oh, yes.
       Q.   So is it fair to say that if we were
  preparing to try this case, if we get to that
  point, I could get a list from Mr. Chaplin just to
  make sure I could compare that against the
  prospective jury list?
       A.   Correct.
       Q.   All right.  What would I call that list
  if I was to ask for it?
        A.   I guess the residents of the Overcomer
  community.  Of course, they don't all live with
  me.  There are other people in the area.
       Q.   Who attend services?
       A.   Yes.
       Q.   Do you maintain a list of donors?  Say
  someone doesn't live on the community but they
  donate money?
       A.   Yes.  We have people who donate money.
  We have a list of every one of them, sure, but I
  don't know if I could give you that list.
            MR. CHAPLIN:  I think we provided
  something in discovery already with regards to all
  of the different plaintiffs.
            MR. UTSEY:  Right, but I'm looking more
  in terms of selecting a jury.
            MR. CHAPLIN:  Selecting a jury.  Okay.
       A.   You are talking about somebody in the
  area that could be potential jurors?
            MR. CHAPLIN:  Somebody that might have
  donated money so that he could actually --
       Q.   Yeah.  Hypothetically, I guess a jury
  list has 150 names on it.  If one person buried in
  that 150 names is someone who regularly attends
  and donates --
        A.   That wouldn't be a problem.
       Q.   -- I want to know that.
            MR. CHAPLIN:  On voir dire, wouldn't
  they have to answer that, though, if they ever
  donated?
            MR. UTSEY:  In my experience, not
  everybody answers those questions accurately.  And
  that's not always intentional.  I mean, I think
  sometimes they get confused or don't know what
  they should answer.  But there is always some --
       A.   If I understand your question correctly,
  you are wanting to know anybody in this general
  area that could be a potential juror?
       Q.   Who has a relationship with you.
       A.   Right.  That isn't no problem.
       Q.   Okay.  If you-all want to do the same
  thing with the people that might have a
  relationship with my clients, we will give you
  that, too.
       A.   Sure.
       Q.   Easy enough.  Let me get some more
  background information on you, Mr. Stair.  How far
  did you go in terms of formal education?
       A.   I went to 10th grade.
       Q.   Where was that?
        A.   In Bethlehem, Pennsylvania.
       Q.   What school is that?
       A.   Bethlehem High School.  That is the last
  one I attended.
       Q.   Did you get a GED after that or any
  other formal education?
       A.   No.  I took Bible study courses and
  things like that from various religious
  organizations, but I never --
       Q.   Did you ever serve in the military?
       A.   No.
       Q.   Tell me about your religious training,
  your Bible study courses or however you want to
  characterize it.
       A.   Well, you just took Bible study courses
  that they had, theological, doctrines and things
  like that.  That is what they were.
       Q.   Are these formal courses of study?
       A.   Yes.  Sure.
       Q.   And when you finish those do you get
  some sort of certificate of completion or degree?
       A.   They would just give you a little
  certificate of completion.
       Q.   Give me some idea of what those
  involved, or which one of those you have done.
        A.   Well, I took a course with the Free
  Methodist Church.  That is back when I was 17, 18
  years of age.  I have never had any theological
  biblical school things.
            I started preaching when I was 16, and
  my preaching, my manner of life, was under the
  auspices of different churches where you would run
  this -- they would call you an exhorter, or
  something like that, and you would practice your
  ministry.
            And they would then approve of you,
  whether you were a pastor or not.  I joined maybe
  four or five churches over the years, but most of
  the time I just preached.
       Q.   I don't have a lot of experience with
  the structure or lack of structure that is
  associated with that, so some of my questions may
  sound like they are uninformed, and that is
  because they are, so help me in understanding
  this.
            First of all, in terms of certificates
  of completion --
       A.   I don't have any.
       Q.   You don't have any of those?
       A.   No.
        Q.   You said that some churches have
  recognized you as a pastor or --
       A.   Well, you would start out -- when I
  first started out, I started out in what they
  called at that time was the Holiness Christian
  Church, and then I went to the Free Methodist
  Church, and each one of these churches would have
  steps of degree of preaching.
            First they would give you what they call
  an exhorter's license, and then you would operate
  under that for a year or two.  And then if you met
  their qualifications they would advance you to
  another license.  And eventually you would get
  ordained.  That was a lot of different
  organizations that I worked in because I was a
  traveling evangelist, and I would work with a lot
  of them.
       Q.   Were you ordained in any of those
  churches?
       A.   No.
       Q.   What would have been the highest level
  that you attained within --
       A.   A licensed preacher, a licensed pastor
  or licensed evangelist.
       Q.   When I hear the term license, that
   suggests --
       A.   They would give you a license that they
  recognized as a pastor or an evangelist in their
  group.
       Q.   A license being issued by that group?
       A.   Right.
       Q.   As opposed to some sort of state agency
  or something like that?
       A.   Right.
       Q.   Have any of those licenses -- or any of
  your licenses with any of those churches ever been
  revoked or rescinded?
       A.   No.
       Q.   With which different churches have you
  been associated where you have been --
       A.   The only one I can think about that
  would --
            MR. CHAPLIN:  Let him finish the
  question.
       Q.   I think you understand where I'm going.
  I am just trying to find out in which churches
  have you been acknowledged to have attained some
  level as a pastor or a minister?
       A.   The only two that I can -- or three of
  them.  There is three of them.  One was the Free
   Methodist Church.  That is very many years ago.
  Then another group, which it's a very small group,
  called the German Eldership Church of God, and
  that was a small group in Pennsylvania.  And then
  for several years I was licensed with the Assembly
  of God.
            The others are -- in the course of time,
  you know, we became an official organized church
  ourself with federal recognition.  So we have
  ability to ordain our own preachers or license our
  own preachers.
       Q.   You are talking about current church?
       A.   Yes, which has been in existence for 25
  years at least, or maybe 30.
       Q.   Well, I am going to talk about that, but
  I just want to make sure I have covered all of the
  territory in between when you began preaching and
  up until the point which you formed Overcomer
  Ministries.
            Have we done that?
       A.   Yes, pretty well.  I mean, like I say,
  up until I came here and organized this church
  group here, we started in New York and then moved
  out of New York, came here and transferred here,
  and we organized it here, and we got the federal
   recognition and we got the organizational
  structure.
            And from that point on -- but prior to
  that I was just mostly a traveling evangelist.  I
  did pastor a few churches.  I pastored one in
  Alabama.  That is another one.  That one I was
  licensed by.  I pastored there for five years.
       Q.   What was that called?
       A.   That was called the Full Gospel Church
  of God.
       Q.   Okay.  Now, how long was it that you
  were doing the traveling evangelism?
       A.   I would say I traveled even after I came
  here.  I stopped the traveling about four or five
  years ago when I was pretty well tied up here with
  the work I was doing here.  But even when I came
  here I would travel almost every month somewhere
  preaching.
       Q.   Was there a period before you began the
  Overcomer Ministries that you were a traveling
  evangelist, as you described it earlier, where you
  made –

Stair failed to mention that he worked for different Evangelists. He set up tents, led singing and took care of the money. Stair used to say he was schooled for the work he is doing now from working for these men then go on and tell how he would take suite cases full of money to the Caymen Islands to put in the bank there or after one had spent all the money on gambling on Horse races instruct Stair to raise more the next service.

       A.   I would do both.  I would pastor
  churches and travel at the same time.  I had a
  church for many years in Savannah, Savannah,
   Georgia, and then I would travel.  But I would
  have revivals, too.  So I was always either
  pastoring or in the course of having meetings.
       Q.   And when you were traveling and having
  these revival meetings, was that under the
  auspices of the church with which you were
  affiliated at the time?
       A.   Yes.
       Q.   Not independent of that church?
       A.   No.  The church -- for instance, the
  church we had in Savannah, it was affiliated with
  Full Gospel Churches and Ministries International,
  which was an independent group of churches, and
  that is where we had our affiliation then.
       Q.   And when you would travel, was it like
  the old-time tent revivals?
       A.   Tent revivals, church revivals, street
  meetings, jail services.
       Q.   And let's talk -- if I call it Overcomer
  Ministries, is that the easiest way to describe
  it?
       A.   Sure.
       Q.   The full official name of Overcomer
  Ministries, though, is what?
       A.   Faith Cathedral Fellowship.
        Q.   How long has it been named Faith
  Cathedral?
       A.   Oh, at least 25 years.
       Q.   It has always had the same name?
       A.   Yes.
       Q.   As I understand it, that is a
  corporation and that is the official name of the
  ministry?
       A.   Yes.
       Q.   But Overcomer Ministries is the
  day-to-day name that most people refer to it as,
  that you refer to it as?
       A.   Well, that is the way we refer to it,
  yes, because that is the outreach of Faith
  Cathedral Fellowship.
       Q.   When was Faith Cathedral Fellowship
  incorporated?
       A.   I don't have the exact date.  Like I
  say, it's been 25 years.  Paul Siegel did it.  He
  did it for us and did a good job.
       Q.   So it would have been -- you mentioned
  something about being in New York and then moving
  here, but it would have been after you were inside
  Carolina that you had it --
       A.   No.  I had a church in New York and
   Boston, and I also had a church at that time in
  Savannah.  I was pastoring those three churches
  and I would come back and forth.
            And then I felt impressed to buy some
  land, and so I came here and I bought some land
  and then I moved here.  When I moved here, then we
  moved our -- we had already started to file for a
  church organization in New York.  We just about
  had it done.
            But then when we came here, we just
  transferred it down here instead of up there.  We
  did it here.  And that is when Faith Cathedral
  became an official federally-recognized authorized
  church.
       Q.   There are several steps, and that is
  what I'm trying to break down.  The first would
  have been getting a state to grant a charter of
  incorporation?
       A.   Right.
       Q.   That would have been in the state of
  South Carolina?
       A.   Yes.
       Q.   And we should be able to determine that
  from the Secretary of State?
       A.   I can go get it.  I have it at home.
        Q.   Because you weren't sure on the date, is
  why I asked.
       A.   No.  I would have to go look at the
  date.
       Q.   But you said Paul Siegel did the
  incorporation?
       A.   Yes.
       Q.   Did he also assist you with any other
  legal aspects of forming --
       A.   He then got us -- he set up the
  incorporation, the board, and the bylaws and
  everything that is required to be recognized by
  the state, and then he filed and got us the
  federal recognition.
       Q.   The 501(c)3?
       A.   Right.
       Q.   Where was Paul working at that time; do
  you remember?  Was he in a law firm?
       A.   Across the street, wasn't he?
       Q.   Was that with Smoak and Moody and --
       A.   Yes.
       Q.   So has Faith Cathedral Fellowship
  enjoyed 501(c)3 status continuously since that
  time?
       A.   Yes.
        Q.   So that would be approximately, again,
  25 years?
       A.   25 years, yes.  I would have to get the
  exact date.
       Q.   What was involved in attaining that
  status?
       A.   Nothing particularly that I know of,
  just applying for it and getting it.
       Q.   Do you remember what the application
  process involved?
       A.   No.
       Q.   Are there ongoing reporting requirements
  associated with that status?
       A.   No.
       Q.   In other words, do you have to make
  filings on an annual basis, for example?
       A.   Not on that one.  We are not a nonprofit
  organization per se.  We are a religious
  organization, and religious organizations do not
  have to file reports.
       Q.   So other than attaining that 501(c)3
  status approximately 25 years ago, have you had
  any communications with the Internal Revenue
  Service concerning that status since then?
       A.   No, because we have met the
   requirements.  We still do.
       Q.   That is what I'm wondering, whether they
  monitor that to make sure that you are still doing
  what you began doing and that kind of thing.  Do
  they?
       A.   Well, if you go outside of it -- there
  is three things they require you to do.  They
  require you to have church services, they require
  you to be benevolent, and they require you to have
  an education process, and we do all three of
  those.

What is the education process? There is no formal education of ministers or Sunday School
Even there home schooling don’t meet all the requirements of the state or local authorities.


       Q.   I am just curious whether you hear from
  them periodically to make sure you are still doing
  those things?
       A.   One time they checked us out, and then
  they found out that we were still doing it and --
       Q.   And they left you alone?
       A.   Sure.
       Q.   When was that?
       A.   1988.
       Q.   And who contacted you at that point?
       A.   They just informed us that our status
  was in question.  And they contacted Paul, and
  Paul went back and whatever they had to do and had
  it validated.
        Q.   Were those IRS agents that contacted
  you?
       A.   They didn't contact me.  They informed
  me that we were under -- they inquired about our
  status, and I took it to Paul, and Paul followed
  through on our status and they reinstated us.
  Well, they didn't reinstate us.  They didn't take
  it away from us.
       Q.   I'm just trying to determine who made
  the contact.
       A.   It was the IRS and it was the state
  officials.
       Q.   State of South Carolina also made that
  inquiry?
       A.   As far as I know.  It didn't last very
  long.
       Q.   But I'm curious whether you know if it
  was out of the Charleston office or the Columbia
  office or --
       A.   I have no idea.
       Q.   Now, do you have a similar status with
  respect to the State Department of Revenue?
       A.   We have nothing to do with the State
  Department of Revenue.  We don't have to do
  anything with them at all.
        Q.   Is that because they have given you a
  status like a 501(c)3 status, or do they
  acknowledge the federal, or how does that work?
       A.   They just don't require anything.  There
  is no reporting or anything because we are a
  church organization and we operate as a church
  organization.
       Q.   Since you have created -- or since you
  created Faith Cathedral Fellowship approximately
  25 years ago, have you operated any other
  churches?
A.  No.

There is a church location out in Henrietta Oklahoma called grace community that is listed as an outreach of Faith Cathedral Fellowship.

       Q.   Have you operated any other businesses?
       A.   No.
       Q.   Have you had any other source of income
  personally since then other than through --
       A.   No.
       Q.   -- the Faith Cathedral Fellowship?
       A.   No.  I haven't taken any income from
  Faith Cathedral Fellowship, if you are talking
  about personally.  Are you talking about me
  personally?
       Q.   Yes, sir.
       A.   No.  I haven't had any income at all,
  and that has been checked by the IRS themselves.
   They came out here and asked me about that,
  checked me out.
       Q.   When was that?
       A.   1988.
            MR. CHAPLIN:  Skip, can you give me a
  second?  I need to confer with my client just one
  minute, if you don't mind.
            MR. UTSEY:  Well, I have already told
  him that under the rules if you-all confer I can
  question him about your conference.
            MR. CHAPLIN:  Okay.  That's fine.  Can I
  just say something to him in front of you?
            MR. UTSEY:  Yes.
            MR. CHAPLIN:  Please listen to the form
  of the question and just answer the question.
            THE WITNESS:  Okay.
       Q.   Was that the same time that the IRS
  contacted Paul or you about the status of Faith
  Cathedral Fellowship that they also contacted you
  about your personal income?
       A.   It was in the general same time, yes.
       Q.   And was that the Federal IRS?
       A.   Yes.
       Q.   Did it also involve the State Department
  of Revenue?
        A.   No.
       Q.   And did Paul deal with that issue as
  well?
       A.   All I know is they came to see me.
       Q.   Oh, okay.  You actually got an in-person
  visit?
       A.   Yes.
       Q.   And who was it?
       A.   They sent two agents out, two IRS
  agents, and they asked me a simple question.
       Q.   What was that?
       A.   How come you don't pay no income tax.
       Q.   And did that resolve the issue?
       A.   Yes.
       Q.   Is that the only time that they made any
  such inquiry of you?
       A.   Yes.
       Q.   Do you have an accountant for the
  fellowship?
       A.   Just my wife.  She is our accountant.
       Q.   Is she actually an accountant or a
  bookkeeper or what?
       A.   She is very good at it.
       Q.   Well, does she have any formal training,
  I guess is what I'm --
        A.   No.
       Q.   How long has she been in that position
  of accountant or bookkeeper?
       A.   Ever since we were married.
       Q.   So the entire life of Faith Cathedral
  Fellowship, has she been the person that has
  handled that end of it?
       A.   Yes.
       Q.   Does she have an official title with
  Faith Cathedral Fellowship?
       A.   No.  She is a vice president of the
  corporation.
       Q.   That is kind of what I'm driving at.
  Who is the treasurer of the corporation?
       A.   I would say she is the treasurer, yes.
       Q.   Has there ever been anyone else who has
  handled the books of Faith Cathedral Fellowship
  other than Teresa?
       A.   No.
       Q.   Have the books ever been subject to any
  sort of external audit by an accounting firm or
  otherwise?
       A.   No.
       Q.   Have you ever used a CPA firm or any
  other outside accountant with respect to Faith
   Cathedral Fellowship?
       A.   No.
       Q.   Help me with the understanding of the
  officers, the current officers and directors of
  Faith Cathedral Fellowship.  Are you the
  president?
       A.   I am the president, and the vice
  president, and we have a chairman of the board and
  we have -- I forget how many board members there
  are, seven or eight.
       Q.   Let's talk about the officers first.
  You said you are the president and you believe
  Teresa is the vice president?
       A.   Yes.
       Q.   And also the treasurer?
       A.   Yes.
       Q.   Does the corporation have a secretary,
  to your knowledge?
       A.   Yes.
       Q.   Who is that?
A.  Margaret Moratto.

Margaret Maratto passed away a couple of weeks ago

       Q.   I saw her name in some of the answers to
  interrogatories and whatnot, but I wasn't clear on
  whether she was a secretary in the sense that she
  was an employee who did secretarial functions or
   whether she was a corporate officer secretary?
       A.   She is just a corporate officer.  We
  don't have any employees.
       Q.   And what are her job -- or what are her
  responsibilities, rather, as a corporate
  secretary?
       A.   She just stays in the office.  She
  answers the phones.  She helps with the mail.  She
  takes the minutes in special meetings that we
  have, like secretaries do.
       Q.   Does she maintain official corporate
  records such as minutes of annual meetings,
  resolutions, that sort of thing?
       A.   Yes.
       Q.   How long has Margaret Moratto been in
  the position of secretary?
       A.   20 years, at least.
       Q.   And since she became secretary, has
  anyone else functioned in that office?
       A.   No.


At different times sisters would help Margaret Moratto in the office.  I was one of them. I helped Margaret with filling the request that came in from listeners, mailing out the newsletters, stuffing envelopes, transcribing listeners address that was left on the answering machine, just to name a few things.

       Q.   Have you always been the president of
  the corporation?
       A.   Yes.
       Q.   And has Teresa always been the vice
  president?
        A.   Yes.
       Q.   Are there any other corporate officers
  aside from -- we will talk about the board of
  directors in a minute.
       A.   Just the board.
       Q.   Let's talk about the board of directors.
  Who is the chairman of the board?
       A.   Chris Gingrich.
       Q.   Can you spell his last name?
       A.   G-r-i-n-r-i-c-k (sic).
            MR. CHAPLIN:  Say it one more time.
            THE WITNESS:  Chris Gingrich,
  G-r-i-n-r-i-c-k (sic).
       Q.   I have seen the name Brother
  Christopher.  Is that the same person?
       A.   No.
       Q.   How long has Chris Gingrich been the
  chairman of the board?
       A.   Ever since we started.
       Q.   And he resides where?
A.  He resides over in Bamberg County.
       Q.   Who are the other members of the board?
       A.   Dave Moratto, Timothy Jones, Rick Bell.
  I have to think for a minute.  That is four.
  Christopher is not on that, right?

Rick Bell moved to the farm just before we did in 1998. As of the time we left in Aug. 2001 there had never been a board meeting of any kind or an adding of Rick Bell as an officer.


        Q.   Are you a member?
       A.   Yeah.  I'm a member, and my wife is a
  member, and the secretary is a member.
       Q.   Margaret?
       A.   Yes.
            MR. CHAPLIN:  Moratto.
       Q.   Is Dave Moratto Margaret's husband?
       A.   Yes.
       Q.   That is seven.  Is that everybody?
       A.   I can't think of any more right now.
       Q.   Is there anyone who has ever been a
  member of the board who is no longer a member of
  the board?
       A.   Not that I know of, no.
       Q.   Have all of the current members of the
  board always been members of the board since --
       A.   Yes, yes.
       Q.   -- the fellowship was founded?
       A.   Well, no.  Some of them came -- when we
  first started we didn't have a full board.  And
  then as time went on we got the board membership.
  Under the original charter it was just me and my
  wife, but then we got the board later on as we
  grew.

Mr. Stair said one time that the board members didn’t even know they were board members and he would never say who was on the board.
Mr. Stair told us in the dinning hall that he has never had a board meeting that he would just make up the minutes if he was ever questioned about them. 

       Q.   I understand.  What is the function of
   the board of directors?
       A.   We report to them on what we are doing,
  why we are doing it, and what our purpose of the
  ministry is all about.
       Q.   And other than receiving these reports,
  does the board of directors do anything with
  respect to the Faith Cathedral Fellowship?
       A.   Whatever needs to be done.
       Q.   Give me an example.
       A.   Well, right now I don't know what answer
  you are looking for because the board, they can
  discipline me, which they did.  They have
  disciplined me in the past, or they question me.
  I have to give an account of what I'm doing.  They
  know how we operate and what our functions are.
       Q.   Help me understand the structure of
  Faith Cathedral Fellowship.  I mean, I understand
  that you have the officers that we have just
  discussed and the board of directors.
            And, again, this is a question of total
  ignorance as far as how this church is organized.
  I can have a preconceived notion because of the
  church I have always attended is set up one way
  and yours is probably different, so I don't know
  how to compare them.
             Are there employees at all?
       A.   No.
       Q.   No employees.  Is there a church
  discipline, or is there some structure within the
  church as far as who is the head of the church?
       A.   We have the bylaws, the church bylaws
  that have been incorporated, and we function by
  the bylaws.

No one who lived there knows of any bylaws…we didn’t!
No one dare confront Stair about anything he has done, let alone discipline him.  He controls the people living there and they are all afraid of him for one reason or another. Just ask anyone that has lived there why there were afraid of Stair.  And how many hours of preaching the community received because they confronted Stair or did something Stair didn’t like.


       Q.   Are those the corporate bylaws or are
  they different?
       A.   Corporate bylaws.
       Q.   Other than that, is there any sort of
  text which deals with how the church is organized
  and operated?
       A.   Only according to the Bible.  We use the
  scriptures through our discipline.
       Q.   So the head of the church under your
  bylaws is whom?  And I'm not talking about God.  I
  am just saying the head of it.
       A.   I am the president of the corporation.
       Q.   And how does that translate into terms
  of your role as minister or pastor, if at all?
       A.   I just pastor, preach.
            MR. CHAPLIN:  Do you understand the
  question?
             THE WITNESS:  Not quite, no.  I mean, I
  am the head of the organization.
            MR. CHAPLIN:  Let him rephrase it.
       Q.   I understand the corporate organization
  and your role as president, but I also
  understand -- and we haven't really talked about
  it -- but I also understand that you preach?
       A.   Well, in the religious source you have
  spiritual leaders, too.  You have men who are
  elders in the church.
       Q.   Well, that is the structure that I'm --
       A.   Well, most of those men are elders just
  like they are the board of directors.  They are
  our leaders of the church.  They are what we call
  the governing body.
            Of course, that is in the spiritual
  realm.  We recognize them as what they are, and we
  use their advice and we call them in for judgments
  and decisions.
       Q.   Is that the same as the board of
  directors, or are there different people that
  comprise the --
       A.   Well, some are the board of directors.
  There are others who are not.  Like Christopher,
  who you are going to see this afternoon, he's not
   on the board of directors, but he is definitely
  one of our elders.
       Q.   Okay.  Well, that is what I am trying to
  drive at.
       A.   We have -- all the men on the board are
  what we call also spiritual leaders, and they help
  make the judgments that need to be done in the
  church.
       Q.   The spiritual leaders, is that the same
  as elders?
       A.   Elders are deacons.  Most churches have
  elders or deacons.  But we don't give those
  offices, but we just recognize them as men who are
  spiritual in that position.
       Q.   So if I use the term spiritual leaders,
  that would be that category of people -- I want to
  use the right term.  You used the term elders, and
  I didn't know if you were just using it in the
  colloquial sense or whether it's specific to your
  fellowship.
       A.   First of all, we don't have a membership
  type of anything, so our men are recognized among
  us by virtue of being there.  These are men that
  have been around who put their life into it, for
  instance Chris Gingrich, for 30 years.
        Q.   Are they elected to these positions?
       A.   No.  We don't elect them.
       Q.   How does someone become a spiritual
  leader?
       A.   By recognition, by being faithful.  You
  just abide by the --
       Q.   Who are the spiritual leaders?
       A.   I mentioned them to you.  Most of them
  are the board of directors.
       Q.   But are there others?  You said, for
  instance --
       A.   I just mentioned also Christopher
  Landry.  He's a spiritual leader.
       Q.   That is Brother Christopher?
       A.   Yes.
       Q.   What is his last name?
       A.   Landry.
       Q.   Anyone else?
            MR. CHAPLIN:  Excuse me.  Can you find a
  breaking point?  I want to try to call Judge James
  Mack at some point.
            MR. UTSEY:  Sure.  Let me just get this
  list.
       Q.   Is there anyone else who is among this
  group of spiritual leaders whose names we haven't
   already discussed as the board of directors?
       A.   Yes.
       Q.   Who else?
       A.   Joe Klein would be one of them.  Of
  course we have Pastor Timothy already.  How many
  do I have up there?  Jonathan Keiser would be one
  of them.  Al, I don't know his last name.
            MR. CHAPLIN:  Do the best you can.
       A.   Dennis Larivee would be one of them.
       Q.   Can you spell his last name?
       A.   L-a-r-v-i-e (sic).
       Q.   Are there others?
       A.   We have a community up here with about
  70 some people, 70 some.  Let me see.  And we
  honor each other as brothers and give each other
  credibility as they live among us.  I guess you
  could call them all spiritual leaders if you
  wanted to.
       Q.   Right.  I am not calling anybody
  anything.  You used the term spiritual leaders, so
  I was trying to make sure I understood who you
  were talking about.
       A.   We don't operate in a realm of picking
  out somebody and saying -- if you are a man and he
  works and he's faithful and he's a brother, we
   respect his opinion, we respect his judgment, and
  we respect his -- they have all put their life
  into this, just like I put mine into it, and they
  all have an accountability to each other.
            MR. UTSEY:  We will take a break so you
  can make your call.
            MR. CHAPLIN:  Thank you.
             (A recess was taken.)
       Q.   Again, this is probably me trying to put
  a square peg in a round hole, so to speak, because
  I'm trying to understand the structure of your
  church, using as a backdrop my understanding of
  how the churches I have been affiliated with are
  structured, but it may not be a good comparison.
            Does your church have one or more
  pastors or ministers or priests, or whatever title
  they are supplied?
       A.   Yeah.  We have at least three pastors,
  and we have men who operate -- I don't know how
  you would call it.
       Q.   What do you call them?
       A.   They get up and preach.  Well, one is an
  evangelist, two are pastors, one is a teacher.
  And I'm more recognized as the prophet, which most
  of your churches won't recognize.
        Q.   Right.
       A.   But we recognize the prophet ministry.
  We have teachers.  We have pastors who operate --
  and that's in the spiritual sense.  That comes
  form a spiritual extent.  That is not something
  you go to school and learn.  It's a spiritual gift
  that God gives people, which is mentioned in the
  Bible, pastors, evangelists, teachers and
  governments, and even some who minister with the
  Ministry of Health.

Because the people that follow Mr. Stair believe that he is the Last Day Prophet of God and speaks only the words of God that Mr. Stair can control them.  He tells them what they should do by using examples from the Bible and twisting them to fit his purpose.

       Q.   Help me with names for each of those
  people.  You are the prophet, is that correct?
       A.   Yes.
       Q.   And there are pastors?
       A.   Pastor Timothy Jones is one.  I would
  say that Al -- I can't think of Al's last name.
            MR. CHAPLIN:  We can get it to him.  Go
  ahead.
       A.   Dave Moratto is an evangelist.  Jonathan
  Keiser is a teacher.  And then we have many other
  men who preach.  I don't know.  I mean, I can't
  give you a whole list of all the men who preach.
  I mean, many that come in and preach are from
  outside, inside.
       Q.   I got you.
        A.   In fact, one of those fellows right
  there used to preach.
       Q.   What fellow right where?
       A.   Tim Butler.
       Q.   Oh, one of the plaintiffs?
       A.   Yes.
       Q.   Are any of these official titles that
  are documented somewhere in church documents?
       A.   No.
       Q.   It's just the way things are developed
  and people go into where their talents lead them?
       A.   Right.
       Q.   Now, does Faith Cathedral Fellowship
  have meetings, formal meetings other than worship
  services?
       A.   What kind of meetings are you talking
  about?
       Q.   Church business meetings, for example.
       A.   If we need them, we call them.
       Q.   And when you have those type meetings,
  who attends?
       A.   Anybody that wants to that belongs to --
  that lives on the grounds.

If they ever had a business meeting while we were there it is news to me!

       Q.   Are there documents generated --
       A.   We haven't had any yet.
        Q.   Oh, you haven't?
       A.   No.  We don't have to have them because
  there is no need for them.
       Q.   Why not?
       A.   Because we just have services.  We
  don't -- business is taken care of with the board
  if we have it and that's it.
       Q.   That is what I was trying to understand.
  So the board is really the business -- I know you
  are not operating as a traditional business, so
  I'm not trying to add some connotation to this
  that is not there.  But the business end of things
  is the board?  Is that fair to say?
       A.   They understand and know what is going
  on, yes.
       Q.   Now, you mentioned --
       A.   Of course, we are very open, I can tell
  you that.  Everything that goes on up there
  everybody knows.

This is not true!
The only things that the community knows about are the things that Mr. Stair wants them to know about.  And then we only know what twisted words he uses to explain things.  Example, when a family moves out of the community we only hear what Mr. Stair has to say about them.  Then he adds things to their departure so he can plant in our mind about how bad they were.  After hearing the lies over and over again…….one begins to believe his lies to be the truth.  I have witnessed this for myself.


       Q.   You mentioned that the board has a
  disciplinary function and that it has disciplined
  you in the past.  Explain that to me.
       A.   Yeah.  A few years ago I committed
  adultery and they disciplined me, and I'm still
  under discipline.  I'm not allowed to go anywhere
   by myself.  And, of course, you know about that.
       Q.   Well, you may be assuming more than is
  there.
       A.   No.  You know about the case.
       Q.   Now, tell me about that.  You said a few
  years ago.  When was this?
       A.   Four years ago, about four years.
       Q.   About four years ago.  Is this the only
  time that the board has disciplined you?
       A.   Yes.
       Q.   What was the nature of the discipline
  other than you can't go anywhere alone?
       A.   Well, I wasn't supposed to -- I had to
  be more careful about how I dealt with each
  individual, you know, to be careful about my life.
  That was all.

There was a meeting of Elders and they told Mr. Stair to go on the air and tell what he had done and repent. Mr. Stair refused saying he would lose HIS ministry if he did. He was also supposed to treat the brethren nicer and quit calling them names during services which he did for a short while but then started up again.

       Q.   Now, how was this disciplinary decision
  reached?  Was it at a formal board meeting or
  what?
       A.   Sure.  We had a church meeting and then
  we had a board meeting.

They did not have a board meeting

       Q.   What is a church meeting?
       A.   Well, when that came down, we called
  everybody together and --
            MR. CHAPLIN:  Excuse me one second.
   Skip, in light of the fact that the matter that we
  are talking about is on a 40J status, I am going
  to object to this line of questioning.  I think
  that this has been put on hold until the case is
  restored.
            MR. UTSEY:  I think it's -- it's still
  discoverable.
            MR. CHAPLIN:  Okay.  If you want to go
  forward with it, that's fine.  I just wanted to
  put that objection on the table because I think
  that the focus of the cases that are -- for the
  purpose of the depo today, none of them have to do
  with where you are at right now.
            MR. UTSEY:  I understand that, but I
  think under the rules of discovery, unless it's
  privileged, I have a right to ask him about it.
            MR. CHAPLIN:  And I think that the 40J
  matter suggests that that is off the docket and
  probably not the purpose of today's meeting.
            MR. UTSEY:  Your objection is on the
  record.
            MR. CHAPLIN:  Good.
       Q.   There was a church meeting, you said,
  with respect to this issue?
       A.   Yes.
        Q.   When was that held?
       A.   Sir, I don't have those dates in my
  mind.
       Q.   Approximately when was it?
       A.   It was about four years ago.
       Q.   And when you say a church meeting, you
  mean what?  Who attended?
       A.   Every person on the land at that time
  attended except the children.  And what took place
  was I made the confession of what I had done, and
  from then the board took care of it and we made
  some stipulations.
            And I was told to be careful who I
  talked to, where I went, and make sure I always
  had somebody with me.
       Q.   Other than your confession, did the
  church meeting consist of anyone else saying or
  doing anything?
       A.   Saying or doing anything?
       Q.   Presumably, when you say you gave a
  confession, you stood up and confessed to what you
  had done wrong?
       A.   Correct.
       Q.   Other than that, did anyone else say --
  for instance, did people that were in attendance
   say here is what I think about it or --
       A.   Sure, some of them did at that point in
  time.

Chris Ginrich told us that the people of the church Stair pastored in Savannah, GA left for the same reason, Stair had committed adultery.
Several sisters that Mr. Stair had approached for sexual favors spoke up and confronted him.  After the meeting one sister told her husband how Stair had been approaching her.

       Q.   Was the church meeting recorded in any
  way, whether minutes were prepared or --
       A.   No.
       Q.   -- audio recordings or anything?
       A.   No.
       Q.   Any documentation that relates to that
  church meeting?
       A.   No.
       Q.   Is there a list of who attended that
  meeting?
       A.   No.
       Q.   What was it that you said in your
  confession there?
       A.   I told them what sin I committed.
       Q.   Right.  And that was it?
       A.   That was it.
       Q.   So I committed adultery?
       A.   Yes.
       Q.   Did you discuss details?
A.  Not very much, no.

There was a separate meeting with the men of the community where details were discussed.

       Q.   And then you said the board dealt with
  it from there.  Was there a separate board
   meeting?
       A.   Yes.  We had several board meetings
  after that.
       Q.   Were minutes prepared with respect to
  those board meetings?
       A.   Not those specific ones, no.
       Q.   Why not?
       A.   Because they were church issues.  We
  weren't dealing with the organizational structure.
  We were dealing with church issues, religious
  things.
       Q.   With respect to your discipline from the
  board, are there any documents of which you are
  aware that relate to that?
       A.   No.
       Q.   All of it was oral?
       A.   Yes.
       Q.   Were there any recordings made of any of
  that?
       A.   No.
       Q.   And you say you are still under
  discipline.  What do you mean by that?
       A.   Well, we set up a rule at that time that
  nobody would go off the grounds or anywhere by
  themself, we would always have somebody with us.
   And we all still abide by that.  We all abide by
  that.
            It's just to be a little safer.  We are
  watching for each other's soul and each other's
  way.  So whenever anyone goes off the ground or
  does anything, they have someone with them.
       Q.   And that applies to everyone there?
       A.   Just about, yes.  I don't know of
  anybody that goes off the ground -- in fact,
  nobody is ever told to go off the ground without
  somebody else with them.
       Q.   I understand.  Well, then is there
  anything in addition to that that you are subject
  to, individually, that you would call discipline?
A.  No.

Mr. Stair blamed the women that lived in the community for the trouble that he was in.  So if he had to suffer with being escorted everywhere he went so did everyone else that lived there. The women had to walk around in pairs looking at the ground.  They were not allowed to look at any males lest lust come over the males.  And even the way the women dressed was changed.  Also the brothers who work off the land like Tim Butler left the land without any escorts.

       Q.   Now, tell me about the instance of
  adultery.  Who was the person?
       A.   I don't want to answer that.
       Q.   I understand you don't want to, but, I
  mean, I have a job to do and --
       A.   Right.  It has nothing to do with this
  case.
       Q.   I understand that, but you still have to
  tell me.
       A.   Tell you what?
       Q.   The name of the person with whom you
  committed adultery.
            MR. CHAPLIN:  Skip, I think that the --
  the objection I raised states that the two cases,
  or the name would be the plaintiff in that matter
  that we brought 40J.
            MR. UTSEY:  I understand that.  But the
  rules say that the only way the witness can
  refrain from answering the question is if it's the
  subject of attorney-client privilege, and it's not
  of a privileged matter, so I have a right to ask
  about it even though it may or may not be
  admissible at trial later on.
       Q.   So, anyway, back to the question.
            THE WITNESS:  Do I have to answer that?
            MR. CHAPLIN:  Yeah.  Just give him the
  answer.  If it continues we are just going
  to --
            THE WITNESS:  What answer am I supposed
  to answer?
            MR. CHAPLIN:  Give him the name.  And if
  this continues we are going to have to take a
  stronger stance.  Go ahead.
       Q.   With whom did you commit adultery?
       A.   Stacey was one of them, Stacey Belford.
        Q.   And there were others?
       A.   Yes.  There was one more.
       Q.   Who was that?
A.  Laquiela Jones, at that time.

He didn’t mention Lolita Burgess or Shirl Halverson who he admitted to committing adultry with at the same time.       Nor the ladies that he had approached trying to seduce them.  And what about the ones that he was just starting to work on.  When the ladies resisted Mr. Stairs advances they became the subject of our next dinning hall sermon.  And it was common for the sermons to last all day long until supper time.  Then he would start again after supper.

       Q.   With Ms. Belford, was this a
  consensual --
            MR. CHAPLIN:  Skip, I'm sorry.  We are
  going to have to --
            MR. UTSEY:  Well, if you are going to
  file a motion for protective order, then we can
  file a motion for protective order and deal with
  it.
            MR. CHAPLIN:  Okay, then we have to deal
  with it.  Because I thought we were coming here
  today to talk about the cases that were on the
  docket that we needed to address.  And right now
  what I feel like is you are pulling a fast one.  I
  don't think that this is appropriate.
            We should not be talking about cases
  that are not on the docket at this present time.
  They are not even of consideration.
            MR. UTSEY:  Well, but it's discovery,
  and this could lead to discoverable material and
  it's a credibility issue.
            MR. CHAPLIN:  When I prepared him for
   his deposition I told him the cases that we would
  be discussing, and I did not tell him we would be
  discussing the cases where the adultery was an
  issue.  And, I mean, because I didn't -- because
  they are on 40J.  They are a 40J motion that we
  both agreed to.
            MR. UTSEY:  I understand that.  But, for
  the record, I think anything that might tend to
  lead to discoverable evidence with respect to
  these cases, including issues of credibility and
  matters of where he has been disciplined by the
  church of which he's a member, are clearly
  relevant to those issues.
            MR. CHAPLIN:  However, and you --
            MR. UTSEY:  Here is what needs to
  happen.  If you are going to instruct him not to
  answer any further questions on this, then the
  rules are pretty clear about your obligation to
  file a motion with the Court seeking a protective
  order and then we can have this discussion with a
  judge and deal with it down the road.
            MR. CHAPLIN:  That's fine, and I think
  we should.
            MR. UTSEY:  If that's what we are going
  to do, at least we can move on to another subject,
   if that is your intention.
            MR. CHAPLIN:  Okay.  My intention is to
  file a motion for protective order.
            MR. UTSEY:  Okay.  So you are going to
  instruct him not to answer any further questions
  on this topic?
            MR. CHAPLIN:  That's correct.
            MR. UTSEY:  Then reserving all rights,
  we will move on to another topic.
       Q.   Other than that episode of being
  disciplined by the board, have you ever been
  disciplined by the board or any other authority
  within the Faith Cathedral Fellowship?
       A.   No.
            MR. CHAPLIN:  And, Skip, can we make
  clear what the topic is that I'm instructing him
  not to answer questions on?  Not on disciplinary
  action, but based on the 40J -- cases that are on
  40J.
            MR. UTSEY:  If you are instructing him
  not to answer, I think you need to make it clear.
            MR. CHAPLIN:  Okay.  I just want to make
  sure you and I understand.
            MR. UTSEY:  What are you instructing him
  not to answer?
             MR. CHAPLIN:  Cases with regards to
  plaintiffs whose cases have been placed on a 40J
  status.
            MR. UTSEY:  Okay.
            MR. CHAPLIN:  Which we did not come here
  today to discuss.  We are not preparing for trial
  for those.  Those are on the back burner, so to
  speak.
       Q.   Who is the custodian of corporate
  records with Faith Cathedral Fellowship?
       A.   Custodian?
       Q.   Is there one person that maintains the
  corporate records?  If I wanted to get them, who
  would be the best person to go to to get them?
       A.   Probably me.
       Q.   Does that include minutes of the board
  of directors meetings?
       A.   Yes.
       Q.   Does it include financial records?
       A.   Yes.  I would be the one to authorize
  it.
       Q.   And does that include corporate records,
  things that you filed with the state, that sort of
  thing?
       A.   We don't file with the state.
        Q.   Well, to obtain the corporation status.
  You had to have had a --
       A.   I have all of those records, yes.
       Q.   Now, you said something about
  authorizing what, financial expenditures?
       A.   I didn't say anything about that, that I
  know of.
       Q.   Oh, okay.  I said something about does
  that include financial records, and you said, yes,
  because I would have authorized it, or I may have
  misunderstood you.
       A.   Yeah.  I am the one that authorizes what
  is spent and what is not spent, yes.
       Q.   Is there anyone else in Faith Cathedral
  Fellowship that has the authority to dictate what
  is spent and what is not spent?
A.  They all do, if they want to.

That is not true. Stair would eat someone for lunch for making a decision to spend money on something without consulting him first and as far as trusting him goes…..he has all the money, what can anyone say?
When we lived on the farm if there was anything we needed from the stores we had to ask Mr. Stair to purchase them for us. And we feared that we might ask for something that Mr. Stair didn’t think was right and then we faced a sermon where everyone would know that we asked for something wrong. Even asking for spices to season the food with could cause a major sermon. The sister even had to ask him to purchase personal items like bras and underwear.  Which meant that we had to tell him what size to get.  Do you know how embarrassing that is?  We didn’t ask for famine sanitary pads.  We learned how to make them ourselves to avoid personal embarrassment.

       Q.   Does anyone else exercise that
  autho

  A.   No.  They trust me.
       Q.   Does the board have to approve your
  decisions with respect to expenditures?
       A.   No.
       Q.   Does it, in fact, do that?
       A.   No.  They could if they wanted to, but
   they don't need to.
       Q.   So in terms of what money Faith
  Cathedral Fellowship spends, you are the one
  making those decisions?
       A.   Basically, yes.
       Q.   Well, basically suggests that is not a
  yes, or not a complete yes.
       A.   Yes.
       Q.   It is a yes?
       A.   Yes.
       Q.   Okay.  Have you ever been arrested?
       A.   Here?
       Q.   What I'm seeking to find out is any time
  you have ever been arrested anywhere, I want to
  know about it.  You were arrested in Colleton
  County?
       A.   Yes.
       Q.   And charged with what?
            THE WITNESS:  We are going back at this
  again.
            MR. CHAPLIN:  Right.  Uhm --
            MR. UTSEY:  Well, this is different,
  though.  This is clearly, under the rules, related
  to questions of witness credibility.
            I am asking him about the charge.  I am
   not asking about the details of what happened.  I
  am asking what he's been arrested for and charged
  with.
            MR. CHAPLIN:  And I would object to that
  as asked and answered because I think that you
  have that information already.  In the discovery,
  I think we provided that.
            MR. UTSEY:  Well, I still have the right
  to ask him about it.
            MR. CHAPLIN:  Well, to your best
  knowledge answer the question.
       A.   I was arrested in Colleton County, two
  charges of second-degree sexual assault, which had
  to do with the adultery, and one that has to do
  with breach of trust, and one that has to do
  with --
            THE WITNESS:  What was that burial
  situation?
            MR. CHAPLIN:  Just that's your
  testimony.  Just go ahead and describe it that
  way.
       Q.   The fourth charge dealt with a burial?
       A.   Yes.  We had to bury a child.  And I
  don't know what they called it, unlawful burial,
  whatever it was.  And they have all been disposed
   of, which you already know, don't you?
       Q.   I have some knowledge of it, but I may
  not have full knowledge, and that is why I'm going
  to ask you --
       A.   I am sure the court can give you a
  record on it.
       Q.   And you can, too.  But, see, I don't get
  to testify at trial, and that is why I need to ask
  what you understand about this.
            What was the disposition of the two
  charges for second-degree sexual assault?
       A.   They were dismissed or put away with or
  thrown out.  I don't know what word is used.
            MR. CHAPLIN:  I think you were
  appropriate when you said dismissed.

They were dismissed because the lawyer goofed up and did not file right. Stair later pleaded guilty to simple assult.   And all the other charges were added just to get rid of them.

       Q.   Did you plead guilty or not guilty to
  those charges?
       A.   I didn't plead either way.
            MR. CHAPLIN:  They were dismissed.
       Q.   What was the disposition of the breach
  of trust charge?
       A.   Same thing.
       Q.   What was the disposition of the burial
  charge?
       A.   Same thing.
        Q.   Did you reach any type of plea agreement
  with respect to any of the charges that were
  pending in Colleton County?
       A.   Yeah.  They had me agree to a simple
  assault.
       Q.   And did you plead guilty to that?
       A.   I sure did.
       Q.   Was that one or two charges?
       A.   Let me see.  That was --
            MR. CHAPLIN:  If you don't recall, just
  say you don't recall.
       A.   I don't recall.
            MR. UTSEY:  At a certain point -- the
  rules are pretty clear that you are not supposed
  to be coaching him.  I haven't objected to that up
  until now.
            MR. CHAPLIN:  Okay.  Objection noted.
       Q.   You pled guilty to simple assault.  And
  who was the victim of that simple assault?
       A.   The two young ladies.
       Q.   Belford and Jones?
       A.   Yes.
       Q.   Did you plead guilty to anything else?
       A.   No.
       Q.   Have you ever been arrested at any other
   time in your life?
       A.   I was arrested in Savannah many years
  ago for bill of trover.  That's what they used to
  call it.
       Q.   And what did you understand that related
  to?
       A.   I bought an organ.
       Q.   A what?
       A.   An organ, and it wasn't any good, and I
  didn't pay for it, and until I returned the organ
  they arrested me.  They either wanted the organ or
  the money or me.  So they arrested me until I
  returned the organ.  And I had to go get the
  organ, and when the organ was returned the judge
  was satisfied.
       Q.   Was that a civil action?
       A.   I don't really know.  I just know the
  sheriff came out.
       Q.   Do you know whether you ended up
  pleading guilty or not guilty?
       A.   I didn't plead nothing.  When the organ
  was returned, they just turned me loose.
       Q.   And were all charges dismissed?
       A.   If there were any charges at all.
       Q.   So, in other words, you didn't have to
   satisfy any criminal penalty, whether it be
  incarceration or fine or anything like that?
       A.   No.
       Q.   What year was that, approximately?
       A.   I don't recall.  I can't --
       Q.   When were you in Savannah?
       A.   It all was around 25 years ago.  It
  might have been 30 years ago, somewhere along in
  there.  That was even before I even moved to
  Savannah, so it might have been 32 years ago.
       Q.   Have you ever been arrested at any other
  times in your life?
       A.   Yes.  I was arrested one time in
  Oklahoma.
       Q.   What was that all about?
       A.   What did they charge me with?  Do you
  know what they -- I don't know what --
            (Telephone rang.)
            MR. CHAPLIN:  Can I take it in your
  office?
            MR. UTSEY:  Yes.
             (A recess was taken.)
       Q.   I was asking you about the arrest in
  Oklahoma.
       A.   Yes.
        Q.   Do you remember what the charge was?
       A.   I was thinking -- I think they called it
  outrage and public decency.
       Q.   And did you understand what the
  circumstances were that led to that charge?
       A.   Yes.
       Q.   What was that?
       A.   A little girl said I made a gesture at
  her.

Mr. Stair told us in the dining hall that the charges were made because he touched the little girl in ways that he should not have done. (sexually)  And the charges were dropped after he was able to talk to the mother and convinced her the girl didn’t know what she was saying.

       Q.   And what happened with that charge?
       A.   They were dismissed.
       Q.   Did you plead guilty, not guilty?
       A.   It didn't even go to court.
       Q.   But did you ever have to file a plea?
       A.   No.
       Q.   Did you pay a fine or anything like
  that?
       A.   No, just dismissed and told me it was
  done.
       Q.   And where was that in Oklahoma?
       A.   Muskogee.
       Q.   And how long ago did that happen,
  approximately?
       A.   45 years.
       Q.   Oh, okay.  It's been a long time?
             MR. CHAPLIN:  How many years?  I'm
  sorry.  I didn't hear that.
            THE WITNESS:  45.  At least 45, I would
  say.
       Q.   Other than the arrest in Oklahoma that
  we just discussed, Savannah that we previously
  discussed and Colleton County that we have
  previously discussed, have you ever been arrested?
       A.   Huh-huh.
       Q.   That is a no?
       A.   That's it.
       Q.   I am trying to make sure your answer is
  clear for the record.
       A.   No.  I wasn't arrested anyplace else.
       Q.   Other than the one instance of
  discipline by the board of Faith Cathedral
  Fellowship, have you ever been disciplined by any
  other church with which you have been affiliated?
       A.   No.
       Q.   Have you ever been treated -- these are
  standard questions.  Have you ever been treated
  for any type of substance abuse?
       A.   No.
       Q.   Or addiction?
       A.   No.
        Q.   Have you ever been treated for any sort
  of mental or emotional problems?
       A.   No.
       Q.   Do you have a family doctor?
       A.   No.
       Q.   Do you get medical treatment at all?
       A.   No.
       Q.   When is the last time you received
  medical treatment?  Never?
       A.   No.
       Q.   Dental work?
       A.   Yes.
       Q.   Do you have a dentist locally?
       A.   Yes.
       Q.   Who is that?
       A.   Dr. Rhoades.
       Q.   Have you ever seen any other health care
  provider other than Dr. Rhoades?
       A.   No.
       Q.   Have you ever been involuntarily
  committed to any type of institution?
       A.   No.
       Q.   Have you ever been a party to any civil
  action other than those initiated by my clients?
       A.   Yes.
        Q.   Tell me about those.
       A.   We had a farm in Alabama, and a fellow
  tried to take it from us that was living on it,
  and it was resolved.
       Q.   Where was that?
       A.   Let's see.  What county was that in?  It
  was down near Auburn.  I can't think exactly where
  it was.
       Q.   And you said we had a farm.  Who is
  that?
       A.   Someone gave the church a farm, and we
  let somebody live on it, and he wanted us to sign
  it over to him because he thought that we --
       Q.   And so --
       A.   So he sued us.
       Q.   He sued you?
       A.   Yes.
       Q.   He sued the ministry?
       A.   Right.
       Q.   And it was resolved how?
       A.   The judge made us -- we gave him back
  his $25,000 that he gave, and then put him off the
  land and we got the farm back.
       Q.   So it did end up going to court?
       A.   Yes.  It went to court.
        Q.   When was this?
       A.   I don't remember the dates.
       Q.   Approximately?
       A.   Five, six, seven, eight years ago.
       Q.   Does the church still own that farm?
       A.   No.
       Q.   What happened to it?
       A.   We sold it.
       Q.   When was that?
       A.   About the same time.
       Q.   To the same individual or to someone
  else?
       A.   No.  We sold it to somebody else.
       Q.   Is that the only other time that you
  have been involved in a civil lawsuit?
       A.   Yes.
       Q.   Have you ever been involved in any
  litigation in probate court?
       A.   No.
       Q.   Have you ever been involved in any sort
  of quasi-judicial administrative actions?
       A.   No.
       Q.   How does Overcomer Ministries -- what
  income does it have?
       A.   I'm not sure if I understand your
   question.
       Q.   Well, does Overcomer Ministries have
  income?  Does it have money that comes into it?
       A.   Yes.  People give us offerings.
       Q.   Does it have any other sources of
  income?
       A.   No.
       Q.   And, generally speaking -- I have got
  some computer printouts that we will talk about in
  a moment that your attorney has turned over.
            But, generally speaking, what categories
  of expenditures does Overcomer Ministries have?
  What does it spend its money on?
       A.   Radio broadcasting.
       Q.   Anything else?
       A.   And maintaining of the facilities up
  there on the farm.  That's it.
       Q.   How long have you been in the radio
  broadcasting business?
       A.   All my life.
       Q.   And so the entire time that Faith
  Cathedral Fellowship has been in existence, one of
  the expenditures it has had has been radio?
       A.   Yeah, the biggest ones, yes.
       Q.   And what type of radio?
        A.   All kinds.  What is on the radio?  I
  mean, what do you mean by that?  I don't
  understand the question.
       Q.   I mean, is it commercial radio,
  programming?
       A.   No, no.  We are not commercial at all.
  Nothing is commercial.
       Q.   I understood something about shortwave
  radio that I know very little about there.
       A.   Shortwave radio is like any other radio.
  You buy time on the stations and you pay them for
  the time that you broadcast on them, and that is
  what we do.
            We buy time from stations in America and
  we buy shortwave time in different parts of the
  world.  We pay for satellites, any forms that get
  the signal into the stations, and that is what we
  pay for.
       Q.   I guess that is what I meant.  When I
  said commercial radio, would it be on AM bands or
  FM bands?
       A.   AM, FM, shortwave, Internet, satellite,
  whatever source that they use.  We use all of
  them.
       Q.   So you said satellite, for example.  I
   understand there is like XM radio or Sirius radio?
       A.   No.  Satellite sends a signal to other
  parts of the world, or any part of the world.  It
  uses satellite to send a signal.
       Q.   I see.  And so you pay whoever owns the
  satellite or manages the satellite?
       A.   We pay many stations.  We pay people who
  own the satellite.  You have to pay them for it,
  yes.
       Q.   Same with the Internet?
       A.   Yes.
       Q.   Now, is there documentation related to
  what your charges are for that air time?
       A.   We have the records of every dime ever
  spent, every record to every station anyplace in
  the world, yes.
       Q.   So, in other words, if you had received
  an invoice from Station X for the air time, would
  you have that?
       A.   We have the invoices, we have the
  canceled checks, the payments.  They are all paid.
       Q.   I noticed in the -- and I'm sort of
  jumping ahead of myself, but these account
  printouts that your attorney provided, one of the
  line item expenses is radio.  And, as you said,
   it's probably the largest expenditure?
       A.   Yes.
       Q.   Under that line item of radio, is there
  anything included other than the air time itself
  that you purchase?
       A.   Well, there are things that have to do
  with the signal satellites and the air time you
  purchase and the facilities you use, yes.  It's
  all included in the --
       Q.   That is what I'm driving at.  What all
  is under that heading of radio?
       A.   I just explained it to you.  We have
  satellite, Internet, and we pay the station for
  the time.  We pay the people who provide the
  satellites.  We have to pay them.  And we have to
  pay for the Internet serving, the T-1 lines and
  things like that.
       Q.   Are there any other aspects of the radio
  broadcast that fall under that expense category on
  your bookkeeping?
       A.   Not as far as air time, no.
       Q.   For example, do you have a studio, or do
  you rent a studio or what?
       A.   We have a place.  On our farm we have
  our own radio facilities.  We have our own
   facilities.
       Q.   And when you purchased that equipment,
  how is that expenditure handled?
       A.   It's probably listed down some way.
  Either computer or radio or some way it's listed.
       Q.   That is what I'm trying to figure out.
  I am trying to break down these categories on your
  expense list, and I'm wondering if radio includes,
  for example, any equipment?
       A.   We could go into radio and we could tell
  where every dime went, whether it went for the
  computers in the radio room or whether it went for
  the printing of -- yes, we could.
       Q.   How would you do that?
       A.   How do we do what?
       Q.   How would you go into it to find that
  out?
       A.   Well, the computer has the categories.
  The bookkeeping has categories.  If we spend
  $1,000 for radio, and then you went to the
  category and say this was spent for the computer
  room, and this was spent for the satellite uplink,
  and this was spent for the --
            MR. UTSEY:  Okay.  Well, let me go ahead
  and mark this document as Plaintiffs' Exhibit 1.
              (Plaintiffs' Exhibit No. 1 was marked
  for identification.)
       Q.   For the record, Exhibit 1 is a group of
  documents which appear to be computer printouts
  which your attorney furnished to me.
            The dates appear to range from the year
  19 -- it's hard to read some of them because they
  were faxed -- 1992, I believe, through 2004.  Can
  you identify that?
       A.   Sure.
       Q.   What is it?
       A.   It's our bookkeeping record.
       Q.   A printout of the bookkeeping record?
       A.   Right.
       Q.   Do you know what type of software you
  use to maintain these records?
       A.   On this one right here we might have
  used -- we have changed them often.  We might have
  used Money Accounts on this one, and now we have
  QuickBooks, I think.  I would have to go back and
  check and see which one.
       Q.   So that if you were to -- let's don't
  talk too much about the printout itself, but let's
  talk about what is on the computer.
            If you were to pull up a screen to see,
   for example --
       A.   It would be that.
       Q.   January 1 through December 31, 2004,
  You would have something that looks like that
  page?
       A.   That is the report that would come out
  from the screen.
       Q.   And then if I wanted to see an
  itemization under an expense category --
       A.   No problem.
       Q.   -- what would you do, click on that
  category?
       A.   Yeah, click on it and print it out.
       Q.   Are those itemizations per category
  contained within Exhibit 1?
       A.   This is the report.  I don't know what
  you are asking me on that one.
       Q.   Let's look at the top page, which is
  January 1 through December 31, 2004.
       A.   Right.
       Q.   The first expense item on that list is
  animals?
       A.   Right.  That has to do with the farm.
  We could tell you what we spent for the animals.
  That is expense.  That is what we pay for the
   animals, or feed or something like that.
       Q.   Right.  So let's say -- and I'm just
  using this one as an example to help understand
  how this is formatted in the computer.
            I see that for the total year $12,100
  was spent on animals, correct?
       A.   Right.
       Q.   And if I wanted to know, well, was that
  purchasing feed or was that --
       A.   Yes.
       Q.   -- veterinary care, or whatever the
  expenditures might have been, what would I do from
  this page to find that out?
       A.   You would punch up animals and we would
  search out the categories.  It would tell you what
  was spent for it.
       Q.   Can you generate a printout or a report
  of that category?
       A.   Yes, I'm pretty sure.
       Q.   Does Exhibit 1 contain that type of
  printout, or is it just the overall printout of
  each category?
       A.   This is the report that we asked for.
  We could ask for a report on something else and
  get a report on it.
        Q.   So if, for example --
       A.   For instance, I have right here some
  reports that she pulled out this morning that have
  to do with certain things.  In fact, every one of
  those people right there, I have a report of
  what -- of their records right there.
       Q.   You have them with you?
       A.   Yeah, but I am not going to give them to
  you right now.
       Q.   Well, why not?
       A.   Because they are for my benefit.  If the
  time comes and we need them, we can give you that
  report.
       Q.   Okay.  The time will probably come
  either today or later.  I don't know.
       A.   Good.
       Q.   When we started this discussion I was
  asking you about radio.  What you are telling me
  is that if we needed to see where each penny was
  spent on --
       A.   Every dime, every check.
       Q.   You could generate reports for that?
       A.   Absolutely.
       Q.   Okay, good.  Who is the individual that
  maintains the documentation in the computer
   program?  Is that Teresa?
A.  Yes.
One day Mrs. Stair asked me if I would be willing to help her with the bookkeeping since I had experience.  We even talked about what she did when she was having problems balancing the books..  She told me that she simply added or deleted a donation to balance the books.  After saying I would help her.  She told me that she had to get permission from Mr. Stair.  Later she came to me and told me that he was very upset about her even thinking about asking me and told her if she couldn’t keep up with it that he would do it himself.

            MR. UTSEY:  Are those notes or are
  those --
            MR. CHAPLIN:  No.  You know what, you
  can have these.
            MR. UTSEY:  -- actual printouts?
            MR. CHAPLIN:  No.  These are notes,
  personal notes.  And, I mean, we could call this
  privileged, but it's nothing that we are going to
  try to hide.
            THE WITNESS:  No.
            MR. UTSEY:  We will get to it in a
  minute.
            MR. CHAPLIN:  Okay, fine.  There is no
  problem with that.
            THE WITNESS:  She just wanted to inform
  me on that.
            MR. CHAPLIN:  I understand.  That is
  going to come up anyway, and I think we should be
  forthright with that.  Thanks for bringing that.
       Q.   Does Faith Cathedral Fellowship have a
  policy with respect to the return of any offerings
  or donations?
       A.   No.
        Q.   In the past, has Faith Cathedral
  Fellowship ever returned some or all of anyone's
  donations or offerings?
       A.   Yes.
       Q.   How were the decisions made to do that?
       A.   I make the decision.
       Q.   And on how many occasions have you done
  that?
       A.   Oh, eight or ten.
       Q.   Did any of them involve individuals
  other than people who have brought these lawsuits
  and the man in Alabama who the judge told you to
  return his $25,000?
       A.   I sent money back to a lot of people,
  and I've refused a lot of offerings at times.
       Q.   Under what circumstances have you
  returned some or all of the person's offerings?
       A.   When I felt like they weren't really
  giving it.
       Q.   What do you mean?
       A.   Well, they would give you some money,
  and I felt like they weren't giving an offering,
  they were trying to buy a service or something,
  and I don't sell any service.  I wouldn't receive
  their offering.
        Q.   Are there any other reasons that you
  have ever returned an offering?
       A.   No.  The only time I have returned an
  offering is when people who came and lived with us
  and then they left.  I would never send anybody
  away empty.  I would always make sure they had
  money.
            Some came with nothing and I sent them
  away with some offering.  Because I felt like if
  they no longer wanted to live under our status,
  and they were going back out there, I wouldn't
  send them out without some money, and I didn't do
  it.
       Q.   In any of those instances have your
  decisions been approved by or otherwise reviewed
  by the board of directors or anyone else?
       A.   Sure, every one of them.
       Q.   So would there be board meeting minutes?
       A.   No.  We just -- like I say, we are very
  open up there.  We discuss all the things all the
  time, and they all know what goes on and what
  happens and how it happens.

It is not discussed with everyone. Stair had me move a man out one time and he gave me 1200.00 to give to the man when we reached his destination. That isn’t much to start out on.

       Q.   So that would be more of an informal
  discussion than a meeting?
       A.   Yes.
        Q.   I notice that in some years you have got
  a net income and some years you have a net loss.
  In those years where you have a net loss, how do
  you make up for the shortcoming?
       A.   It's what was left over from the
  previous year.
       Q.   Just used as retained earnings?
       A.   Sure.
       Q.   And so in those years where you have net
  income, you just retained those earnings to offset
  any future losses?
       A.   All the offerings come in and go into an
  account.  Some years you took in more than others
  and other years you didn't take any.  It's just
  like a monthly thing.
            Some months you take in more than you
  paid out, and other months you don't take as much
  in as you pay out.
       Q.   So it balances out in the long run?
       A.   Right.
       Q.   When you say it comes into one account,
  is that a bank account?
       A.   Yes.
       Q.   And what bank would that be?
       A.   Right now it's Walterboro bank.
        Q.   Bank of Walterboro?
       A.   Yes.  There was Enterprise Bank.
       Q.   How long have you been with Bank of
  Walterboro?
       A.   Four or five years.
       Q.   And the account is listed under what
  name?
       A.   Faith Cathedral.
       Q.   Is your name also on the account?
       A.   Yes.
       Q.   Individually?
       A.   Uh-huh.
       Q.   Why is that?
       A.   Because I'm the one that exercises the
  business.  I am the one authorized by the board
  and the corporation to handle the business.
       Q.   So you write the checks, or sign the
  checks at least?
       A.   I sign the checks and my wife signs the
  checks.
       Q.   How many different accounts do you have
  with the Bank of Walterboro?
       A.   We have a savings accounts, we have a
  checking account, we have a CD.
       Q.   And do you have accounts, at present,
   with any other banks?
       A.   Yes.
       Q.   What other type accounts?
       A.   We have a money market account with
  Tidelands Bank.
       Q.   Where is that?
       A.   It's in Summerville.
       Q.   How long have you been doing business
  with Tidelands?
       A.   Maybe two years.
       Q.   Any other accounts with Tidelands?
       A.   No.
       Q.   Any other accounts with any other banks?
       A.   No.
       Q.   Do you have any investment accounts?
       A.   With those banks.
       Q.   Those same banks?
       A.   Yes.
       Q.   What type of investment accounts?
       A.   Tidelands Bank is the money market
  account.  We have a CD with Walterboro.  That is
  the investments.
       Q.   Oh, okay.  I'm sorry.  I meant any type
  of investment account where you would invest in
  securities or that sort of thing?
        A.   No.
       Q.   How about you personally?  Do you have
  any bank accounts?
       A.   No.
       Q.   And I think you told me earlier that you
  don't draw a salary or any other pay from Faith
  Cathedral Fellowship, is that correct?
       A.   No.
       Q.   Is that correct?
       A.   Correct.
       Q.   Do you receive income from any other
  source personally?
A.  No.
The church even paid his ex-wife a lump sum of money every year for child support and alimony according to Mr. Stair preaching in the dinning hall. 

       Q.   How do you provide for your day-to-day
  needs in terms of a place to live and groceries
  and --
       A.   The church provides me with a house and
  food and clothing.
       Q.   Anything else?
       A.   That's all I need.  I don't even need
  that almost.
       Q.   And the house it provides, is it on what
  you have been describing as the farm?
       A.   Yes.  It's on our farm.  It's an old
  house that they tore down and rebuilt me a little
   shack.

That is the best living quarters, shack, on the farm.  It has running water, kitchen, private bath,  rain water shower outside and electricity.  Most trailers didn’t have kitchens to cook in, no running water and no bathrooms.  Our trailer had no running water, no bathroom, no compost toilet,  no kitchen.  It was a basic trailer that provided protection from the rain.  We used a wood burning stove to heat with and we used a public shower house for our bathroom needs.  There were some trailers that people lived in that didn’t even have electricity.  They used solar panels.

       Q.   Just so the record is clear, we have
  talked about the farm several times.  Just to make
  sure, can you state for the record what you have
  been referring to when you talk about the farm?
       A.   We have -- our Faith Cathedral
  Fellowship runs a community farm where we have
  people who live, just like you would in a
  monastery, or people have given up their personal
  ambitions to live together as Christians, and we
  have all things in common, like is spoken of in
  the scriptures, and that is what we do.
       Q.   And it's located where?
       A.   In Canadys.
       Q.   How large is the farm?
       A.   It's about one hundred and, oh, twenty
  to thirty acres.
       Q.   And what sort of structures are on the
  farm?
       A.   We have mobile homes.  We have a
  tabernacle.  We have a dining hall.  We have farm
  barns and equipment.  It's a farm.  It's a regular
  organically type farm.  We grow our own food, and
  we live together like a regular family, and no one
  is compelled to stay or no one is invited to come.

We are told that if we ever leave we will go to Hell. We are also told that if we don’t live in one of these communities associated with Stair that we will not make it through the Great Tribulation that the Bible speaks of.  

        Q.   Now, other folks who live on the farm --
  and I don't say other folks.  I am talking about
  your expenses being paid by Faith Cathedral
  Fellowship.  How about the expenses of the farm
  with --
       A.   Everything is paid by the ministry.
       Q.   So anyone who lives there, insofar as
  their food, their housing or their clothing --
       A.   Is all provided by the community.
       Q.   -- is paid for by the community?  Now,
  are there requirements that if you are going to
  live there that you have to give up anything?
       A.   No.  This is the way we live.  If they
  want to come here, they understand that when they
  come they put whatever they have into the
  community.
       Q.   That is what I'm asking.
       A.   Because that is what sustains them,
  their time, their work, their effort.
       Q.   Let's say that somebody wants to join
  that community --
       A.   You can't join us.
       Q.   When I say join, I guess move to the
  community, move to the farm.
       A.   We bring them there for a couple of
   days, for a week or two and visit, and then see if
  they can live with us, that we can live with
  them.  We explain to them how we live here.  And
  if they agree to it, and they all do, then they
  can live with us.
       Q.   And if that hypothetical person owns a
  house, has a bank account, an automobile, can they
  keep those things in their personal name?
       A.   Not and live with us, no.
       Q.   So if they choose to live with you, what
  do they do with those things?
       A.   They donate it all to the church, or
  somebody else, get rid of it.  I had a lady some
  time ago that came in from Arkansas, and another
  man just moved in from Augusta, and he had a
  house, and he said, well, what should I do.  I
  said, give it to -- what do you want to do with
  it?  I said, do you have children?  He said, yes.
  I said, just give it to the children, so he gave
  it to the children.  The woman in Arkansas, she
  gave it to her children.
       Q.   So, basically, they need to divest
  themselves of those possessions to be consistent
  with the philosophy of --
       A.   If they want to live with us, yes.
        Q.   I had asked you a little bit about
  returning of donations to anybody a few minutes
  ago.
            Have there ever been instances where
  somebody has donated, say, a house or other
  property to Faith Cathedral Fellowship and then
  decided that they didn't want to continue living
  on the farm?
       A.   Sure.
       Q.   In those instances, have you ever
  returned their property to them?
       A.   I didn't have their property.  I had
  their money, but not their property.
       Q.   What happens when someone donates
  property to Faith Cathedral Fellowship?
       A.   We sell it.
       Q.   And you keep the proceeds?
       A.   I haven't had too many instances like
  that, though.
       Q.   Did any of those incidents involve any
  of my clients?
       A.   That had property?
       Q.   Right.
       A.   That they bought?
       Q.   Or that you sold?
        A.   No, not that I know that they had
  property that they donated to us, no.
       Q.   Did any of them own property that they
  sold and then gave the proceeds of the sale to
  Faith Cathedral Fellowship?
       A.   Yes.  In fact, every one of them you
  have there, I am sure they had resources, and when
  they came they sold and brought us the money, or
  gave us the money.  And some gave us the money
  before they even came.
            You have one right there.  Mr. Tim
  Butler was in debt to the IRS and to the State of
  Ohio because he wouldn't pay taxes.  He's a
  patriot.  So when he came here, for six months I
  took the money from him that he worked and then I
  paid his debts for him.  I paid his debt.  He
  don't record that, but we paid his debt.

Mr. Stair just held the money I made until there was enough to pay off my debts.
We also have records of the communications between us and the IRS.  None of them went through Mr. Stairs hands.  Also the State of Ohio DID NOT reduce our debt.  We had to pay them every penny that we owed.  And we have the copies of the money orders we used to pay our debt.  And I believe they do not state Mr. Stairs name or his ministry on them.   No one comes to the community with any debt or ties to the world.
            Just like the General, when we paid his
  debt, because we don't believe in having debt.
  None of our people have debt.  So if they come and
  they have debt, we try to get them out of debt and
  we help them get out of debt.
            And if they are able to work, we let
  them work until they -- and then when Tim Butler
  left, not only did we pay his debt, we gave him
   $30,000 cash.  Plus we gave him a motor that we
  paid for, $12,000.

They paid $1700.00 for the motor and I left my old one there that was still usable that was worth at least $1000.00

            And we gave him -- he backed up his
  truck and loaded up a pile of food to take with
  him.  So these are things that we gave back, sure,
  because -- yes.

What food? We brought more then we left with. We also left at least $500.00 worth of camping equipment.
Not to mention personal items like a quilting frame, sewing machine, clothing that was left behind because they were placed in storage units for everyone to use.
       Q.   I am going to get to each one of them
  individually in a minute, so I don't want you to
  have to tell me twice.
            But I noticed on Exhibit 1 that one of
  the line items is return offering.  What is that?
       A.   I mean, sometimes people give us an
  offering and then after awhile the situation
  develops where I didn't believe that it was an
  offering and I return it back to them.
       Q.   Does that include circumstances like you
  were just describing with Mr. Butler when he --
       A.   No.
       Q.   Where would those be documented on here?
       A.   Where would what be documented?  It
  might be under that category.  I would have to go
  home and look under the category.
       Q.   I am curious about any instances where
  an individual has joined your community but then
  left and you have given them any portion of their
   offering?
       A.   We have done that, yes.
       Q.   And what I'm curious about is, looking
  at Exhibit 1, under which of these expense
  items --
       A.   It might be under return.  Well, that is
  not enough.  It would probably be under their own
  name or something.
            This is the general expense report here.
  This is not an individual report.  If you want a
  report, we can get a report for each one of those
  things.
       Q.   Okay.  Well, I do see that their are
  some names, for example, on the first page of
  Exhibit 1, and maybe that will help explain things
  for me.  I see Edward Fernandez children, or
  child.
       A.   We have child for -- he has a child
  support obligation.  We pay child support or give
  him the money to pay it.
       Q.   And that is consistent with your policy
  of not having debt for any of your --
       A.   Right.  Anybody who lives with us, if
  they have obligations we take care of them.  We
  work together.  Just for instance, he takes care
   of our dairy farm up there, and so we just -- if
  anybody has any debt, we take care of it.
       Q.   I understand.  Then I see Mueller is one
  person on here.
       A.   Who is that?
       Q.   M-u-e-l-l-e-r.
       A.   He's not with us no more.
       Q.   Well, there is a line item --
       A.   Yeah, but what happened, he turned in
  $12,000 that he had for child support.  That is
  what he did.  And we kept the $12,000 and we went
  to the state of Michigan and we made a deal to pay
  his child support off because he owed them child
  support, and we took his money and we paid his
  child support.  He turned it in to us and then we
  took it and paid the child support.
       Q.   So the line item for $13,652 in 2004
  would have been the payment of the child support?
       A.   Right.
       Q.   What is the personal line item on this?
       A.   That is probably things that I get for
  me personally or my wife, family.
       Q.   Which it's not a lot of money,
  obviously, but that is like clothing and whatnot?
       A.   Yes.
        Q.   Anything else that would be under that
  category?
       A.   No.
       Q.   I see there is a line item for Vernelle
  Bush?
       A.   Sister Bush used to live there with us.
  She is dead now.  She just died.
       Q.   Why would --
       A.   We have certain people who live with us
  that they have an income, and we keep a separate
  record for every person's income that they turn
  in, and she was one of them.
       Q.   When you say income, what do you mean?
       A.   They got checks, Social Security checks,
  retirement checks, people who got income.  There
  are some people that come there that are retired
  and they turn in their income.
       Q.   So that's why you would be getting, for
  example, $914 for several months from Vernelle
  Bush?  I imagine it's Social Security.
       A.   Her Social Security every month was
  right around $900 for a long time, yes.
       Q.   Why would there be an expense for
  Vernelle Bush?
       A.   Because she might want something.  She
   might want something and we buy it for her.
       Q.   How about -- I see under the income side
  Chris Gingrich?
       A.   Yes.  He's been on the farm for 30
  years.

Chris lived in Savannah, GA until sometime around 1999 or 2000
Chris never lived on the farm.  He moved on a piece of land Doug and his wife purchased in Bamburg county.  Where Rick Bell now lives.  Interesting thought……. Doug and his wife were in the same spot as Mike and Kathy Duvaul were in when we left there.  The only difference being that Doug had a monthly income from his father and was in line to inherit a lot of money when his dad dies.  This land was referred to as the River because it was on the river.  It was also the place where the women and children was instructed to run to if for any reason there was trouble at the farm with the authorities.

       Q.   And what income --
       A.   He gives his retirement funds.
       Q.   How about Lois Anderson?
       A.   She gives her Social Security check.
       Q.   Peter Scott?
       A.   Peter Scott, he doesn't work anymore,
  but when he did work he turned in his money.
       Q.   He worked outside of the community?
       A.   Yes.  We have people who work sometimes
  out of the community.
       Q.   This says Rios Tony, or maybe it's Tony
  Rios?
       A.   He's not with us anymore.
       Q.   What income did you have from him?
       A.   He had support for children that was
  given to him.
       Q.   Larivee Dennis?
       A.   Dennis Larivee.
       Q.   Dennis Larivee.  I'm sorry.  What income
  did -- actually, it's a negative income.
        A.   He doesn't have any income anymore.  He
  used to, but he doesn't anymore.
       Q.   WQIZ is listed as an income?
       A.   Yes.  We used to own WQIZ radio.
       Q.   And the income would be what?
       A.   We didn't get no income from WQIZ, that
  I know of.
       Q.   I am looking at the second page of
  Exhibit 1.  It reflects in June of 2003 $199,660.
       A.   Oh, we sold the station.  We sold the
  station.
       Q.   That is what I meant.
       A.   Yeah, the income.
       Q.   That was the proceeds of the sale?
       A.   Right.
       Q.   There is a line item under the income
  portion that says outside work.  Is that the
  people who work outside of the farm?
       A.   Yes.
       Q.   And their income is accounted there, is
  that correct?
       A.   Right.  In other words, they work
  outside, and they bring their paychecks back home
  and they give it to the church.
       Q.   Do you remember a gentleman named Geoff
   Steeby, S-t-e-e-b-y?
       A.   Yes.  He used to live with us for quite
  awhile and he moved back to Michigan.
       Q.   What expenditures would have been
  incurred on his behalf?
       A.   I would have to go check the records.
       Q.   You can't tell from looking at Exhibit
  1?
       A.   No.  He -- how much?  It couldn't have
  been too much.
       Q.   A couple of hundred dollars a month for
  several months.  I'm looking at Page 32, which is
  2002. I see his name on it.
       A.   I would have to go back.  Geoff has been
  gone for quite awhile in Houston.  I don't think
  we paid child support for him.
       Q.   I see it also in 2001.
       A.   He has been gone for about four years,
  so --
       Q.   And in 2000.  How about Gary Hinton?
       A.   Gary Hinton was a young man who came
  here.  He was in debt.  And, again, our brothers
  went out with the work and we took our money and
  paid him out of debt.  That was one of the fellows
  that came with nothing and went away with $6,000.
        Q.   Terry Peters?
       A.   Gary Peters?
       Q.   Terry Peters.
       A.   Oh, Terry Peters.  He still is with us.
       Q.   What expenditures would you be incurring
  on him?
       A.   Whatever he needs.  It might have been
  some money we sent to his wife, for his family.
  I'm not sure exactly of the expense.
       Q.   Now, looking at the income portion of
  these reports, there is one line item for
  offerings, and then just beside that is one for
  mail.  What does that mean?
       A.   That is offerings, too.
       Q.   That is what I was wondering.
       A.   Well, we have offerings that come in
  through the mail and offerings that people just
  give to us, like you do with contributions.
       Q.   So mail would be mail receipts of
  offerings?
       A.   Yes.
       Q.   There is a line item for checks
  returned.  What does that mean?
       A.   Checks returned?  I can't tell you.  I
  am sure it might be something we sent back to
   people, or refused or whatever.
       Q.   An offering you refused?
       A.   Yes.  Or sometimes they give us a check
  and it would bounce, so we would have to send it
  back.  And so you show in the record that it's not
  in the income anymore.
       Q.   One item, I'm looking here specifically
  at the 2001 summary report, it says left
  community?
       A.   Yes, people that left the community, we
  would give them some money.
       Q.   And that would go under that line item?
       A.   Yes.  I'm pretty sure you could find it
  under that line item.
       Q.   I notice that there are legal expenses
  that are incurred periodically.  For what would
  the Faith Cathedral Fellowship be incurring legal
  expenses?
       A.   The only legal expense we have is when
  we hired Mathias Chaplin and -- our friend right
  here.
       Q.   Right.  And for what purpose, this
  lawsuit?
       A.   Yes.  No, not this one.  We had the
  previous lawsuit, the criminal charges.
        Q.   The criminal charges as well?
       A.   Yes.
       Q.   And they are not large amounts.  But
  going back in time, we have legal from time to
  time as a recurring expense, and it might only be
  a couple of hundred dollars here and there, and
  I'm just curious what type of legal work that
  Faith Cathedral Fellowship would be needing?
       A.   We had the lawyer over in Alabama and we
  had Paul, but Paul didn't get much.  There can't
  be too much legal expense because we didn't have
  any other legal expense, that I know of.  We had
  to pay the lawyer in Alabama, and I think it was
  $2,000 and that was it.
       Q.   Did Faith Cathedral Fellowship pay for
  the expense of defending you in the criminal
  charges?
       A.   Yes.
       Q.   What year was that?
       A.   That was four years ago.
       Q.   Well, I see in the year 2001 that there
  were legal expenses incurred of over $130,000.
       A.   That is when we started the criminal
  defense.
       Q.   And then in 2002 you had legal expenses
   of over $340,000?
       A.   Because we had to put up the bond.
       Q.   For?
       A.   For the same charge.  You have to put up
  a bond.
       Q.   Did they get reimbursed to you at some
  point?
       A.   Yes.
       Q.   And that would be reflected on the
  income side?
       A.   Yes.
       Q.   How much was the bond, do you recall?
       A.   Had a cash bond of $200,000 and we had
  a -- what do you call it, a surety bond?
       Q.   Surety bond?
       A.   Yeah, surety bond.  The total bond was
  $400,000.
       Q.   And do you know where that would be
  represented on the income side of the balance
  sheet here?  Would that be under reimbursements?
       A.   I don't really know.
       Q.   Now, with respect to my clients, I know
  from the discovery responses I received from your
  attorney that, at least insofar as Butler, Duval,
  Hartley and Lindsey, you have stated that you have
   given them some money when they left the
  community?
       A.   Sure.
       Q.   Are those payments reflected on any of
  the documents that make up Exhibit 1 right there?
       A.   I am sure they are someplace in here
  that they were given out.  That is where we got
  the records from right there.  There is somewhere
  that we could produce the record of each one of
  those persons, the money given back to them.
       Q.   We are just not positive, sitting here
  today, which one of the expense categories those
  would fit under?
       A.   No.  I'm not sure.  Probably return
  funds somewhere.
       Q.   Like, you know, we have left community
  is one item.  Return offering is another item.
       A.   I will tell you this, that if you need
  those records, we can get them for each
  individual.  We can print out a record for each
  one of them.
       Q.   Okay.  Now, let's talk individually
  about some of these clients, the Allabys.
       A.   The Allabys never lived here with us.
       Q.   Okay.  I just want to talk generally
   about each one of them.  We will take them one at
  a time and your relationship with them.
            When did you first become acquainted
  with them?
       A.   As far as dates, I can't give you a
  date.  The Allabys go way back maybe seven, eight,
  ten years ago.
       Q.   Tell me that story, as you recall.
       A.   The story was they moved to a community
  in Canada that had a fellowship with us, or
  affiliated with us.  I never owned it.  I had
  nothing to do with it.  It was just a satellite
  group that had a fellowship with us.

They were called Unity Community and Faith Cathedral Fellowship had a charter or something like that to cover that community.

            And they moved out there, and they put
  their money out there, and then they left.  And
  when they left those people up there, whoever the
  two men up there who handled it, they never gave
  me the money.  It wasn't given to us and they
  never lived here with us.
       Q.   Did Faith Cathedral Fellowship ever
  receive any of the money that the Allabys donated?
       A.   Yeah, before they moved to the
  community, yes.  They used to send money here like
  hundreds of people do.  We have -- people send
  money all the time.
        Q.   So they donate through the mail?
       A.   Yes.
       Q.   And do you have any idea how much they
  donated?
       A.   The Allabys gave, between 1995 and 1999,
  $3,976.
       Q.   What were the dates again?
       A.   The dates were between 1995 and 1999.
  That is what they gave to us here.  What they gave
  up there, I have no idea.
       Q.   Do you know whether that is U.S. dollars
  or Canadian dollars?
       A.   That was U.S. dollars.
       Q.   I had a document that you-all produced
  that broke it down between Canadian and U.S.  I
  think I have an extra copy, actually.
            MR. UTSEY:  Make this Exhibit 2.
             (Plaintiffs' Exhibit No. 2 was marked
  for identification.)
            MR. CHAPLIN:  May I see that?
            MR. UTSEY:  Yes.
            MR. CHAPLIN:  Yeah.  You have some
  Canadian money there, too.
       A.   When we got Canadian money we put it in
  the bank.  We bank deposited it and they send us
   how much it is in U.S. currency.  After they run
  it through, they send back to us what it's worth
  in U.S. currency.  That is what we do.
       Q.   That is what I want you to clarify.
  This Exhibit 2 here, which is a document I
  received from your attorneys, has both Canadian
  and U.S. dollars.
            It's your belief that once you convert
  that all to U.S. dollars the amount is $3,976?
       A.   Yes.
       Q.   Now, have you ever seen this document,
  Exhibit 2, before?
       A.   No, I don't think so.
       Q.   Do you know anything about who prepared
  it?
       A.   Probably Sister Margaret.
       Q.   Moratto?
       A.   Yeah.  She might have done that because
  she could have went in and got the records.
       Q.   Is there any reason for to you believe
  that that is anything other than accurate?
       A.   No, no.  When it comes in, Margaret will
  write them down and then she will deposit it, and
  then the bank tells us what it's worth in U.S.
  dollars and then we put that into our records.
        Q.   Now, there is no indication on Exhibit 2
  that any money was ever refunded to or returned
  to --
       A.   Not from us, no.
       Q.   I mean, is that correct?
       A.   Correct.
       Q.    Faith Cathedral Fellowship did not give
  the Allabys any money?
       A.   No.
       Q.   Now, do you know whether the Allabys
  liquidated any assets and donated any money when
  they --
       A.   Not to me.
       Q.   Hang on a minute.  I am not trying to be
  rude, but it's going to make her job really hard
  if we are both talking at the same time.
            Do you know if the Allabys liquidated
  any assets and donated any money from the sale of
  those assets when they moved into the Canadian
  community?
       A.   I don't know.
       Q.   With respect to that Canadian community,
  what was it called?
       A.   Oh, I don't know if they had a special
  name at all.
        Q.   What did you refer to it as, the
  Canadian community?
       A.   Yes.
       Q.   Where was it located?
       A.   Saskatchewan.  It's still there.  As far
  as I know the men still have the farm.
       Q.   Who are the men that have that
  community?
       A.   The two men that -- we bought the farm,
  I can tell you that much.  But those two men, the
  Canadian government would not let a U.S. citizen
  own the land, and these two men were supposed to
  be our friends, so we put them on and -- I can't
  think of their names right now.
       Q.   So the purchase price for the farm was
  actually paid by Faith Cathedral Fellowship?
       A.   Yes.
       Q.   How much was it?
       A.   $15,000, I believe it was, or
  thereabouts.
       Q.   And you said that that community had a
  fellowship with --
       A.   Just a fellowship with us.
       Q.   What does that mean?
       A.   That means they believe what we believe
   and supported us and we supported them.
       Q.   Were the expenses --
       A.   No.  They took care of everything up
  there.
            MR. CHAPLIN:  Ssshhh.  Let him finish
  his question.
            THE WITNESS:  I'm sorry.
            MR. CHAPLIN:  Sorry about that.  I
  didn't mean to ssshhh you like a child.  I am just
  trying to make the statement and finish up because
  I'm ready for lunch.
       Q.   Were any of the expenses of the Canadian
  community reflected on the books of Faith
  Cathedral Fellowship?
A.  No.

I believe it was Geoff Steeby that kept the records for the Canadian community.  To help Mrs. Stair keep the records straight.  Maybe Greg Lindsey can tell you more because he was friends and room mate with Geoff.

       Q.   And was any of the income from the
  Canadian community on the books?
       A.   There was none.
       Q.   There was no income?
       A.   No.
       Q.   How many people resided up there?
       A.   Off and on there might have been three
  or four, five or six.
       Q.   Now, in respect to the farm here in
  South Carolina, or the community here, are there
   times that in your broadcast, for example, or your
  written word that you encourage people to become
  members of the community?
       A.   Absolutely not, no.
       Q.   How do people learn that you have this
  community?
       A.   They can go on our Internet site.  I
  talk about the farm.  I talk about our community.
  People come by and see us.  People come by to
  visit.
       Q.   When you talk about it, what do you say?
       A.   I just tell them we are at the farm,
  that we live here.  I use the scriptural approach
  where we live like the scriptures did in the Book
  of Acts.  You-all have all things common.  Nobody
  owes anybody anything.
            I like to tell them about the effect of
  living without debt.  And that is something that
  you can say to somebody, 75 people live here and
  nobody owes anybody money.  We are all out of
  debt.  That is an unusual situation.
       Q.   Do you explain that people are welcome
  to join the community?
       A.   No, no.  There is nothing to join.  I
  tell them straight out, you can't join this
   community.
       Q.   Well, join not in a membership sense,
  but join as in a physical sense?
       A.   No.  I never invite anybody to do that.
       Q.   How do people determine that they can
  give up things and move to the community?
       A.   They may come for a visit.  They may say
  can I come and visit you, or they come to
  service.  Then they will say to me, well, how can
  I be here?  And I say, well, you really can't.  I
  say, we just don't have -- we have nothing to
  join.
            And then if they persist they would like
  to live like that, then I will let them come for a
  visit.  Two or three times they come, and if then
  they determine they want to abide by the
  situation, if they want to do what they want to
  do, give up everything, then they do it, and they
  come with that understanding.
       Q.   So you have some conversation at that
  stage of what would be necessary for them to move
  there?
       A.   Yeah.  If they keep implying that they
  would like to live with us I say, do you
  understand how we live here?  This is how we live.
   Do you want to do that?
       Q.   Now, at your website, or anything else
  that you publish, whether it's broadcast-wise or
  written-wise or anything, have you ever described
  the farm in Saskatchewan?
       A.   No.  I did when we were affiliated with
  them, when they had a fellowship with us, yes.
       Q.   Oh, you no longer have a fellowship with
  them?
       A.   No.  They pulled away from us about four
  or five years ago.
       Q.   What were the circumstances of that?
       A.   I guess the criminal case.  Tim Butler
  can probably tell you more about that.
       Q.   Was there anything written by them or
  by --
       A.   We had no legal ties whatsoever.
       Q.   I understand.  But, I mean, did somebody
  write you a letter, for example, saying we would
  like to sever our fellowship?
       A.   Yeah.  One of the gentlemen up there
  just called me one day and said we are not going
  to have anything more to do with you, and that was
  the last I heard from him.
       Q.   And you are thinking that was about four
   years ago?
       A.   Yes.
       Q.   Prior to that, how long had they been in
  fellowship with Faith Cathedral?
       A.   Two or three years.
       Q.   During that two- or three-year period,
  is that when you would have talked about that farm
  and your Internet broadcast?
       A.   I talk about different communities that
  fellowship with us, even now, in different parts.
  We have one group of people up there in North
  Carolina who are pastors.  We have a group of
  people over there in Kentucky.  We have a group of
  people out in Oklahoma.
            And just like a church.  I would say we
  have fellowship over there.  If you want to attend
  church there, you may do that.  It's just like you
  advertise services in different locations around
  the world.
       Q.   Right.  But I began this discussion when
  we started talking about the Allabys and the fact
  that they moved to the farm in Saskatchewan.
       A.   That was their desire.
       Q.   But during the period when they moved
  there, were Faith Cathedral Fellowship and that
   farm in fellowship together?
       A.   Sure.
       Q.   And during that period was Faith
  Cathedral Fellowship discussing the farm in
  Saskatchewan on its website and in another --
       A.   We have mentioned that we have a
  fellowship up in Saskatchewan, sure.  That is how
  they found out about it.
       Q.   And did you describe what the farm was
  like up there and what the principles were behind
  it?
       A.   No.
       Q.   You didn't say, like you did here, that
  people give up everything to live here and --
       A.   No.
       Q.   What did you say?
       A.   I just told them if they want to visit,
  they can go visit.  That is what the Allabys did,
  as far as I know.  They went out there to visit
  and decided they wanted to live out there.

No one could move there or to any community affiliated with Stair without His permission.

       Q.   Do you know how long they stayed there?
       A.   Maybe a year, year and a half.  I don't
  know.  One day they left and they were gone.
       Q.   Do you know why they left?
       A.   I guess they didn't want to live there
   any longer.
       Q.   But did you know anything more about
  their decision?
       A.   They probably didn't like the situation.
       Q.   What situation?
       A.   Whatever situation, how we were living
  there, the situation with the people.
       Q.   I understand.  But I am not asking you
  to speculate.
       A.   There was no specific thing that I know
  of, no.
       Q.   That is what I'm asking, whether you
  knew of any specific reason.
       A.   No.
       Q.   Do you know whether the individuals who
  were running the farm in Saskatchewan returned any
  money to the Allabys?
       A.   I have no idea.
       Q.   Have you had any contact with the
  Allabys since they severed their ties with that
  farm?
       A.   No.
       Q.   Have you ever offered to reimburse or
  return any money to the Allabys?
       A.   No.
        Q.   Have they ever asked you to?
       A.   No.
       Q.   So it's just never been something you
  had to decide whether to do or not to do?  Is that
  fair to say?
       A.   When they left, they left.
             (Plaintiffs' Exhibit No. 3 was marked
  for identification.)
       Q.   Let's talk about the Butlers now.
            MR. CHAPLIN:  Can I interrupt one
  second?
            MR. UTSEY:  Yes.
            MR. CHAPLIN:  When do you think we are
  going to have lunch?  Because I have quite a few
  questions that I want to follow up with as well.
            MR. UTSEY:  Well, we have to go through
  all the plaintiffs, so it's going to be a little
  while.  I didn't know if you wanted to push
  through and then take a lunch break, or go ahead
  and take a lunch break and -- I don't care one way
  or the other.
            MR. CHAPLIN:  Well, can we just think
  about it and kind of set something up?  I need to
  return a few messages.  I would like to have some
  lunch.  But I just wanted to work with you.  I
   don't want to break your flow here.
            MR. UTSEY:  It doesn't matter to me.  I
  mean, if you want to take a lunch break now, we
  can take a lunch break now and then resume until
  we finish, or we can keep going for a little while
  and then take a lunch break.  I'm flexible.
            MR. CHAPLIN:  Because the depositions we
  have after him, they are on standby.  They know
  they need to be here today.
            MR. UTSEY:  Right.
            MR. CHAPLIN:  So if we could take a
  break now, that would be great.  Until when?  I
  mean, since you are at a different climate, or a
  different person.  You are getting ready to move
  to a different person now, right?
            MR. UTSEY:  Yes.  It's a good time.  We
  will take a break and go off the record.
            (Lunch recess taken.)
       Q.   I told you I was going to ask about what
  you did at lunch and who you saw.  I want you to
  tell me.
       A.   I saw my wife and I saw Mr. Landry.
       Q.   Did you have any conversations with
  anyone concerning the deposition?
       A.   Yeah.  We talked a little bit about the
   bookkeeping situation.
       Q.   Who did you discuss that with?
       A.   My wife.
       Q.   Did you learn any additional information
  aside from what you and I have already discussed?
       A.   Only that we can get you all the records
  that you need, that has to be done.
       Q.   Did you determine what type of software
  program is used for that?
       A.   Money Count.
       Q.   Money Count?
       A.   No, QuickBooks.
       Q.   Okay.
            MR. CHAPLIN:  She is in the lobby now,
  by the way.
            MR. UTSEY:  Yeah.  I met her a minute
  ago.
            MR. CHAPLIN:  Okay.  So we don't have
  any lag time.
            MR. UTSEY:  Okay, good.
       Q.   Did you learn any other information in
  your conversation with her?
       A.   No.
       Q.   Did anyone give you any suggestions
  about how to answer any questions for the
   remainder of your deposition?
       A.   No.  I guess that would have been me
  giving them suggestions.
       Q.   Well, I can ask them about that.
       A.   Yeah, sure.
       Q.   Okay.  We have talked about the Allabys,
  and I think we were getting ready to discuss --
       A.   I explained that to you, if you remember
  that.  That is Canadian funds.
       Q.   Right.  We have already finished --
       A.   When you break that thing down, it's
  about $1,500 less than that in U.S. currency.
       Q.   Which is about the number you gave me?
       A.   Right.
            MR. CHAPLIN:  So you had that confirmed
  while you were at lunch?
            THE WITNESS:  Right.
       Q.   You did confirm that?
       A.   Yes.
       Q.   All right.  Now we know where the
  numbers go.  Let's get this one out of the way.
  Unless you need these, I am just going to move
  them so they don't confuse you.
       A.   I don't need them.
       Q.   Tell me about -- I want to talk to you
   now about the Butlers.  How did you first become
  acquainted with them?
       A.   On the radio.
       Q.   Pardon?
       A.   They heard me on the radio.
       Q.   When did you first speak with them?
       A.   I don't know dates.  I can't give you
  dates.
       Q.   Do you know approximately when that
  would have been?
       A.   Well, it was somewhere around '97, '98,
  somewhere along in there.
       Q.   How did you first have contact with
  them, by telephone, in person, what?
       A.   Yes.  They started to support us, and
  they started to call, and then they wanted to come
  for a visit and they came for a visit.
       Q.   When you talked to them on the
  telephone, do you remember any of the
  conversations you had with them?
       A.   Not particular, no.  There was nothing
  particular about it, except maybe just the
  ministry, what I preach and what I talk about.
       Q.   Do you remember specific comments that
  you made to them or they made to you in those
   conversations?
       A.   Not on the phone, no.
       Q.   So you-all arranged for them to visit
  the community here?
       A.   They wanted to come for a visit, so we
  let them come for a visit.
       Q.   And that would have been the farm here
  in Colleton County?
       A.   Yes.
       Q.   And do you remember when that was?
       A.   No, I don't remember the dates.  I'm
  sorry.  I just don't remember dates.
       Q.   And that's all right.  And you
  understand I need to ask, because until I ask I
  won't know what you do know.
       A.   I can find approximate dates, but I
  don't remember them.

  Q.   Tell me the circumstances of their
  visit?
       A.   When people come for a visit we give
  them a place to stay, and they live with us like
  we live here.  They go out and we start working,
  what we do on the farm, and they talk to the other
  people and they find out how we live.  This is how
  we do it.  We all work together.
             We produce our own food.  We grow our
  own crops.  We very seldom have to go buy anything
  because we produce everything.  We have our own
  ability to farm.  We have our own ability to
  repair cars.  We have our own carpenters.  We have
  electricians.  We are a self-sufficient
  community.
            And we don't need any money outside.  We
  have people on that farm that haven't gone off the
  farm in 15 years.  Don't have to.  I don't go off
  it.  Mag (phonetic) said to me this morning, wow,
  we haven't seen you in awhile.  I stay on the
  farm.
       Q.   Right.
       A.   And they come and they live and they see
  what we do, and then they go back.  That is the
  procedure we have always used.
       Q.   How long was the Butlers' visit?
       A.   A week or two.  You mean to live?
       Q.   No, no, when they first came.
       A.   Oh, about a week.  When I let the
  Butlers come I broke my rules.  I don't mind
  telling you.
       Q.   What do you mean?
       A.   Because I let them come with debt.  They
   were in debt.  He owed the IRS $60,000 and he owes
  the state of Ohio $30,000, or something in that
  area.  Because he wouldn't pay -- he was a
  patriot.  Do you understand what I mean when I say
  a patriot?
       Q.   Someone who claims that they don't have
  to pay the government?
       A.   Pay taxes, right.  And that is what he
  was, and he didn't pay taxes.  He didn't do it.
  When he came to me I said, wait a minute, we pay
  taxes.  We don't do that.  We are not going to
  play that kind of deal.
            So I initiated a contact with the IRS
  and with the State of Ohio and we worked out a
  settlement plan on how to pay his debt, which was
  a great savings, to tell you the truth.

I did the initiating at the suggestion of Mr. Stair. I owed the IRS 42,000 and Ohio 5,000 and we was able to get the IRS reduced to 11,700 I believe.

            But when you do that, when you make a
  deal with a federal agency like that, if they
  agree to a certain amount they will say you have
  ten days.  That's the reason why he couldn't pay
  his debt, because he couldn't come up with that
  kind of money, but because he was part of the
  community and we took the responsibility, we took
  the money and we paid his debt.
            And so then whatever he earned, he
   contributed just like everybody else did.  But we
  paid that particular debt because one of our rules
  is no debt.

We had 120 days to pay and I earned all that money to pay it off within 90 days.

       Q.   Now, you had some note cards with you a
  minute ago.
       A.   I don't -- oh, I wish I knew -- did I
  leave them here?  Because I don't know what
  happened to them.  I thought I left them here.
       Q.   Well, I was just going to ask you about
  these amounts because you said them so quickly.
       A.   We have the amounts.  We have the
  amounts.  We gave Tim Butler back in cash.
       Q.   I am going to get to that in a minute.
  The amounts that you just were saying a moment ago
  about his indebtedness --
       A.   Yes.  I would have to go home and find
  out how much we paid.
            MR. CHAPLIN:  Well, what did you say a
  minute ago?
       Q.   You said something about the State of
  Ohio and --
       A.   He owed the State of Ohio income tax.
  He owned the IRS income tax.
       Q.   Do you know how much?
       A.   It was around $60,000.  I don't know the
   exact figure.
       Q.   All total?
       A.   The IRS.
            MR. CHAPLIN:  I thought you said 90.
  You said 60 and 30.
       A.   Yeah.  The IRS was around 60 and the
  State was about 30, I think it was.  I can't be
  exact on that because I don't know, but it was in
  that bracket, and we paid both of them off.
       Q.   How much did you pay to pay them off?
       A.   I think -- like I'm saying, you are
  asking me for figures that I can't come up with
  right off.
            MR. CHAPLIN:  He said ballpark.
       A.   I would say about $30,000 for the IRS,
  which was reduced from $60,000, and the State
  $30,000.
            And what I had Tim Butler do -- he was a
  truck driver.  And you understand when these
  people come to live with us, we pay all of their
  living expenses.  They don't have to buy no food,
  no clothes, no gasoline for their cars, none of
  those things.
            The church -- they live with us.  Their
  life becomes that way, and that is how we do it.
   And whether you give much -- did you see that
  young man that stood right at that door there?
  Did you see him?
       Q.   Yes, sir.
       A.   That young man gave $2 million, sir.
  He's not asking for it back.
       Q.   Well, I am just talking about Mr.
  Butler.
       A.   I am trying to tell you what these
  people do, whether you come with nothing or
  whether you come with everything.  Whatever you
  have, you give it, just like me.
            For 25 years I have given.  What do you
  think a man like me would be worth if I was a CEO
  in a large corporation?  Could I make a $100,000
  salary?  Patch (phonetic) over here does, why
  can't I?  But I don't.
            We even pay taxes on the farm up there.
  As a church we don't have to, but on a certain
  part of it I agreed to pay taxes.
            MR. CHAPLIN:  Let's go back to Butler.
  That was --
       A.   Well, Butler came.  And he was a truck
  driver, so I kept him driving the truck so we
  could get his money.  I took his money, put it in
   the church's account, and then we took it and paid
  the debt.

Look at the wording.  Mr. Stair says what he really wants then covers it up with added words.  …."so I kept him driving the truck so we could get his money." ……

       Q.   I am getting a little off track, because
  I was kind of going through this chronologically.
  I was talking about their first visit, which I
  think you said --
       A.   The first visit, they worked around on
  the farm and then they went home.  They went back
  to Ohio.
       Q.   During that visit, is that when you
  broke your rule and agreed to accept someone with
  debt?
       A.   No, no.  When he first came I wasn't
  sure I wanted to have him come live with me
  because he had a bunch of young children,
  teenagers, and teenagers are trouble, especially
  if you bring them in and they are not used to this
  kind of -- and his boy became very much
  troublesome.

Matthew did as he was asked and Mr. Stair gave him a terrible time so he left in 2000 and we couldn’t see or speak with him for a whole year. Mr stair wanted him out of his way because he was competition for the young ladies he wanted.  Mr. Stair treated Timothy and Steven Jones in the same manner as Matthew.  The only difference is that they would not leave.  Mr. Stair had to force them to leave.  Timothy and Steven are Pastor Timothy Jones boys.

            You see, if you bring a teenage son with
  you, he comes because you are coming.  He's not
  coming because he wants to be there.  Can you
  understand that?
       Q.   Yeah.  I understand what you are saying.
       A.   So when you do that, then after awhile
   they don't want to be there and so then they start
  causing you trouble.
            And at first I said, you have a boy
  right here.  I said, you are going to bring him
  along and he doesn't want to be here.  And so he
  went back home, and later on he conceded that he
  would bring his children and he brought them.
  They brought the children.  But, like I said, the
  boy gave me trouble, gave us trouble.
       Q.   During this first visit, did you have
  conversations with Mr. or Mrs. Butler about the
  prospect of them living there?
       A.   They had let me know that they would
  like to move there with us, yes.  Anyone that has
  ever came on there, after awhile the issue would
  come up.
            And then I say, well, you want to live
  here with us?  Do you see how we live?  Can you
  live with us?  You know the rules.  Whatever comes
  here -- everybody, everybody, no matter who it is,
  you give what you have.  They didn't have to do
  it.  They could have kept it.  But they couldn't
  keep it and come here.
       Q.   Now, are you the person with Overcomer
  Ministries that had that conversation with the
   Butlers?
       A.   Yes, sure.
       Q.   Do you know if other people did?
       A.   I am sure they talked with the other
  people about it.
       Q.   Did you explain to them about the rules,
  that you give everything up?
       A.   Yes.  The rules are written out and the
  rules are given to them.  They know the rules.
  Every person there knows the rules.

We never saw any papers or signed anything with rules on them. I don’t recall anyone doing that.

       Q.   Where are the rules written?
       A.   We even have some papers up there where
  they signed.  I don't know whether the Butlers
  signed theirs or not.  But we have some people who
  would sign, yes, everything, everything they give.
       Q.   Now, where the rules are written, what
  do you call this document?
       A.   It's not a document.  It's just an
  understanding that we have amongst each other.
       Q.   Is it written?
       A.   Not necessarily.  Right now we have some
  places where people have signed some documents.
  When this thing started to develop, we come up
  with a little document.  Now, I would have to go
  home and see if the Butlers signed it or not.
        Q.   When what thing developed?
       A.   This nonsense with these people asking
  for their money back, which you don't ever do with
  the church.  You give money to a church and you
  don't ask for it back.  That is something anybody
  does.  Do you give money to a church?
       Q.   Since these lawsuits, are you saying
  that you developed a document to have people who
  live in the community sign?
       A.   We wrote a little document so these
  people understand fully that they agree to this,
  that when you come here that we are not obligated
  to give your money back.  You are getting what you
  are giving as an offer, just like when you walk
  into your church and you lay down your offering.
  That is an offering.
       Q.   When did you begin having people sign
  that document?
       A.   I don't really know that either.  I
  would have to go back and look at it.
       Q.   Who drafted that document?
       A.   Probably one of our brothers.  It's just
  a little statement that we agree that this is what
  we want to do.
       Q.   Now, I understood -- and maybe I
   misunderstood your testimony a moment ago, where I
  thought you said the Butlers had read the rules
  because they were in writing?
       A.   No.  The Butlers -- nobody reads the
  rules.  When they come there I tell them, if you
  want to live here, this is what we do, this is
  what we believe.

Again watch his wording…… "Nobody reads the rules."    That is because there are no rules.  You live there because you are afraid that if you don’t live in a community setting and don’t do what Mr. Stair a.k.a. The Last Day Prophet of God, says then you are damned to hell.

       Q.   That is what I'm trying to drive at.  I
  want to know what it is --
       A.   I explained it to you three or four
  times already.  We don't have nobody come with
  debt.  You have to be out of debt.  We don't have
  debt.  If you have a debt, you can't come.  You
  clear out your debt first.  That is a rule.  We
  don't buy anything on credit and we don't go in
  debt.  Isn't that commendable?  I think it is.
       Q.   I am asking you what you told the
  Butlers.  Is that --
       A.   I told the Butlers what I tell
  everybody.  If you want to live here with us -- if
  you live here with us, everything you have you
  give to the church, everything.  And if there's
  anything you need, then we will provide it while
  you are here.
            And then you work.  You work in the
   community.  Whatever needs to be done here, we do
  it and we do it together.
            And there are certain things we believe
  in in the spiritual realm.
            We don't run to doctors.  Although, we
  do go to doctors if we have to.  If they want to
  go, they may go, but most of these people don't
  want to go.

He would say "You can go to a doctor but if you do don’t come back"
No one left the community without being sent by Mr. Stair.  If you did, you knew that you would receive Mr. Stairs wrath at the dinning hall after the next meal or in the tabernacle when he was preaching to the whole world.

            Most of them come with their own
  opinion, this is what they want to do.  They want
  to believe in God.  They want to believe in God
  for their healing and for their health and for the
  deliverance.
            And that is voluntary.  If they want to
  go -- they can live any way -- you understand that
  I have several hundred people outside of the
  community that support us?  And they don't -- they
  go to doctors.  They do the things they want to
  do.
            I don't require them to live like I do,
  except if you want to live under our auspices,
  this is the way we live here.  That is just the
  way we do it.
       Q.   And is that the extent of what you
  explained to the Butlers during this first visit?
        A.   Sure.
       Q.   Was there anything else you talked to
  them about?
       A.   No.
       Q.   Did you talk to them at all about what
  their offering to the church would be used for?
       A.   Everybody knows what the offering is
  used for.  I even get on the radio and do that.  I
  tell them.  I spend -- 90 percent of the income
  goes for the radio broadcast because that is what
  this is all about.  This is a ministry that
  reaches the world.
            My dear friend, while I'm sitting right
  here talking to you I could take this phone and I
  could talk to the entire world.  God has blessed
  me.  God Almighty, Yahweh, has blessed me to be
  able to speak to the entire world, and that is
  what I do, and I do it very faithfully.
       Q.   And did you have any conversation with
  the Butlers about the expenditures other than the
  90 percent going to radio?
       A.   No.  Why should I?  Every bill --
  everything up here gets paid.  People know where
  it goes.  We tell the people from time to time
  about this, we had to buy that, we do this, we do
   that.  People know where the money goes.
       Q.   But the Butlers were visitors.  That's
  what I'm driving at.
       A.   No, no.  The Butlers -- when they came,
  they knew where the money went.  They knew.
       Q.   And how did they know?  That is what I'm
  trying to figure out.
       A.   What do you mean how did they know?
       Q.   Well, someone had to tell them --
       A.   Tell them what?
       Q.   -- or they had to get the information
  otherwise.
            MR. CHAPLIN:  Just --
       Q.   I am simply asking you was there any
  conversation with the Butlers during their first
  visit --
       A.   Not any more than anybody else, no.
       Q.   I am not asking to compare.  I want to
  know specifically what you recall about the
  conversation with the Butlers about where the
  money they donate, or would donate, would go?
       A.   No, not any particular.  Not more than
  anybody else, no.
       Q.   Well, what would you have done with
  anybody else?  That is what I'm driving at.
        A.   What I tell you, is that we tell the
  people all the time here is what we buy, here is
  what we do, here is where the money goes.  The
  electric bills are so much.  The gasoline bill is
  so much.  I bought $12,000 worth of honey the
  other day.  I tell the people where the money
  goes, and then I can back it up.
       Q.   And you explained all of that to the
  Butlers in this initial visit?
       A.   Sir, we have a common --
            MR. CHAPLIN:  Yes or no.
       A.   Yes.  Yes, I explained it to them.  They
  understood.
       Q.   Now, I'm not asking what you think they
  understood.  I am asking you what you told them.
  You told the Butlers --
       A.   I didn't tell them specifically any more
  than anybody else, but they did know.  They did
  hear.
       Q.   I don't mean to sound like I'm arguing
  with you, but you have to remember I understand
  you have had conversations with a bunch of people
  like this, so it's easy for you to compare your
  conversations with the Butlers with other people,
  but I haven't been privy to any of those
   conversations.
       A.   What I'm trying to say is we have a
  major dining room, a fellowship hall, and we have
  a meeting room, and it's in those places where we
  discuss everything right out in the open all the
  time.
            For instance, the other day I went and
  bought some honey.  And I got back up in the
  dining room and I said, today we just spent
  $12,000 to buy some honey.  I said, now, you-all
  be careful how you use it.
            Or we bought some gas the other day
  because it's cheaper.  I can buy it -- and
  everybody in the community, you can bring any of
  them in here and sit down and they would tell you
  they have heard how the money goes, where it goes,
  even when it comes in, even when it comes in.
       Q.   In the initial visit with the Butlers,
  did you go through all of the expense items that
  would be reflected in Exhibit 1?
       A.   No, no, no.
       Q.   Did you go through --
       A.   No, no, no.
       Q.   -- all of the categories that would be
  reflected by Exhibit 1?
        A.   No.
       Q.   At any point did you go through that
  with the Butlers?
       A.   No.
       Q.   Why not?
       A.   Because it's not required.
       Q.   For example, when we talked earlier you
  explained how some people have child support
  obligations that the community will pay?
       A.   It's understood that when they come
  there that all of their responsibilities -- that
  every obligation they might have will be taken
  care of.
       Q.   Did you explain that to the Butlers?
       A.   Yes, sir.
       Q.   And did you explain to the Butlers that
  you --
       A.   I explain it to the general population
  that --
            MR. CHAPLIN:  You have to let him finish
  the question, Brother Stair.  I know this has you
  infuriated, but let's hear the question.
       Q.   During the Butlers' initial visit, that
  one-week approximate visit --
       A.   Yes, they understood that.  I'm pretty
   sure they did.
       Q.   No.  I'm not asking what they
  understood.  I'm asking what you told them.
       A.   Yes.
       Q.   You told them that you were paying child
  support for some people?
       A.   No.  I didn't tell them we were paying
  child support for anybody.  What did -- that had
  nothing to do with their situation.
       Q.   Did you tell them that you were paying
  some people for leaving the community?
       A.   No.
       Q.   Did you tell them that you were spending
  money on legal expenses?
       A.   No.
       Q.   Did you have any subsequent
  conversations with the Butlers after that one-week
  visit?
       A.   Not that I can recall.
       Q.   How did you know that they had decided
  to join the community?
       A.   They let me know they wanted to come.
       Q.   Pardon?
       A.   They just let me know they wanted to
  come.
        Q.   Was that a telephone call or a letter or
  what?
       A.   Either a letter or a phone.  I am not
  sure.
       Q.   And when was it that you made the
  decision to permit them to come despite the tax
  obligation that he had?
       A.   I can't recall.
       Q.   How did you communicate that to Mr.
  Butler?
       A.   Might have been by letter, or phone, or
  he might have came to see me.  I really don't
  know.
       Q.   Did you explain to him, as I think you
  characterized it earlier, that you were breaking
  one of your own rules to allow him to do that?
       A.   Yes.  He knew that.  I told him that.
       Q.   As best you can recall, exactly what did
  you tell him?
       A.   I told him that I was going to let him
  come, and that he was to keep on working, and that
  we would take his money and we would clear out
  this debt, and that is exactly what we did.
       Q.   And you told them that was the first
  time you had done anything like that?
        A.   Sure.
       Q.   And I think you indicated you actually
  negotiated with the IRS to reduce the lien from 60
  to approximately 30?
       A.   Yes.
       Q.   And did you negotiate with the State of
  Ohio?
       A.   Yes.
       Q.   You said it was approximately $30,000 he
  owed the State.  How much did you negotiate that
  down to?
       A.   I don't really know.
       Q.   Where in Exhibit 1 would the payments to
  the IRS and State of Ohio on behalf of Mr. Butler
  be found?
       A.   I don't know that either.  You would
  probably have to go back and look under Mr.
  Butler's name, and then we would find out what he
  gave and what we gave back in reference to him.
       Q.   But it would be an expense payment,
  though, that would be reflected somewhere on
  Exhibit 1, wouldn't it?
       A.   Yes.
       Q.   Do you remember approximately when it
  was that you paid those two debts?
        A.   No.
       Q.   Do you remember when approximately the
  Butlers moved to the community?
       A.   I could get the date, but I don't
  remember them.
       Q.   Let's look at these documents that
  comprise Exhibit 1.  I notice that as of 1998, I
  guess as of April of 1998, you begin to reflect
  income under the name Tim Butler?
       A.   Right.
       Q.   That would be his earnings as a truck
  driver?
       A.   Yes.
       Q.   Do you think, then, that 1998 would have
  been when you paid his taxes?
       A.   Yes.  That could be the same time.
       Q.   Now, I'm looking again on the 1998 page
  of Exhibit 1, and under the expenses it says Tim
  Butler, and I have got several entries which total
  $17,719.  Do you think that --
       A.   I am not sure whether that was for the
  IRS or what it was.  I would have to go back and
  verify that.  We also bought a motor for him at
  that time, I think, that cost quite a bit of
  money.

That money was for the IRS debt of 11,000 something and the State of Ohio debt of 5,000 something.
        Q.   In 1999 there is an expense line for Tim
  Butler which totals $1,503.  Do you know what that
  was?
       A.   No.
       Q.   And in 2000 there is an expense item
  totaling $552 for Tim Butler.  Do you know what
  that was for?
       A.   It might have been for some tools.
  That's how much in tools we bought for him to work
  on his truck.

Each year we had to pay the H.U.T. (Highway Uses Tax)  I believe that it was $550.   The $2. Could be for money order that we used to pay it with.

       Q.   And in the year of 2001 I see a total of
  $32,017 paid for Tim Butler.  Of that, one amount
  was rounded off to $30,000 in August of 2001.
       A.   That sounds like the IRS situation
  there.
       Q.   Do you believe -- the remaining $2,017
  was for what?
       A.   I really couldn't tell you.
       Q.   Now, you said something about buying a
  motor for Tim Butler.  What was that?
       A.   He wanted a new motor for his truck.
       Q.   Did he own the truck?
       A.   Yeah, he owned the truck.
       Q.   I didn't know whether he had donated
  that to --
        A.   No, he didn't donate the truck.  He
  would have if I had taken it, but there was no
  need for it.  It was tagged in his name.  It was
  titled in his name so he could drive the truck,
  and so we just left it that way.
            But, like anybody else, the income that
  came in from it was donated to the farm, to the
  ministry.
       Q.   And then the expense for the truck was
  paid by the farm?
       A.   Yes.
       Q.   And that would be the motor, for
  example?
       A.   Right.  And we would even give him some
  money to make his trips, give him cash money so he
  could drive on the road.
       Q.   Did you pay for the fuel?
       A.   Yes, indirectly.  Like I say, we would
  give him some -- he would bring his check home,
  and we would let him keep a certain amount of that
  for his operating expenses.

I got advances from my company to pay for fuel and most repairs. The checks turned into Stair reflected money earned minus those advances.    When Tim would make the trips to the different communities with the semi Mr. Stair would give him money for fuel.  Tim had to account for every penny that he spent.  I know this because I was the one that wrote it all down for Mrs. Stair to make it easier for her to record them in her records.  Tim even kept a log book and records of all the miles that he drove in what state so he could pay the taxes out of the advance money that he got from his job. 

            What I should have done was take it all
  and then make him -- then give it back to him.
  That's what I should have done.  I goofed on that
  one.
        Q.   Now, this is Exhibit 3, a document that
  was produced by your attorneys to me.  Do you
  recognize that document?
       A.   Pretty well.
       Q.   Do you know who prepared that document?
       A.   That looks like Sister Margaret's work.
       Q.   Do you know whether it's accurate?
       A.   As accurate as it could be on the
  figures that she has, because she writes down what
  the people do.
            MR. CHAPLIN:  Yes or no.
       A.   Yes.
       Q.   Tell me what these amounts mean.  $2,850
  in 1995, is that just a cash contribution or
  offering?
       A.   I would say so, yes.
       Q.   Same for those next three items?
       A.   Yes.
       Q.   And then there is a line that says
  working offerings net of expenses.  What does that
  mean?
       A.   I don't know.  I am sure there are some
  expenses that are probably involved in that
  somewhere.
       Q.   Well, those are documented for 1998
   through 2001.  Would this be the income he
  generated as a truck driver that was paid to the
  ministry, net of the expenses of his generating
  that income?
       A.   Very possible.
       Q.   Do you know whether the net of expenses
  includes the expenses that were incurred to pay
  off his debt?
       A.   No.  Those are probably expenses just to
  run his vehicle.
       Q.   Do you know that or are you just
  assuming that?
       A.   That there does not -- those figures
  don't match up with the debt that we paid.
       Q.   Well, wouldn't you need to know how much
  income there was in order to know whether it
  matches up?
       A.   No.  It would have made no difference
  how much income.  It wouldn't have made a bit of
  difference how much income.  We are determined to
  pay the debt, whether he had any income or not.
  We would have paid his debt whether he was making
  a dime or not.
       Q.   Well, I understand that.  What I'm
  saying is if these are net figures --
        A.   This is probably operating.  If there is
  any expense in that, it's probably operation of
  the vehicle.
       Q.   But do you know that with 100 percent
  certainty?
       A.   No.
       Q.   Who would know that, Margaret?
       A.   We would have to go back and look in the
  book, in the bookkeeping.  It would show up in the
  records somewhere.
       Q.   Well, this reflects total given of
  $67,732.  Again, would that be using the net
  figures?
       A.   Yes, as far as I can tell.
       Q.   And it says $30,000 returned 8/2001.
  What does that mean?
       A.   That is the cash money we gave back to
  him when he left.
       Q.   A minute ago when we were looking at
  Exhibit Number 1 we got to the year 2001.  And
  specifically in August of 2001 I asked you about a
  $30,000 figure and you said that may have been the
  IRS.
            Now that you look at this Exhibit 3, do
  you think that was the money you returned to Mr.
   Butler?
       A.   It could have been.  The IRS figure
  might have been put in another realm.  I would
  have to look.
       Q.   How is it that -- well, let me ask you
  this.  You have said earlier that you were the one
  that made the decision on how much money to return
  to anybody if you ever did return money, correct?
       A.   Sure.
       Q.   So you decided the $30,000, that you
  would pay the $30,000?
       A.   Yes.
       Q.   How is it that you came up with that
  figure?
       A.   Well, you see, we calculated -- these
  brothers out here calculated that the living out
  here is about $15,000 to $20,000, if they were
  living out someplace else, providing housing and
  everything else for them, it would be about
  $20,000 a year.
       Q.   Who calculated that?
       A.   Brother -- Mr. Duval, who was a very
  economic man.  He said, when you live on this
  farm -- he said, the way we live, he said, it
  would probably cost us $22,000 a year if we lived
   anywhere.
       Q.   22?
       A.   Yeah, 20 or 22.  Oh, come on now.
       Q.   No.  I just didn't hear you.  I am
  trying to hear what you said.
       A.   Yeah, 22.
       Q.   So what did that have to do with the
  $30,000 amount for Mr. Butler?
       A.   I just decided to give Mr. Butler some
  money back because he had given quite a bit, and I
  decided I wasn't going to let him go out without
  any money.
            Technically, I didn't have to give him
  anything.  He gave to the church.  I don't have to
  give money back when people donate to a ministry.
  You don't have to do that.  That is not required.
       Q.   Okay.  I am just trying to figure out
  how you came up with 30,000, and not 25 or not 35
  or some other number?
       A.   No particular reason.  Larry Hartley I
  gave 70.  Another guy I gave $5,000.  Another guy
  I gave $3,000.  I gave them what I felt like I
  could -- so they could get out there and get
  started again.
       Q.   Is there any other fact that you
   considered in determining that $30,000 would be
  the appropriate amount to give him?
       A.   No.
       Q.   Is this the only money that you returned
  to Mr. Butler, the $30,000?
       A.   Cash, yes, that's the only money
  returned.
       Q.   What else did you give him?
       A.   He took tools.  He took the tools we
  bought for him.  He took food out of our
  warehouse.  He backed his truck up and loaded it
  up with food.  What is the value of that?  I have
  no way of valuing that.
Q.  Can you approximate that value?

All of our stuff was loaded on their strait truck. I had no trailer, just a semi. The only food givin us was a 5 gallon pale of peanut butter. We brought over 200 quarts of food when we came.

       A.   No.  How can I approximate?  I mean, I
  could guess, but that wouldn't be very well.
       Q.   Do you know what the value of the tools
  were?
       A.   Yeah.  The tools were several hundred
  dollars.  I'm sure of that.  Some of those tools
  you bought for that truck cost you four or five
  hundred apiece.

I took an air wrench that I paid for from the money that I took from load advanced (talked about above) The rest of the tools I took I brought with me.      About half of the community left the same day that we did.  We all were forced off the land because they didn’t want us defiling their Sabbath by being in the community.  So if there was any tools missing……it could have been taken by anyone that wanted them because all things were common to everyone.  So anyone could have taken them.

  Q.   Total value of the tools, do you know
  approximately what they were worth?
       A.   No.
        Q.   Did you give him anything else, other
  than what you have already told me, when he left?
       A.   No.
       Q.   What were the circumstances of the
  Butlers leaving the community?
       A.   Because I committed that sin, and when I
  committed that sin I made the confession.  And he
  was like some of the others, they thought it was
  just terrible that I committed this sin, and it
  was.  To commit that sin is a terrible sin, but
  it's not any more terrible than anybody else's
  sin.
            But I did commit it, and I got up before
  the congregation and I confessed it.  And I have
  been willing to walk circumspectly and more
  carefully since that time.  And I have not
  committed it since then.  Thank God for that.  I
  want to stand before God one day and -- I will be
  standing before a judge one day, and that is my
  concern.
       Q.   Now, so this was --
       A.   You know, Tim Butler was not even in the
  open meeting.  He was not even there when I
  confessed it.  So you know what happened?  When
  Tim Butler came home I called the board together,
   and I called Tim Butler in and personally sat
  there and told him what I had done.
       Q.   What did you tell him?
       A.   I told him I committed adultery, just
  like I told you.
       Q.   What was his reaction?
       A.   Well, he didn't like it.
       Q.   What did he say?
       A.   Well, he tried to throw me out of the
  ministry.  He tried to make me quit the ministry.
  He wanted to take over the radio work.

What….I never did any such thing! Matter of fact I didn’t say anything at that time.  It wasn’t until the next week when the men of the community were gathered outside of the radio room having an argument with Mr. Stair that Mr. Stair attacked Tim.  Causing Tim to say that we were leaving.  It was after that moment that other men started tell Mr. Stair that they were leaving also.  I heard this from our trailer because the men were loud and we lived close to the radio room.

       Q.   What did you think of his reaction?
       A.   I just told him you are wrong.  If you
  don't like it, that's fine.  I don't think it was
  right for him -- man, when you are judging a man
  for sin, you have to consider your own sin.  If
  he's without sin, let him cast his stone.
       Q.   So what was your reaction to his
  reaction?
       A.   None whatsoever.  When he decided he
  wanted to leave, just leave.  What can I do?
       Q.   But when he said that you should leave
  the ministry --
       A.   It wasn't his place to say that.  We had
  other men there.  We have men who have been with
   me 30, 40 years that are still there.  Christopher
  was there.  There was other men there.  And they
  accepted my repentance.  They accepted my
  willingness to submit to their judgment, Yulatool
  (phonetic).
       Q.   And when Mr. Butler told you that he
  would rather leave the community then --
       A.   Leave.
       Q.   -- did you say anything else to him at
  that time?
       A.   I just told him to leave.
       Q.   What conversations did you-all have
  concerning what he could take with him in terms
  of --
       A.   None whatsoever.
       Q.   Well, you said he left with food and
  tools?
       A.   Yes.  He done that without me even
  knowing it.  I didn't even know it.  I just told
  him -- I gave him his money.  He went and bought a
  car.  The next thing I know he was taking the
  tools out of the garage.  He backed up to the
  warehouse and took food, and I didn't even notice
  that he had done that.  He never discussed that
  with me.  He just done it.
        Q.   You said you gave him the money.  Did
  you have any conversation with him about the
  money?
       A.   No.  Just gave him the 30,000 and that's
  it.
       Q.   So he told you he was leaving the
  community, and then later you just walked up and
  handed him a check for $30,000?
       A.   Yeah.  Every person that left, I gave
  them some money to leave so that they could go
  back out and live.  They had –

Tim was handed 2 checks by Tim Cheek and Christopher Landry. Mr. Stair did not talk to us after Tim told him that we were leaving.  As a matter of fact only ones that talked to us were the ones that were leaving also. One check was for $7,000 along with $3,000 cash so we could go get a car since there was none in the community for us to have. We received that money on Friday, the day we left. The second check was for $20,000.  We received it when we went back on Monday to get the truck that was loaded with our things and moved it into a storage unit in Orangeburg.  Because we still didn’t have a place to live.  Mr. Stair did sent two men to help us unload the truck and take it back to the community.
       Q.   I understand that.  But what I'm trying
  to understand is was it a matter of you simply
  walked up to him, he didn't say a word, you didn't
  say a word, you just handed him a check and --
       A.   What are you trying to get out of me,
  sir, a specific conversation?  I don't know what
  we said.  Here is your money, you leave.
       Q.   Was there a conversation?
       A.   No, not particularly, except for one
  time he didn't want to leave, and I asked him when
  he was going to leave, or what was preventing him
  from leaving, and he said, what are you going to
  do, call the law on me?  I said, no, I'm not going
  to do that.  But I said, why hang around?  Just if
   you are going to leave, go ahead and leave and
  stop --
       Q.   What my question is, when you gave him
  the $30,000 check --
       A.   There was no conversation.
       Q.   None at all?
            MR. CHAPLIN:  I'm going to object to
  asked and answered.
            MR. UTSEY:  Okay, that's fine, but that
  is not a proper objection.
            MR. CHAPLIN:  Why not?
       Q.   Was there any statement made by Mr.
  Butler at that time or any statement made by you,
  or you both just sort of stood there and said
  nothing and you handed him a check?
            MR. CHAPLIN:  Again, asked and answered.
       A.   I don't know what you are asking.
       Q.   Did you make a statement to Mr. Butler
  about the $30,000 check at any point in time?
       A.   No.
       Q.   Did Mr. Butler ever --
       A.   Not that I know of, no.
       Q.   Did Mr. Butler ever make any statement
  to you about the check?
       A.   No.
        Q.   Did Mr. Butler make any statement to you
  at any point in time about how much money he would
  like to have when he left?
       A.   No.  He just said I put thirty -- sixty
  thousand in this ministry.  That's what he said,
  because he thinks he does, but he really didn't.
  He put it in, but he doesn't count what he got
  back for putting it in.
       Q.   When did this conversation take place?
       A.   I have no idea.
       Q.   What else happened in that conversation?
       A.   Nothing.
       Q.   So he simply said that and you didn't
  respond?
       A.   No.
       Q.   What else did he say?
       A.   I don't know.  I don't know what else.
  The decision was made to leave and he left.
       Q.   And other than him saying he put $60,000
  into the ministry --
       A.   He didn't even say that to me.  He
  probably -- he said that to somebody else.
       Q.   Well, who did he say that to?
       A.   I don't know.
       Q.   How did you learn of it?
        A.   People tell me.  It comes through the
  grapevine.
       Q.   Who did he tell --
       A.   I don't know.
       Q.   So you never had that conversation with
  him?
       A.   No.
       Q.   Now, at that time did Mr. Butler still
  own his truck?
       A.   Yes.  He always owned his truck.
       Q.   And he took the truck with him as well?
       A.   Yes.
       Q.   And he purchased a new car, you said?
       A.   After I gave him the money, and he got
  ready to leave, the next I know he drove in with a
  car.

I had to buy a $2000.00 car because the car I brought had been ruined and junked. There was so many people leaving there weren’t any other vehicles to take.

       Q.   Do you know where he got that from?
       A.   No.
       Q.   Why was Exhibit 3 prepared?  Was it for
  this lawsuit?
       A.   I'm not sure.
       Q.   Have you ever seen a document like this
  other than those --
       A.   I think when these people started to go,
  we went back ourself and started to check exactly
   what they did give and what they didn't give.  And
  that might have even been one of the reasons why I
  made a judgment how much to give them back.  That
  is the only thing I can tell you about that.
       Q.   So did you have Exhibit 3 prepared
  before you gave $30,000 to Mr. Butler?
       A.   I don't remember that.
       Q.   Well, you said it may have been a basis
  for your judgment.  That is what I'm trying to
  figure out.  How would we be able to determine if
  it was?
       A.   It wasn't.
       Q.   It was not?
       A.   No.  That would have no bearing on what
  I gave.  I am a man of God, sir, and if God tells
  me to do something, I do it.  And if God said to
  me you give him so much money back, even if he
  didn't deserve it, I would have done it.
            It's just like I said, we would have
  paid that man's debt if he never gave a dime into
  the place, just like we've done with others, like
  I would do with you or anybody else.  If God would
  say to me you help that man, I would help you, and
  that is a judgment I make.
       Q.   I am just trying to understand a comment
   you made, so I'm not trying to argue with you.  So
  that we are clear, the $30,000 was not a product
  of any of the information that --
       A.   The $30,000 to Mr. Butler had nothing to
  do with him personally or anybody else.  Every
  person that came to me, I would make a judgment on
  what kind of money I was able to give back to
  them.
            Remember, I am handling God's money.  I
  am handling church money.  So I have to be able to
  justify to give it in the spiritual moral sense of
  the thing.  And, as a church, I am allowed to
  benefit people, allowed to help people.
            I was just telling somebody out there --
  we were talking about a church in Memphis that
  went and bought a house and gave it to somebody
  from the Katrina situation.  They just gave them
  the house.  They took the church money and they
  bought a house and gave it to the people.
            See, so that's what -- when these people
  got ready to leave us, even though they were
  opposing me, I did not send any of them away
  empty.  I did not give them all their money back
  because their money was offerings, but I didn't
  want them to go back out with nothing.
        Q.   Well, did the amounts that you gave
  these people --
       A.   The amount had to do with him because of
  the amount he had turned in, yes.  It had to do
  with that.
       Q.   Was it just generally in reference to
  the amount that they had offered, or was it an
  equation, you gave them a certain percentage
  back?  Or tell me how it had something to do with
  what they offered.
       A.   It had nothing to do with what they
  offered.  I felt certain -- like Larry Hartley or
  anyone, I felt like I give them enough money of
  what they gave.
       Q.   Now, hold on a minute, because you just
  said that it had something to do with what they
  offered.  Did it or did it not?
       A.   It did not.
       Q.   So the amounts were selected without any
  reference to what they offered?
       A.   Right.
       Q.   So if you had felt like giving Mr.
  Butler $100,000 --
       A.   If I felt like giving him nothing, I
  would have gave him nothing.
        Q.   Or $100,000?
       A.   Or $100,000, right.
       Q.   And there would be no criteria that you
  would use to determine that amount?
       A.   None whatsoever.
       Q.   Other than what you felt --
       A.   None whatsoever.
       Q.   -- was appropriate, right?
       A.   Yes.
            MR. CHAPLIN:  Do you need a break?  Are
  you okay?
            THE WITNESS:  Yeah, I'm all right.
       Q.   Did Mr. Butler complain to you about the
  amount?
       A.   No, not to me.  He might have to
  somebody else, but he didn't do it to me.
       Q.   All right.  Let's talk about Mr. Duval.
       A.   Who?
       Q.   Michael Duval.
       A.   Oh, okay.
       Q.   How did you first become acquainted
  with --
       A.   All of these people, every last one of
  them, sir, heard me on the radio.  I'm a radio
  broadcaster.  I cover the nation.  They heard me
   on the radio.
            MR. CHAPLIN:  But he's talking about
  this one specifically, just Duval.
       A.   Radio, conversation, came and moved
  here.  Moved here to South Carolina on their own.
       Q.   Where were they from?
       A.   New York State.
       Q.   When did you first have a telephone
  conversation with Mr. and Mrs. Duval?
       A.   I don't know.
       Q.   Did you talk to them on the telephone?
       A.   Oh, I'm sure.
       Q.   Did they come for a visit?
       A.   They moved here.  They moved here and
  lived in Walterboro for quite awhile.
       Q.   You mean not in the community?
       A.   They moved here without my -- they
  didn't ask me.  They just moved to Walterboro.
  And the next thing I knew they were down here and
  they started attending the services.

Noticed he almost said permission.  Which would have been the truth.

       Q.   Was that the first time you met them in
  person, when they began attending services?
       A.   Yes -- no.  I might have met them one
  time when I went up to that area for a meeting.  I
  think they told me they came to our meeting in
   Syracuse, or something like that.
       Q.   Do you know approximately when it was
  that they moved to the Walterboro area?
       A.   No, I don't.
       Q.   Do you know when it was approximately
  they began attending services here?
       A.   No.
       Q.   Did you ever have any conversations with
  them about moving to the community?
       A.   Sure.
       Q.   When did those begin?
       A.   I don't know.
       Q.   What were the nature of those
  conversations?
       A.   Same thing with everybody else.  You
  want to live here, you come out here and work with
  us, and you find out whether you can live here
  with us under our terms, the way we do things, and
  whether we can live with you.  It's the same with
  anybody anywhere.
       Q.   Just like what you described with the
  Butlers?
       A.   Yes.
             (Plaintiffs' Exhibit No. 4 was marked
  for identification.)
        Q.   Okay.  I am going to hand you now what
  has been marked as Exhibit Number 4 and ask you if
  you recognize that document.
       A.   Uh-huh.
       Q.   You do?
       A.   I recognize some of it.
       Q.   There are several pages there.  It's
  just the way it came to me.
       A.   Yes.
       Q.   What is that document?
       A.   Just the money they gave and the money
  we gave back.
       Q.   Who prepared that?
       A.   Either my wife or Margaret.  This looks
  like Margaret and that looks like maybe --
       Q.   For the record, the handwritten part
  looks like Margaret?
       A.   Uh-huh.
       Q.   That is a yes?
       A.   What Margaret would do is we have a
  bookkeeper.  The bookkeeper keeps a record.
  Margaret has each individual.
       Q.   An individual what?
       A.   She has a list of people who have
  written to us over the years, and she keeps a
   record.  She can tell how much money they send and
  when they send it and what we send back to them.
  And that is probably Margaret right there.
            4-9-96, she would tell you that is how
  much money they gave.
       Q.   For the record, because we have to read
  this later, you are pointing at the second page of
  Exhibit 4, which is a handwritten page that you
  think is the handwritten record that Margaret
  prepared?
       A.   Yes.
       Q.   Would the same be true for the next
  page, the third page, which is handwritten, also?
       A.   Yes.  I would say so.
       Q.   And insofar as the first page, which is
  typed with some handwriting on it --
       A.   That might be Margaret, too, making a
  summary.  I really don't know.
       Q.   Do you know why this first page was
  prepared on June 27, 2001?
       A.   Yeah, because we started to give them
  money back and I wanted to know what we were
  giving them back.  So I asked her to give me a
  record of it, how much did the people give, how
  much did we give them back.
        Q.   And it appears that this was signed by
  Mr. Duval?
       A.   Yes.  I have to have records where I
  gave the money to.  See, it's God's money.  It's
  not their money.  It's church money.  If I give
  you money, sir, I want you to sign a record for
  me, or a check for me or sign a receipt for me.
       Q.   Well, other than Mr. Duval, did you have
  any of these other folks sign something?
       A.   We either got a check or they signed a
  receipt.
       Q.   Because I don't know that I have
  received copies of all of those.  Do you think
  they are there, a check or a receipt for all of
  them?
       A.   Yes.  We can find it.
       Q.   Let's talk now about Exhibit 4.  What is
  this to Henry Chaplin Real Estate for purchase of
  land?
       A.   When he left he wanted to buy some land,
  so we went and bought the land for him.
       Q.   And was that these four checks totaled
  up for that purchase?
       A.   Whatever it says there.
       Q.   Well, there are four checks, and then it
   says --
       A.   We gave him some cash.  We gave him some
  cash.  We gave him some -- we wrote two checks for
  him.  When he started to live here we started to
  give him some cash so he could do some things, and
  then we paid the checks, and that's the total
  amount we gave him at that time.
       Q.   The next line says gave back mobile
  double wide home and moving and setup, $4,500?
       A.   He had a home out there on our lot.
  When we bought the land for him where he wanted --
  he went and picked out the land he wanted.  We
  went and bought the land for him and then we moved
  his trailer for him.  We went down and moved it
  down, set it up so he could go and live in it.
  Gave him the two cars back.

As far as I can remember Mr. Duval had nothing to do with getting the land. They didn’t even want to leave. Mr. Stair forced them to leave.   Basically Mr. Stair wanted them off the land after he got what he could get from them.  Meaning the land where the tabernacle is.  Mr. Stair found the land, moved the double wide trailer that they were living in and told them that was there new home.
  Q.   Had he donated the double wide to the
  community when he first came there?
       A.   When he came it was -- he lived in it
  himself.  That is the one he lived in.  When he
  left we --
       Q.   You gave it back to him?
       A.   Yes.
       Q.   And there is another check of $14,300
  for purchase of land and tax on trailer.  That is
   the same land we were just talking about?
       A.   The land we were talking about, yes.
       Q.   And then a check for $5,000?
       A.   We gave him cash so he would have some
  money.
       Q.   And then transfer from PrimeVest
  Financial Service to Hartford Life?
       A.   We had some investments at that time,
  and we just took some of the money and transferred
  it over to him to give him some of his money back.
       Q.   You transferred it to an account that he
  had?
       A.   The account was an annuity account, and
  we transferred the annuity into his name.
       Q.   So did you have -- or did the ministry
  have investments through PrimeVest Financial
  Service at one point?
       A.   At that time we had annuities.  At that
  time we had several annuities.  We don't have any
  more annuities nowhere.
       Q.   The total of this is $71,320, and then
  someone has written a note, $100 cash.  Is that in
  addition to that typed amount?
       A.   Yes.
       Q.   Now, turning to the second page, what is
   this information?
       A.   These probably represents all the offers
  that come in.
       Q.   Both before and after he moved to the
  community?
       A.   Yes.  Down here is -- when he came to
  the community we bought him -- he bought 74 some
  acres, he bought it with his money, and that is
  what the value of it was right there.
       Q.   I'm sorry.  I'm confused.  This 34.8 --
       A.   When he came out there to us he did not
  move on the community.  He moved next door and he
  bought that piece of land.  He bought it.  Because
  at that particular time he was trying to find a
  way to reduce his property tax, or his property
  investment tax.

Mr. Stair told us that he told Duval to buy the land next door. The land was in Mr. Duval’s name for some time before Mr. Stair made him sign it over to the ministry and shortly thereafter kicked them out.  Mr. Stair forced Mr. Duval to sign over the land to the ministry.  It seemed like Mr. Stair was holding something over Mr. Duval head.

            And so he bought the land so he didn't
  have to pay capital gains tax.  When you move from
  one place to another -- that man, when he moved
  here, had to even pay South Carolina tax on his
  income even though he didn't earn none of it
  here.  And at that particular stage he went and
  bought that land right next to us, and that is
  where he moved on it.
       Q.   And did he donate that to the --
        A.   Then later on he donated the land to the
  church.
       Q.   Somebody here has value, $75,000,
  question mark.  Does --
       A.   Because we are not quite sure what the
  land plus the buildings and everything is all
  worth.
       Q.   Do you know what he paid for it?
       A.   I would have to go back and look at it.
  I think the land was something like forty some
  thousand.  I really don't know.
       Q.   What kind of improvements were on it?
       A.   We put his trailer on it.  We put our
  tabernacle on it.  We put a barn on it.  We
  cleaned up the fields.  We have houses on it now.
  Now it's part of the community.
            It must have one -- it has a barn on it,
  a tabernacle on it.  It has three or four houses
  on it.
       Q.   Do you know what the property taxes were
  on that piece of property, or what the appraised
  value for tax purposes was?
       A.   I don't know what it was then because --
  since we transferred it over there is no property
  tax on it.
        Q.   So by your calculations, if you figure
  that property was worth approximately $75,000,
  then his approximate offerings were $149,961?
       A.   Somewhere along in there, yes.
       Q.   So I'm reading that correctly?
       A.   Yes.
       Q.   Now, I'm looking at the third page of
  Exhibit 4 here, and I'm confused by this because
  it looks to me like it's a different number, and I
  don't understand why they are different.
       A.   Because part of it was the -- this is
  the money we gave back in total cash all together.
  This would be the amount we gave back totally.
       Q.   But I am trying to figure out the
  donation or offering portion of it.  This says
  total cash offerings, $13,740, but on the previous
  page it says total cash offerings of $74,961.  Do
  you know which one is accurate?
       A.   I think they are both accurate when you
  look at the source of them.
       Q.   How can they both be accurate?  Is it a
  sum of those two that --
       A.   Because I told you part of it -- we
  weren't looking for any kind of legal thing here.
  We were looking for our own understanding of what
   the Duvals had given and what they had not given.
  So we weren't trying to get this -- what you are
  trying to find.
            Sister Margaret would go into her
  bookkeeping, and she pulls the Duval file, and she
  could tell us how much they gave in a year.  In
  the bookkeeping it would be put in a different
  situation.  And the Duvals gave approximately one
  hundred and forty some thousand, including the
  land.  That is what they gave.
       Q.   So that would be consistent with Page 2
  of Exhibit 4 here?
       A.   The overall total that the Duvals gave
  was right around one hundred and forty some
  thousand.
       Q.   Okay.
       A.   And when they left, we gave them seventy
  some thousand dollars cash back.  We moved the
  trailer for them, we set him up, gave him some
  cash to live, gave him his two cars back.  He had
  two cars that we gave him back.
            MR. CHAPLIN:  Can I see if I understand
  that a little better?
            MR. UTSEY:  No.  Hang on.  I'm not
  finished.
        Q.   On the second page the offerings, the
  cash offerings, were sort of in two groups.  There
  is offerings mail and offerings local, and then
  bought lumber I guess would be the third category.
  Bought lumber would be lumber that Mr. Duval
  purchased for the church?
       A.   This is probably before he ever came
  here.  This came in the mail.
       Q.   Right.  That's '93 through '96?
       A.   This is when they finally came and they
  started to give offerings.
       Q.   And so these would be cash offerings,
  these first four.  That would be April 9 of '96
  through September 3 of '97?
       A.   Right.
       Q.   The next two which say bought lumber
  in '98 and '99, that would be expenditures he
  made?
       A.   Yes, when he bought -- probably spent
  the money to work and we counted it as a donation.
       Q.   Where did he get the money from to do
  that?
       A.   He had it.  He still had money.
       Q.   Oh, okay.  I guess I was confused.  I
  understood everybody gave up their money to come
   join the community?
       A.   I just got finished explaining to you
  that when Mr. Duval came, when he came out there I
  did not take his money.  He bought a piece of land
  next door, first, so he did not give all of his
  money then.
            He came out and bought his own land.  He
  owned the land.  He put his house on it.  He
  bought the house trailer.  He built a barn on it
  with his own money.
            MR. CHAPLIN:  I think we got the point.
            MR. UTSEY:  Hang on a minute.  I just
  want to -- I don't need you interrupting.
       Q.   So at what point did he give up
  everything to join the community?
       A.   He lived right there on his own land
  next to us for several years, and it still was his
  own land.  And then one day since I said, now, you
  want to be a part of this community?  We want to
  build this tabernacle and stuff like that, then
  you need to donate the land.
            Now, he didn't have to.  He could have
  done like everybody else.  We would have just
  separated ourselves from him and he could have
  lived over there and done what he wanted to.
        Q.   This has a date of December 31, '98 next
  to transfer of property.  Do you think that is
  when it was that he made that --
       A.   If that's what it says, that's what it
  says.
       Q.   But the transfer of property would have
  coincided with that decision?  That is what I'm
  trying to determine.
       A.   I'm sure of that.
       Q.   How did you come up with the $71,320?
       A.   The same way I did with Mr. Butler.
       Q.   How is that?
       A.   I just made a judgment.
       Q.   Did you ever have any conversations with
  Mr. Duval about how much money you were going to
  return to him?
       A.   Yeah, I told him.
       Q.   And did he ask for a certain amount?
       A.   No.
       Q.   Did you tell him how you came up with
  the amount?
       A.   No.
       Q.   It looks like it was sort of an ongoing
  process with him because checks appear to have
  been written and the transfer of funds seem to
   have occurred over about a month and a half?
       A.   When it became a decision that he was
  going to leave, I started to help him find a way
  to do it.
            First of all, he had to find a piece of
  land.  Second, he had to find a way to pay for it.
  He had no money now.  At this point in time he's
  already part of the community, so everything he
  has is now part of the community.
            So if you are going to leave, he has to
  have a way to do it.  So I started to give him
  some cash.  And then when he picked out the piece
  of land he wanted -- he didn't have any money, so
  we paid for the land.
            And then when he got ready to leave I
  gave him some more cash and I gave him the
  $40,000, the annuity situation.  And the reason I
  did the annuity situation is because the annuity
  would have given him a $500 to $600 a month
  income, which he didn't have no income.
            So I said, Mr. Duval, now, you can do
  what you want to do with it.  He could leave it
  there or he could cash it in.  I don't know what
  he done with it.  But the annuity was set up that
  he would have gotten $500 a month or more, between
   five and six hundred a month off of the annuity.
            Because he's out there now with no job,
  he has to live, so I was trying to help him have
  an income.  Kind of cool of me, wasn't it?
       Q.   What did you understand the reason why
  Mr. Duval left the community?
       A.   Because they didn't want to live with us
  anymore.  They were very -- they didn't want to
  live with the community anymore.  They didn't want
  to be a part of it.
       Q.   Do you know why?
       A.   For several reasons.  The daughters
  would get upset.  Him and his wife would fight,
  like most men do.  And they would have a squabble
  and she was going to leave and he was going to
  leave.  His children didn't want to be there.
            When that finally came to that decision,
  I had gone through that hassle with them at least
  six times.
       Q.   Were there any other reasons that the
  Duvals ever expressed to you why they were leaving
  the community?
       A.   Not that I know of.  And they left long
  before this other situation ever developed.
       Q.   To your knowledge, did they have any
   dissatisfaction with the way that the ministry had
  been operated?
       A.   Not that I know of.  In fact, they were
  begging me to let them stay.
       Q.   You told them they had to leave?
       A.   Yeah.  I said -- when they came again to
  start talking about wanting to leave, I said,
  well, this time you are going to do it.  This time
  we are not going to back away from it.
       Q.   Did you give them a choice?
       A.   No, I didn't give them a choice.  They
  were not part of the community anymore.  Boy, this
  is something, God, I'll tell you.  It's amazing.
  Amazing world, Lord.  Thank you, Jesus.
       Q.   When the Duvals chose to donate
  everything to the community, did you have any
  conversations with them about what their donations
  would be used for?
       A.   No.
       Q.   Did anybody explain that to them?
       A.   No.
       Q.   Had they participated in any meetings or
  other conversations --
       A.   No.
       Q.   -- in which any expenditures were
   discussed?
       A.   No. I have got several hundred people
  who send money here every week, every day.  I do
  not discuss with them how I spend the money.  They
  send the money because they believe I'm a
  trustworthy man, and then my records prove that I
  am.
            I spent the money where it goes.  I stay
  on the radio.  It costs us a great deal of money
  to do that.  And my records prove that is where it
  goes.  I don't have no fancy car.  I don't live in
  a big house.  I don't have fancy clothes, and I
  don't take expensive vacations.
            I live a very simple life right amongst
  the people.  I live right there with them.  And
  the people that know me all over the country, they
  know that.  They know that.
       Q.   I really don't want to talk about all
  the people around the country, but just the
  Duvals.  What would you say --
       A.   I don't owe the Duvals any more than
  anybody else.  They give an offering and that was
  it.
            MR. CHAPLIN:  Let him ask his question.
       Q.   What would you say was the source of the
   Duvals' information about how the money they
  donated would be spent?
       A.   There was no any more source than
  anybody else.  You are giving a donation because
  you want to give it.  That is the way you give.
       Q.   I mean, on your radio program or on your
  website is it explained --
       A.   No, no.  We don't explain what we do.
  It's understood by the way I operate that the
  money that people give is used basically primarily
  to take care of the radio ministry and to take
  care of the ministry of this church, the local
  ministry, feed the hungry, clothe the naked, take
  care of little things, have church services,
  worship God.  That is what we do as a church.  We
  do just like churches.  We have services.  Every
  day we have services, and we do it all the time.
       Q.   Was there ever a time that you explained
  to the Duvals the entries or any of the entries
  that are reflected by Exhibit Number 1?
       A.   No, no, no.
       Q.   Why not?
       A.   No need to.
       Q.   Did they ever have questions about any
  of these expenditures?
        A.   No.
       Q.   Would they have been privy to this
  information?
       A.   Sure.  If they -- we put that record out
  and put it on our bulletin board every year.

He never has done that. Noone knows anything about the finances except Stair and Theresa.

       Q.   Exactly like Exhibit 1?
       A.   Yeah.  We will give them a record.
  Anybody that wants a record, we let them look at
  the records.
       Q.   Let me make sure I'm clear on that then.
  Is it your testimony that you take an exact copy
  of each of these pages at the end of each year and
  put it on the bulletin board?
       A.   We tell the people about them, yes.  And
  sometimes we put them up and sometimes we don't.
       Q.   How often do you put them on the
  bulletin board?
       A.   Whenever we decide to do it.
       Q.   How often is that?
       A.   Whenever we decide.
       Q.   Well, how many times have you done it,
  say, in the last two or three years?
       A.   Two or three times.
       Q.   And when you put up a copy of a page
  like the top page on Exhibit 1 here, do you have
   any explanatory information with it?
       A.   No.  I tried to explain to you -- of
  course I probably can't, but I will try anyway.
  We have open services.  All the business is spoken
  out openly all the time, daily, daily.
            I just got a $20,000 check today, sir.
  I have to pay $30,000 over here for this radio
  broadcast.  It's spoken openly in front of
  everybody.
       Q.   Does that include all of the
  expenditures reflected by Exhibit 1?
       A.   Yeah.  I just paid so-and-so's child
  support today, or we just helped Brother so-and-so
  with that, or we just took care of Brother
  so-and-so's situation over here.
            Yes.  We talk openly.  We have an open
  family.  That fellow just had a fight with his
  wife, let's pray for him.  That is what we do
  there.  We just do it openly.
       Q.   Do you explain those expenditures to
  people who do not live at the community?
       A.   I don't have to explain, no.  For what
  reason?
       Q.   I am just asking, do you?
       A.   No, I do not.
        Q.   So you would have to be living at the
  community to hear that?
       A.   They hear me on the radio.  I tell them
  what we do.  I get on the radio and I do the same
  thing.
       Q.   That is what I want to ask.  Do you go
  on the radio and explain to the people who are
  listening all the same expenditures that you --
       A.   No, no.
       Q.   I mean, you don't say we just paid
  so-and-so's child support?
       A.   Oh, I have done that.  I have told them
  we pay some people's child support, yes.
       Q.   But you don't go into as much detail as
  you just described?
       A.   No.
       Q.   Why not?
       A.   What for?
       Q.   I am not asking you what for.  I just
  asked why --
       A.   Because there is no need for it.
       Q.   All right.
            MR. CHAPLIN:  Before you get to the next
  person I would like to take a five-minute break.
            MR. UTSEY:  Okay.  We can do that.  I'm
   ready to start with the next one, so we can do it
  now.
             (A recess was taken.)
       Q.   Let's talk about Larry Hartley.  When
  did you first become acquainted with Mr. Hartley?
       A.   I will try to answer that question for
  all of them.  I really can't say any of those
  dates.  I just don't have any idea.
       Q.   The circumstances of your first meeting
  Mr. Hartley, do you recall those?
       A.   No.
       Q.   Did Mr. Hartley come to live at the
  farm, the community?
       A.   Eventually.
       Q.   Do you remember any of the circumstances
  that predated that as far as his relationship with
  the ministry?
       A.   Just supported the ministry.
       Q.   Financially, you mean?
       A.   Yes.
       Q.   Did you have any conversations with Mr.
  Hartley about his joining the community before he
  actually came to live at the community?
       A.   Only when he decided -- let us know he
  wanted to do it.
        Q.   Did he make a visit like we discussed
  earlier with some people?
       A.   Everyone that comes makes a visit, yes.
       Q.   And do you recall how long it was before
  his actual decision to move to the community that
  Mr. Hartley made that visit?
       A.   He had to make two or three visits
  before he decided, and he would go back home, and
  if he wanted -- after two or three visits, if they
  want to pursue it, then by that time they know the
  situation and what the conditions are.
       Q.   Do you recall the length of any of the
  visits that Mr. Hartley made?
       A.   No.
       Q.   During those visits did you talk with
  Mr. Hartley about, what you called earlier, the
  rules?
       A.   I am sure I discussed with him that if
  he came to live with us you understand that
  everybody gives everything here and that's the way
  it is, and from that point on we are responsible
  for whatever you need, whatever you want.
       Q.   Before he actually moved to the
  community, did you have any conversations with Mr.
  Hartley concerning the expenditures of the
   community?
       A.   No.
       Q.   Did you discuss with him where his
  donations would be spent?
       A.   No.
       Q.   Did you generally talk about where the
  ministry spent its money and for what purpose?
       A.   No.
       Q.   Do you know any source of his
  understanding of where the money would go if he
  donated it?
       A.   No.
       Q.   Do you know why he would have donated
  money if he had no idea where it was going to go?
       A.   I guess he just believed what I was
  doing was right.
       Q.   And what you were doing was?
       A.   Preaching the word of God.
       Q.   Well, was it at least implicit that the
  money donated would go to assist you in preaching
  the word of God?
       A.   The appeal that goes out from this
  ministry is to support the ministry, if you
  desire, to help us preach the message of Jesus
  Christ to the world.  That is the appeal, and
   that's what people send their money to do and that
  is what we do with it.
       Q.   And is that what -- why do you tell
  people that?
       A.   Because that's the way it is.
       Q.   I mean, it takes money to --
       A.   They can give it or not give it.
       Q.   But, I mean, you have to have the money
  to buy the air time?
       A.   Right.
       Q.   And so --
       A.   I also believe in giving offerings to
  the work of God, sure.  I believe in giving
  offerings.  Whether I'm on the radio or not, we
  are a church.  We are a legitimate church.  We
  worship God.  We preach.  Have an education
  system.  This is our Christian life-style.  So
  whether we are on the radio or not, people give
  offerings to this ministry.
       Q.   Well, do you expect people to hear what
  you are saying about what your ministry is about
  and what the offerings are for?
       A.   I am sure they do hear.  There is no
  reason why they shouldn't.
       Q.   Well, do you expect people to act in
   response to that?
       A.   Sure.  Some do and some don't.  Some get
  mad.  Some call me a crook.  Some call me a cult
  leader, and some call me a good man and some call
  you a bad man.
       Q.   Is one of the reasons that you are out
  there telling people about the need to send
  contributions because you are hoping that they --
       A.   Because I believe it's God's will for
  people to give to the cause of Christ or give to a
  ministry.
            MR. CHAPLIN:  I am going to make an
  asked and answered objection.
       Q.   Do you expect people to rely on the
  statements that you make?
            MR. CHAPLIN:  Asked and answered.
            MR. UTSEY:  I didn't ask him that.
       A.   I think every person has a right to make
  a judgment, and I will tell you to make a
  judgment.  If you don't believe I'm doing what is
  right, then don't support me.  If you don't
  believe I'm an honest man, then don't give me any
  money.
       Q.   Well, that really wasn't my question.
  My question is when you make statements on the air
   about what you plan to do with money that you
  raise, do you expect people to rely on those
  statements?
       A.   Absolutely.
       Q.   And do you expect them to accept those
  statements as being accurate, as being true?
       A.   Absolutely.
       Q.   Is it reasonable for them to rely on
  those statements?
       A.   Why not?  Sure.
             (Plaintiffs' Exhibit No. 5 was marked
  for identification.)
       Q.   Now, with respect to Mr. Hartley, let's
  look at Exhibit Number 5.  Is this another -- the
  first page of this, is this another summary that
  appears to have been prepared by Margaret Moratto?
       A.   Yes.
       Q.   And the second page is a combination of
  a receipt that Mr. Hartley signed and a check that
  you issued to him?
       A.   We had him sign for cash.  He needed
  some cash.  And he also took his camper with him,
  a nice camper that was probably worth three or
  four thousand that he gave.  We gave that back to
  him because we get no receipt for that.
        Q.   Let's work backwards.  It looks like we
  are accounting for a total of a $71,000 return.
  That would be $1,000 cash reflected by this
  receipt and a $70,000 check?
       A.   Yes.
       Q.   The check is written on a PrimeVest
  account.  Which bank was that with?
       A.   That was with -- I told you we had
  annuities.  You could write checks on it.  The
  same annuity we paid Mr. -- what's his name?
       Q.   Was that PrimeVest?
       A.   Yes.
       Q.   Is that account now closed?
       A.   Yes.
       Q.   I notice that the check -- the account,
  rather, has both your name and Faith Cathedral
  Fellowship, Inc., on it?
       A.   Any time a corporation makes you a
  checking account or an investment, they have to
  have somebody who signs for that incorporation,
  and I am that man.  I am the man that has been
  authorized to sign and make business transactions
  and pay bills.  I am the man.  I sign contracts,
  checks, agreements.
       Q.   I understand you were on the signature
   cards, but apparently your name was also on the
  account as well?
       A.   You have to have it on the account.
  That is what they require you to do.
       Q.   Do you recall what kind of account it
  was, whether it was a --
       A.   It was an annuity.
       Q.   No.  Was it a joint account?
       A.   No, straight church account.
       Q.   When did you close the account with
  PrimeVest?
       A.   I have no idea.  It's been for several
  years.
       Q.   Well, this check was written in August
  of 2001, so it was still open --
       A.   It wasn't long after that.
       Q.   Why did you close the account with
  PrimeVest?
       A.   Because I started to invest the monies
  where I could keep better control, where I knew
  where it was at, and that is why I put it in the
  bank where I just told you this morning.
            I have two accounts where the money is
  there in Walterboro and Tidelands.  That is where
  we have the money.  They are both accounts that I
   can use the money.  Those accounts are a little
  more difficult to get money out of if you have to
  use it.
       Q.   I see.  Liquidity issues then?
       A.   What?
       Q.   Was it a matter of liquidity of the
  funds?
       A.   Yes.  I don't take any money if things
  are tied up for 15 years, because I believe that
  Jesus is coming.
            And I'm using the money, and I don't
  believe the people that are giving me the money
  because they are storing and making an
  investment.  I believe they are giving me the
  money to spend it, so I have it so I can spend it.
       Q.   Sure.  Now, do you remember when it was
  that Mr. Hartley moved into the community,
  approximately?
       A.   No.  I could get the date, but I don't
  remember, no.
       Q.   The summary of the contributions that he
  made here, or offerings that he made here run from
  1996 through 2001?
       A.   Yes.  Long before he came he supported
  this ministry.  At least two or three years before
   he came he gave great sums of money, but not any
  more than anybody else.
       Q.   For instance, there is a $76,500
  offering he made in 1997?
       A.   He sent that money in the mail.
       Q.   That's what I was going to ask you.
  Weren't all of these cash offerings in his case?
       A.   Yes.
       Q.   And how is it that you came up with the
  amount to return to him?
       A.   I told you, I make a judgment.
       Q.   Same way as you did with the others?
       A.   Right.
       Q.   Did that have any relationship to the
  amount he had offered?
       A.   No.  I felt like the man should get
  quite a bit back because he gave a lot, yes.
       Q.   Now, did you have any conversation with
  Mr. Hartley about the amount that you were going
  to return to him?
       A.   I told him what I was going to give him
  and he said fine.
       Q.   Did he ask for a certain amount?
       A.   No.
       Q.   What were the circumstances of Mr.
   Hartley leaving the community?
       A.   I told you they all left -- when that
  situation with the women came in, that is when
  they all left.
       Q.   Now, wait a minute.  You told me Mr.
  Duval --
       A.   Duval had already left before that.  But
  this was the same situation.  He left along with
  Butler and others.
       Q.   After your confession?
       A.   Yes.
       Q.   And did Mr. Hartley express to you --
       A.   Sure did.
       Q.   What did he tell you?
       A.   He told me I was a low-down dog, a
  scoundrel, a rascal, whatever name you can think
  about.  And at that point in time I felt like it.
       Q.   And did he tell you that was the reason
  he was leaving the community?
       A.   Yes.
       Q.   At any point before his departure did
  you explain to him all of the items, the
  expenditures that were reflected --
       A.   I never explained that to anybody except
  like I told you.  Openly I tell people what we do.
   I do not go to any person and give an account of
  everything I do with the money.
       Q.   And when you do that openly at these
  group settings where you explain, do you go
  through all of the expenditures you make?  You
  don't sit down and say, okay, we bought a bag of
  feed and --
       A.   No.  But I would tell them we just paid
  off what's his name's bail over there, or we just
  paid -- they know.  Or we just bought this
  tractor.  We just bought this.  I am a very open
  man.
       Q.   But, I mean, it would take you all day
  if you explained everything that you spent,
  wouldn't it?
       A.   But most of the people that live with us
  know we do this.  They understand it.  They
  understand it.  They got a bill -- the other day a
  woman went down and got some new eyeglasses.  She
  has no money.  We paid for the eyeglasses.
            The next person over there said, well, I
  need some teeth.  So we paid for his teeth.  It's
  an understandable thing that someone needs
  something, a pair of shoes or whatever.  Whatever,
  we get it for them.
        Q.   Let's talk about Greg Lindsey now.  Was
  he someone who donated to the ministry before he
  moved there?
       A.   No.  Greg started to give very small
  offerings, and then one day he showed up here.  He
  just showed up here, came to one of our
  gatherings, and then he just stayed.  He's another
  one that I wished I never would have done it like
  that, because I shouldn't have let him stay, but
  he just stayed.
       Q.   So he didn't do the visit, go away and
  come back?
       A.   No.  It was a mistake I made.  I liked
  Greg.
       Q.   Had you ever talked to him before him
  showing up that day?
       A.   Only on the letters that he would write
  me.
       Q.   So you-all did correspond?
       A.   Sure.  I get letters from people all
  over the world.  They correspond with me and I
  write them back.
       Q.   You did?
       A.   I write everybody back.  I answer every
  day.  Write me one.  I promise you I will write
   you back.
       Q.   Did you keep copies of the letters that
  you wrote to him?
       A.   No.  We probably had them.  But, I mean,
  we don't have all of them.
       Q.   Do you think you may still have some of
  the letters you wrote to Mr. Lindsey?
       A.   No.  If I did, I'm not going to go look
  for them, I can tell you that.
       Q.   If you don't have them, what happened to
  them?
       A.   Sir, if you get six, seven hundred
  letters a month, after awhile you get a big ol'
  box of them.  You keep them for awhile and then
  you burn them or you throw them away.
            MR. CHAPLIN:  Hold on one second,
  please.  Just one minute.
             (A recess was taken.)

Q.   We were talking before we took the break
  about Mr. Lindsey just showing up one day and then
  stayed.
            Did you have any conversation with him
  about his showing up there and deciding to stay?
  How did that all go down?
       A.   Well, yes.  I mentioned to him that I
   don't usually let people stay like that, but he
  seemed like a -- I told you, I liked him.
            And he was a -- I found out that he was
  a very knowledgeable young man on computers.  He
  built computers for me.  He took over the computer
  work.  He loved to do it.  So that is how he
  stayed.  As far as contributions, he didn't give
  very much.
       Q.   When he came and you had this
  conversation about him staying, did you talk to
  him about the rules and giving up everything, et
  cetera?
       A.   Sure.  He knew the rules.
       Q.   How did he know the rules?
       A.   Everybody that comes there knows the
  rules.  They are told.  We all turn everything in.
  We all live in common.  Nobody has any debt.  This
  is what we believe.  This is what -- every single
  person knows that.
       Q.   Now, did you talk to him about -- well,
  did he make any donations?  That is, did he like
  own anything that he donated to the community when
  he first moved there?
       A.   Not much that I can think of, no.
       Q.   Did you talk to him about what donations
   he might continue to make and where they would go
  as far as --
       A.   No.
       Q.   How long did he live there?
       A.   Three or four years.
       Q.   And what were the circumstances of his
  leaving?
       A.   Same ones.
       Q.   About the confession you made?
       A.   Right.
       Q.   Did he talk to you personally about
  that?
       A.   No, just got mad and said I'm leaving.
       Q.   And how did you learn about that being
  the reason for his departure?
       A.   He told me.
       Q.   Oh, okay.  So you did talk to him?
       A.   He came to me and -- no.  I didn't talk
  to him.  He talked to me.  He said, I'm leaving.
  I said, fine.
       Q.   What else did he say?
       A.   He just said I'm leaving.  So I gave him
  $500, and rented a U-Haul truck for him, and he
  backed it up to the computer room and filled it
  full of the equipment that we had bought and took
   off.  And that is the last I heard of him, until I
  found out he was -- he called me a dog and a crook
  and a cheat and a liar like everybody else.
       Q.   How did you come up with the $500
  amount?
       A.   Because he didn't give hardly anything
  when he came, and he didn't have any big
  responsibility.  I was just trying to get him to
  get out so he could get back to doing what he was
  doing.
             (Plaintiffs' Exhibit No. 6 was marked
  for identification.)
       Q.   Let me hand you now Exhibit Number 6.
  This is the first page of another summary that Ms.
  Moratto had prepared concerning Mr. Lindsey?
       A.   All right.  These are all offerings he
  sent before he came.
       Q.   What is the second page of Exhibit 6?
       A.   Mail, local, total offerings.  I think
  when he finally got here he went to school a
  little bit, and I think when he went to school he
  got paid for going on the G.I. Bill or something,
  and that is probably some of the money he gave.
            Every person that comes here, if they
  make any money off the ground or anything, they
   donate it and all the funds come in.  That is the
  rules.  I don't care if he makes $10,000 or $5,000
  or five bucks.
            So he was going to school for awhile
  when he first came here under a G.I. Bill and he
  got some money.  I don't know how much it was.
       Q.   The third page of Exhibit Number 6 is,
  again, a handwritten page.  Do you know what this
  is?
       A.   That is probably the total amount we
  gave back to him.  That is what it says.
       Q.   And the fourth page appears to be a
  receipt for an U-Haul, is that correct?
       A.   Yes.
       Q.   You-all rented the U-Haul for him?
       A.   Yes.  When a man turns in all of his
  money, and he wants to leave, he had no money,
  right?  So we give him money.  We help him do what
  he wants to do.
       Q.   I'm looking at the second page now of
  Exhibit Number 6.  This indicates total offerings
  of $6,575.58.  Is that how much Mr. Lindsey
  offered and donated?
       A.   If that's what it says, that's what it
  says.
        Q.   Well, the reason I'm curious is the next
  page says total given $2,487.25.  The first page
  says total $3,133.93, and so I'm confused about
  what the actual amount is.  Can you --
       A.   I can't tell you the exact amount.
       Q.   Now, the last page of this is a receipt
  for $200 cash that Mr. Lindsey signed.  A minute
  ago I thought you said $500.  Do you know if it
  was $200 or $500?
       A.   Probably the $500 is with the rental of
  the U-Haul combined.
       Q.   Back to the second page of this document
  which your attorney provided us, it says returned
  $200 cash, $471.83 moving costs, so $671.83.  You
  think that is the accurate figure?
       A.   I'm sure all of those we can find
  receipts for them.  I would have to look for them,
  but we could do it.
       Q.   Well, we actually have a copy of a
  receipt for $471.83 for the U-Haul.
            Now, the other expense I wasn't clear on
  is at the bottom of Page 2 of Exhibit Number 6 it
  says, this is net of an expense of $692.00 paid
  8/94.  What is that all about, do you know?
       A.   No.  We might have paid some fees or
   something for him to go to school, but I'm not
  sure.
       Q.   You would have to dig that up?
       A.   He had to travel back and forth to
  Beaufort, so we had to provide a car.  We had to
  provide the expense to do it.  There is no telling
  where they all come from.
       Q.   And do you know when it is that Mr.
  Lindsey actually moved?  Would that coincide with
  this U-haul bill?
       A.   Somewhere along in there, yes.
       Q.   Which, for the record, is August 20th,
  2001.
            Is that when, other than the Duvals, is
  that when most of this group left, around August
  of 2001, approximately?
       A.   Duval is the only one that left before.
  Tim Butler, Larry Hartley, Greg, they all left
  about the same time.
            The people up in Canada, they were long
  gone before this ever came about. They had no
  idea.  And the other guy -- you have another one
  there, don't you?

The people in Unity Community in Canada did not brake up until after they learned the truth about what Mr. Stair had done.  I think it was about a year or so later.

       Q.   Oh, yeah.  What about him?
       A.   Which one are you talking about?
        Q.   Kevin Nevin?
       A.   Yeah, Kevin.  Kevin never lived here.
  He never lived here.  He listened to us on the
  radio, and he sent me offerings in the mail like
  everybody else does.  It's amazing.
            I sat over in Alabama and the judge
  looked down and he said, what do you do, you give
  a man the money for the church and you are asking
  for it back?  Who ever heard of such a thing?
             (Plaintiffs' Exhibit No. 7 was marked
  for identification.)
       Q.   Now, Exhibit Number 7, is there a
  summary that Ms. Moratto has prepared for Mr.
  Nevin?
       A.   Yes.
       Q.   And, as far as you know, is that an
  accurate summary of --
       A.   I think it's $22,000 over a five-year
  period of time.  Yeah, $22,000 over a five-year
  period of time.
       Q.   And all of those were mailed offerings,
  correct?
       A.   Right.  Well, they were either mailed,
  or he came one time for a few days and he might
  have gave an offering then, I don't know, but most
   of them were considered offerings.
            And what difference does it make whether
  it comes through the mail or the man hands it to
  me?  If it's an offering, it's an offering.
       Q.   What were the circumstances of his visit
  that one time?
       A.   People come for services.  They like to
  come and hear me preach.  There are a few of them.
  Not too many, but there are a few.  They like to
  come and hear me preach.  Maybe you ought to come.
       Q.   So that is why he came?
       A.   Will you come if I give you an
  invitation?
       Q.   I don't know that I would, number one;
  and, number two, I don't know if your lawyer would
  let me.
       A.   Oh, yeah.  We would let you come for
  service.
       Q.   In Mr. Nevins' case, did he come hear
  you preach?
       A.   Sure.
       Q.   How long did he stay?
       A.   He stayed a couple of days.
       Q.   And do you remember approximately when
  this was?
        A.   No.
       Q.   Now, do you know why Mr. Nevins stopped
  providing offerings?
       A.   I haven't the slightest idea.  It might
  be for the same reason.
       Q.   You have never had a conversation or
  communications with him?
       A.   No.  I haven't talked to Kevin since the
  last time -- I don't -- I can't remember when I
  ever talked to him.  2001, that's the last time he
  gave.  Yeah, it was probably the same reason.
            Do you understand -- no, you don't
  understand.  Tim Butler is the initiator of this,
  and that you do know.  And he went around to all
  of these people, and he knew Kevin, so he went to
  Kevin, and he got everybody he could get to help
  him with this case.  That is what he done.

At that time, Tim and I had no communication with Kevin Nevin.  What ever he heard he heard it from the people that he was having fellowship with in Cherry Hill NJ.  I believe that it was at the home of a Sister Bonnie something.  Don’t you just love the way that Mr. Stair has used Tim as his escape goat for all of his troubles.

            But Kevin, up to that point, had no
  trouble -- never no trouble with Kevin at all.  He
  never said a word to me about anything.  We never
  had any conversation about anything.
       Q.   You talked earlier about your confession
  being the impetus for some of these folks leaving
  the community.
            And I know you talked about having a
   meeting among the church there at the property
  where you made your confession, and you talked
  about another meeting where Mr. Butler was there,
  I believe you said, and you talked to him.
       A.   He wasn't in that general meeting.  He
  was driving the truck that day.
       Q.   Did you ever have a meeting -- excuse
  me.  Not a meeting.  Did you ever communicate your
  confession over the radio --
       A.   Sure.
       Q.   -- or otherwise?
       A.   Sure.
       Q.   So there would have been a way in which
  Mr. Nevin would have heard that confession?
       A.   No.  The confession was made long after
  he made his decision.
            MR. UTSEY:  Are those notes that you are
  passing to the witness?
            MR. CHAPLIN:  No, no, no.
            MR. UTSEY:  Oh, okay.  I was just kind
  of confused about it.
            MR. CHAPLIN:  No, no.  These are my
  notes, and I'm not passing anything to him.
            MR. UTSEY:  Okay.
       Q.   Do you know whether Mr. Nevin ever heard
   your confession?
       A.   I am sure, from my opinion, he heard it
  from Tim Butler.  He didn't hear it from nobody
  else.  But I know what Butler did.
       Q.   He could have heard it from you, though,
  couldn't he?
       A.   I hope he did.  I would have been more
  than glad if he would have.  You know, there is
  nothing more powerful in the Christian faith than
  confession.  It's the greatest thing ever.  If you
  confess, he forgives.  Thank God for confession.
       Q.   And you provided your confession over
  the radio because you hoped that as many people
  that could hear it would hear it?
       A.   No.  I provided my confession because I
  wanted to be right with God.  I am going to meet
  my God one day.  Whether this whole world kicks me
  in the teeth or not, I stand before him one day,
  and I wanted to have my sins forgiven, and I
  wanted to be free from them, so I confessed them
  according to the scriptures so I could be free
  from my sin and see my God.  That is the thing I'm
  concerned about.
       Q.   Well, I'm confused then, because I know
  you had a church meeting where you made that
   confession?
       A.   Yes.
       Q.   Then you did a separate meeting with the
  board of directors and Mr. Butler?
       A.   Because he wasn't in the meeting.
       Q.   So that wasn't to confess to God?  That
  was just so Mr. Butler heard it, right?
       A.   That was so Mr. Butler would know what I
  had done, yes.
       Q.   Sure.  You also then went on the radio
  and made a confession, but you already confessed
  to God?
       A.   Yes.
       Q.   Why is it that you felt the need --
       A.   Because the people out there who do
  support me, and many of them stayed right with me.
  You understand that even though these people left,
  there is 80 or 90 or 100 that didn't leave that
  all knew the same thing.

There was about 50 people that stayed in the community that heard his real confession.  The listeners on the radio heard a rosy painted picture of a child that got caught with his hand in the cookie jar and not the truth.

            And there are people out there who heard
  me on the air, and they did turn away from me
  because they received my confession.  It was an
  honest confession, and they have watched my life
  since then and they have checked me since then.
       Q.   But I'm going back to the purpose of
   your putting the confession on the radio.
       A.   Because it was required of me.  You
  know, nobody required me to make the confession to
  the people except God, nobody.  Nobody caught me
  in that sin, sir, nobody, nobody.  God caught me
  and he told me that you need to do this.
            And I did it because the scriptures tell
  me to, and I did what the scriptures told me to
  do.  I repented of my sin.
       Q.   I understand that.  Did you intend, by
  putting it on the radio, that your supporters
  would hear that confession?
       A.   I wanted the supporters to hear it so
  they could make a judgment.  Do you want to
  continue to keep supporting me or do you not want
  to.  And many of them chose not to.  There are
  people that don't send me any more money.  They
  don't support me.  Then there are others who still
  do.
       Q.   Why is it that you say that Mr. Nevin
  was influenced by Mr. Butler insofar as --
       A.   Because I know what Mr. Butler did.
       Q.   What is that?
       A.   He went to all these people, every one
  of them.  He personally went to them.
        Q.   How is it that you know that?
       A.   Because they let me know.
       Q.   Who let you know?
       A.   They would let me know.
       Q.   They being who?
       A.   They would talk and would go around.  It
  would get back to me.  Mr. Butler talked to this
  one, went to this one.  I'm sorry, but that's what
  he done, sir.
       Q.   No.  I'm not debating that.  I'm just
  saying --
       A.   Oh, never mind.  Never mind.
       Q.   -- "they" is a pronoun and I would like
  a name.
       A.   I don't have any names.  I deal with too
  many people.  I can't give you all the names.
       Q.   So you don't remember who it was that
  told you that?
       A.   No.
       Q.   And you don't remember who Mr. Butler
  approached?
       A.   No, not specifically, except I know the
  result of -- of course, these fellows, these guys,
  were doing what they are doing.  They let me know
  we are not going to support you no more or this or
   that.
       Q.   How about Mr. and Mrs. Pfund.  Tell me
  how long --
       A.   I don't even know those people.
       Q.   Did they ever live at the community?
       A.   No, not at this one.  They lived at one
  in Tennessee.
       Q.   What was the relationship with the
  community in Tennessee?
       A.   Same as the one in Canada.  It's just
  like a church anyplace else.  They fellowship with
  us.  They just open -- they don't do it anymore.
  They broke off and have their own fellowship, but
  at that point in time we had fellowship, like a
  little convention.
       Q.   That point in time being the time when
  the Pfunds lived there?
       A.   I don't know when Eric lived there or
  how long he lived there.  I have no idea.  He went
  there.  The man let them live there.  The one in
  charge there, that is his community.  That was
  his -- he was the one in charge and that was it.
  He made the decisions, and Eric knows that.  To
  hear this man's -- some of the charges he has made
  on me is absolutely ridiculous.
        Q.   What charges?
       A.   That I took his money.  I didn't take
  his money.  He gave it up there where he went to
  live.
       Q.   At the time he gave the donations, was
  that community in fellowship with the community
  here?
       A.   Yes.
       Q.   And we talked about this with respect to
  the Saskatchewan community.  Was the one in
  Tennessee one that you had mentioned on your radio
  broadcast?
       A.   Yes.  I have places now that I mention
  where people gather together.  I have places now.
  For instance, I mentioned one up in Philadelphia
  where a woman just has fellowship in her home.
            I don't have no financial ties to her.
  I don't run the community.  I don't run any of
  these communities.  They have men.  They have
  people there that run their own.  It's a church.
  They have their own church organization. They just
  fellowship with us, that's all.
            And I recommend here is a place to go to
  service, there is a place to go to service or
  there is a place to go to service.
              (Plaintiffs' Exhibit No. 8 was marked
  for identification.)
       Q.   Let me hand you Exhibit Number 8.  Is
  this another summary prepared by Ms. Moratto?
       A.   Yes, I would say so.
       Q.   And does that relate to Mr. and Mrs.
  Pfund?
       A.   Yes.  Those are probably for -- yes.
  Those are funds they sent in the mail long before
  they went to the community up there.
       Q.   Funds that they send in the mail to you?
       A.   They sent to the ministry, my friend.
  Can I say this to you again?  My offerings are
  donated by people from various places throughout
  the world.  They don't send the money to me.  They
  send it to this ministry.

Most checks are written out to "Brother Stair"  not to the ministry.  Most people don’t even know that there is a name to his ministry.   He used to brag in the dinning hall about this and state that he could cash those checks without anyone knowing that he even received them. And keep that money for himself. Just like he had been schooled.  One thing that we have learned about Mr. Stair,  if he brags about it then he is either currently doing it or it is something that he has done in the past.  With him telling all of his stories it is hard to tell the difference from present or the past.

       Q.   This ministry being the one located in
  South Carolina?
       A.   Faith Cathedral Fellowship.
       Q.   Okay.  Now, you talked about donations
  that the Pfunds gave in Tennessee?
       A.   They moved over there, and when they
  moved over there they gave their money.  That is
  their business over there.  It's not mine.
       Q.   Is that when they stopped sending the
   donations here?
       A.   Yes, when they move.  Isn't that simple?
  When they move and they give all their money, can
  they give any more?
       Q.   But when they made their move, did they
  donate everything they owned?
       A.   Over there they did, not to me.  Eric
  has fussed at me many times because he handed his
  money over there and when he left the man wouldn't
  give it back to him, and he fusses at me like I'm
  supposed to send the money back to him.  That's
  not even sense.  I don't even hardly know Eric.
       Q.   Who is the man in Tennessee?
       A.   His name is Dowell, Pastor Dowell.  Ask
  Tim.  He will tell you about him.
       Q.   Is that his last name?
       A.   His name is Dowell, D-o-w-e-l-l, yes.
       Q.   What is his first name?
       A.   I don't know.
       Q.   And are they still in fellowship with
  you here?
       A.   No.
       Q.   Why not?
       A.   My friend, I will repeat to you again.
  When I did that, these people started -- that you
   are talking about -- started to pull away from me.
  They broke fellowship because of this particular
  sin.
       Q.   Because of the confession you made?
       A.   Yes.  When I made the confession, I made
  it openly to the church.  Then I called all of
  these preachers that I knew from all of these
  areas, all of them, and I had a meeting with the
  preachers, with the men of God, with the elders,
  and I went through it again.
            And Dowell was there.  And they decided
  after that meeting that they were not going to
  fellowship with me anymore.
       Q.   Now, when you were in fellowship with
  these other churches, like Dowell's church in
  Tennessee, was there any financial connection
  between your ministry and --
       A.   They maintained their own finances and
  that was it.
       Q.   Did they, for instance, did they send
  donations to you?
       A.   Yes.  They would send donations here
  sometimes and I would send donations there.  We
  would help each other, whatever the need might be.
       Q.   Did they assist with paying for your
   radio ministry?
       A.   They sent offerings here, yes.  Every
  offering that is sent to this place, the primary
  purpose of that offering is to help us maintain
  the radio ministry.
       Q.   And was there a set amount that each of
  them would send you?
       A.   No, no.
       Q.   Would the detailed financial records of
  Faith Cathedral Fellowship demonstrate what
  donations were made by these others?
       A.   Whatever offerings were sent, donations,
  and we have a record of everybody's offering that
  was sent here, no matter who it was.
       Q.   Including if it came from --
       A.   If it would come from Pastor Dowell, we
  would put down Pastor Dowell sent $500.  If it
  came from Pastor Jones, we would put down Pastor
  Jones sent $500.  We have a record of whoever sent
  money here, yes.
       Q.   And the ministry he had in Tennessee, or
  the community he had there in Tennessee, rather,
  did it have a name?
       A.   It's called Straightway.
       Q.   Would your books ever reflect, for
   example, offerings from Straightway?
       A.   No.
       Q.   It would be by the name of the pastor?
       A.   The pastor.
       Q.   Have you ever returned any money to the
  Pfunds?
       A.   No.
       Q.   I think I asked you this, but just to
  make sure.  Did you ever return any money to the
  Nevins?
       A.   No.  The Nevins didn't live with us.
            MR. CHAPLIN:  You answered the
  question.
            MR. UTSEY:  As I understand it, Mathias,
  we are here -- this deposition will only relate to
  those donation cases, right?
            MR. CHAPLIN:  Right.
            MR. UTSEY:  So that if we are going
  forward on any other cases at any point in time,
  then we will do a separate additional deposition
  with respect to those cases?
            MR. CHAPLIN:  That's my understanding.
            MR. UTSEY:  Okay.  I just wanted to make
  sure we were on the same wavelength.
            MR. CHAPLIN:  That is what my fuss was
   about this morning, but I wasn't trying to --
  anyway, let's go ahead.
       Q.   I have here the answers to
  interrogatories which your attorney sent over.
  Have you reviewed these in the past?
       A.   What are they?
       Q.   It's called answers to interrogatories.
  They answer a bunch of questions.
       A.   I am pretty sure I looked at them
  because Mathias is pretty thorough on that.
       Q.   They were sent back in March of 2005.
       A.   Yes.  I'm sure he made sure I saw them.
       Q.   They list a number of witnesses, and I
  want to make sure that I have these correct.
            Brother Christopher would be -- there
  was two Chrises, I believe.  Chris Gingrich?
       A.   Chris Gingrich, you will be talking to
  him a little later on.
       Q.   Okay.  Margaret Moratto we talked about.
  Teresa Stair is your wife.  Chris -- this says
  Singrich, but his name is Gingrich, right?
       A.   Gingrich, yes.
       Q.   David Moratto we have talked about.
  Timothy Jones we have talked about.  Rick Bell,
  you said he was a member of the board, also,
   right?
       A.   Yes.
       Q.   And Joseph Klein, who is Joseph Klein?
       A.   He is one of our ministers, one of our
  brothers.
       Q.   What does he know about this case?
       A.   He knows everything from the beginning.
       Q.   So he has talked to the plaintiffs?
       A.   I am sure they have all talked to the
  plaintiffs.  We lived together.

Joe Klein moved there just after we left. We never talked to him.  Joe Klein was sent to Point Pleasant church location to divide the people and then he sold the property for Mr. Stair.   Joe is one of  Mr. Stairs "Yes Men".  He will say and do anything the Mr. Stair tells him to do even though he knows that it is not the truth.  Just like David Marrota, Christhoper Landry, Pastor Timothy Jones, and any member of the board or elders.

            MR. CHAPLIN:  But do you know that?
       A.   Talked to them about what?
       Q.   I am just trying to find out why he's
  listed as a witness.  What information do you know
  of that he may testify to?
       A.   Joe was in on the meeting when I called
  Mr. Butler in.

How can this be.  Joe Klein was in Point Pleasant at that time.  He was not at the farm.

       Q.   And do you know of any other knowledge
  he would have specific to this case?
       A.   Not any more than anybody else.
       Q.   Do you know of any other witnesses that
  are not on this list?
       A.   Witnesses to what?
       Q.   Who may testify in this case?
       A.   I don't know.  It's up to him.
        Q.   Well, the reason I ask, like I said,
  this was March of 2005 when we got this list of
  potential witnesses from you, and I didn't know
  whether in the last, however many, 20 months or so
  that more have come up.
       A.   I could bring up 500.
            MR. CHAPLIN:  But I would probably
  control who testifies or not.  I don't have any
  names to supplement at this time.
       Q.   Your attorney has produced to me a copy
  of a document dated January 18, 2005, which has
  the board of trustees listed.  Do you know why
  that document was prepared?
       A.   Not in particular.  I guess he's got a
  list of our trustees, our board.
       Q.   Did you do that for purposes of a bank,
  for instance?
       A.   No.  We have always had that.  We might
  have just done it for our own -- on behalf of
  ourselves.
       Q.   How often do you update that?
       A.   I don't have to update it.  It's
  steadfast.
       Q.   This one has a date of 2005.  So if you
  have always had it --
        A.   Well, I think the banker requested it
  for -- to authorize the money for the bail.
       Q.   Now, one of the other documents your
  attorney has produced to us is a copy of a plat
  prepared for Dolly Milbaugh (phonetic) in Point
  Pleasant, West Virginia.
            Do you know why this document was
  included among the documents being produced as a
  potential exhibit in this case?
       A.   Dolly gave us a church and we sold the
  church.  And I don't know any particular reason
  why, except that is part of the land.
       Q.   And then I have a statement from Joseph
  Klein dated January 18, 2005 which talks about the
  work he did in West Virginia and he participated
  in the sale of the building.
       A.   Right.
       Q.   Do you recall any other conversations,
  specific conversations with any of my clients that
  I have asked you about here today that we haven't
  already discussed?
       A.   We didn't have very many conversations.
  I can't recall anything specific.
            MR. UTSEY:  I may be done, but I need to
  take a break and check my notes and we will wrap
   it up.
            MR. CHAPLIN:  Go ahead.
             (A recess was taken.)
       Q.   Was there ever a time that the Allabys
  lived or stayed here at the community in Colleton
  County?
       A.   They came for a visit.
       Q.   How long was that visit?
       A.   I don't know.
       Q.   Would it have been about a month in
  length?
       A.   No.  It might have been a couple of
  weeks.
       Q.   Do you know why it is they came for that
  time frame?
       A.   Yeah.  They came to visit.
       Q.   Was that something that you suggested to
  them?
       A.   I invite people to come to services all
  the time to see us, sure.
       Q.   So that is a yes?
       A.   It's a yes in the general sense.  It was
  not just a general invite to them personally.  It
  was a if you want to come be with us in service.
       Q.   Did you ever have a specific
   conversation with the Allabys encouraging them to
  come to Colleton County community?
       A.   If they wrote and said they wanted to
  come for a visit, I'd say sure.
       Q.   Did that happen?
       A.   I'm sure, or they wouldn't have came.
       Q.   Was there ever a time where either of
  the Pfunds ever lived in the Colleton County
  community?
       A.   No.  They came for a visit like
  everybody else.  Come to visit and they came to
  live with us.
       Q.   When did they come to visit?
       A.   I don't know.
       Q.   Would that have been before they moved
  into the Tennessee community?
       A.   No.  Those people never came, that I
  know of.
       Q.   They never came to Colleton?
       A.   Not Eric Pfund, no.
       Q.   Or his wife?
       A.   I don't even know his wife.  I wouldn't
  know them if they walked through that door.
            MR. UTSEY:  Okay.  I don't have any
  other questions.
                  EXAMINATION
  BY MR. CHAPLIN:
       Q.   I have a few follow-up questions for
  you, Mr. Stair.
            Based on the individuals that you have
  been asked about so far today, I think they are
  plaintiffs that have filed actions against Faith
  Cathedral and yourself, did you enter into formal
  or informal contracts with any of these people?
       A.   No.
       Q.   Did you make promises to them, exactly
  what their tithes would be used to pay for?
       A.   No.
       Q.   Did you make representations to them
  about what the money would be used for in any
  purpose?
       A.   Only in reference to most of it was used
  for radio broadcasting.
       Q.   When you made the -- when you made the
  confession to the congregation, did any leave at
  that time because they felt their money was being
  used improperly or because they couldn't stand you
  any longer?  Why did they leave?
            MR. UTSEY:  Object to the form.
       Q.   When you made the confession to the
   congregation -- do you recall that time?
       A.   Yes.
       Q.   Why did they leave after the confession?
            MR. UTSEY:  Object to the form.  You are
  asking someone else's state of mind.  But, I mean,
  he can answer it if he thinks he knows.
            MR. CHAPLIN:  I am asking what is his
  impression of why they left.
       A.   They didn't leave right away.
       Q.   But what is your impression as to why
  they eventually left?
       A.   Well, I think as they got to talking
  about it, and I think it was Tim Butler, but they
  decided that I wasn't going to stop preaching, and
  that I was going to stay on the radio because that
  was my ministry, and --
       Q.   Did you get the impression that they
  were upset with you for what you had done?
       A.   I think a lot of them had got to -- how
  do I put this?  I think after they started living
  with us, in their own heart they decided that
  really wasn't what they wanted to do.  So when I
  made this confession, it gave them a reason to
  justify going and there was no way out.  It's
  almost like a marriage.  The honeymoon was over.
        Q.   So you think that in their minds -- or
  you had the impression that when you confessed
  your sins to them --
       A.   It gave them a reason to --
       Q.   -- they became disgusted with you?
       A.   Yes.  At that point I was disgusted with
  myself.  Oh, Lord.
       Q.   Give me one second to look over a few
  things here.  I know you have been asked this
  question by opposing counsel, but why did you give
  back any money to these people and -- why did you
  give them any money?
       A.   Retrospectively, I wish I hadn't.
       Q.   But you did, so why?
       A.   I just didn't feel it was right for
  people to come here and give everything they had
  and to go back out there without having something
  to go back out with.  And so friend and foe alike,
  I gave money back to them.
            I gave one man $5,000, and I could kick
  myself for that, because the man didn't -- you
  know, I just couldn't picture at that point people
  going back out without anything.
       Q.   Okay.
       A.   So I made sure they had money to get
   where they were going and --
       Q.   Okay.  Thank you. I think you answered
  my question.
            As far as the amount you gave them, at
  any point did you consider how much it cost you to
  take care of these individuals --
       A.   Sure.
       Q.   -- during the time that they were there?
       A.   Sure, sure.  It was always considered.
       Q.   You looked at what you invested as far
  as their daily --
       A.   Sure.  You give them a livelihood, and
  living in fine homes, and all bills paid and
  everything you needed, the minimum would have been
  $15,000 a year.  You stay four or five years,
  $15,000 a year, what have you got?  Yeah, my mind
  thought that way.
       Q.   Well, what about people who only gave
  like maybe -- or had nothing to give but had
  bills?
       A.   It didn't make a difference.
       Q.   Did you still give them money?
       A.   Sure.
            MR. CHAPLIN:  I don't have anything
  else.
                  FURTHER EXAMINATION
  BY MR. UTSEY:
       Q.   Let me ask a follow-up question on
  those.  When you considered the value of the
  living arrangements there when you were
  considering --
       A.   I never even gave that much thought, my
  friend.  Mr. Duval was the one that brought it to
  me.  I was flabbergasted.
       Q.   Well, let me make sure I'm clear then.
            Did you or did you not consider the
  value of what these people received for living in
  the community when it came time to determine how
  much to pay them?
       A.   Yes.
       Q.   Did you also consider the value that the
  community got from their services that they
  donated?
       A.   Everybody gave the same.  Everybody in
  the community was equal.
       Q.   And did you value that in monetary
  terms?
       A.   Yes.
       Q.   What was the value of the services that
  you assigned to my clients who lived in the
   community?
       A.   I told you, their living expenses.  They
  lived.  They lived there.  Like about $15,000,
  $20,000 a year would be the value.
       Q.   That would be the value of what they
  gained from them living there, right?
       A.   If they were out somewhere living like
  they lived in that community, it would cost them
  between $15,000 and $20,000.
       Q.   I understand that.  But if they had been
  out living somewhere else and doing the work they
  were doing, they also would have been paid for
  that, right?
       A.   And they were getting paid.  They were
  getting paid what they agreed.  They agreed that
  they would get -- whether a brother turns in five
  bucks or one turns in five thousand, the equality
  is there.
       Q.   What I'm asking, though, is when you
  went through this mental process of evaluating how
  much benefit these individuals received from
  living in the community, did you also evaluate the
  benefit that the community received from the
  efforts that these individuals put in there by
  doing whatever tasks they performed at the
   community?
       A.   Yes.  Sure I did, and none gave any more
  than anybody else, none of them.
       Q.   What was that amount that you evaluated?
       A.   Whatever they had.  Everybody gave
  everything.  I have some out there that gave ten
  dollars.  You know, Jesus used an example like
  that.  He said, that woman gave more than you all,
  because she gave everything she had, and that is
  our basis up there.
       Q.   No.  I am not talking about the monetary
  contributions that they made.  I am talking about
  the work contribution.
       A.   That is their monetary contributions,
  what it's worth.
       Q.   Like I thought you said somebody worked
  on computers?
       A.   Yes.
       Q.   Somebody was good with financial issues?
       A.   You put all of these talents into it.
       Q.   Someone did, you said, the dairy farm?
       A.   Right.  The diary farmer, he doesn't
  contribute any more than the one that works on the
  computer.
       Q.   Well, how do you value someone's
   services --
       A.   And it was the righteous theory.
       Q.   -- if they are not working for a
  paycheck?
       A.   We don't do it like the world out there.
  You are giving everything you have, whatever your
  ability is, whatever your talent is.  Some can do
  this and some can do that, but you are giving all,
  and that's where the value is.
       Q.   Well, did they get any monetary credits
  for those contributions, the work contributions --
       A.   No, no.
       Q.   -- when you decided on how much to
  return to some of these people?
       A.   No.
       Q.   Why not?
       A.   No reason to.  Technically,
  scripturally, theologically, religiously and
  legally, as a church I have no obligation to give
  them any money back, none whatsoever.  Churches
  don't give money back when you donate it to them.
  Churches just don't do that, sir.
       Q.   But you did that?
       A.   I did because I had a sense of judgment
  inside me that I wanted to help these people get
   back to where they can live, at least a little
  bit, even if they did me wrong.
            It didn't make no difference.  I wanted
  to help them get back out and pick up the pieces
  that they had laid down when they came.
       Q.   And the benefit --
       A.   Boy, is that a wrong thing, sir?  Would
  you make a judgment on that, please, sir?  Never
  mind.
       Q.   And the benefit of living in the
  community to each of these people, was that
  something that the church expected to get some
  return on?
       A.   Say that again.
       Q.   The monetary value or benefits --
       A.   We don't figure monetary value.  It's
  the last thing in the world we figure.  We have a
  spiritual and moral conscience we work by, and it
  doesn't matter whether a brother gives me $5,000
  or it costs me $20,000 to take care of him.
            The money has no value at all to us.
  Our faith is our value.  Our life-style is our
  value.  Our comfort in God is our value.  Our
  trust and our love for each other, that is where
  we put our value.
        Q.   I understood you to say a minute ago,
  though, that you assigned a value per year of
  living in the community?
       A.   I am just trying to show these people
  that they didn't get a raw deal.  They got a good
  deal.  They came in with debts.  They left without
  them.  Their debts were paid.  You can't evaluate
  that.
       Q.   But as far as the living arrangements,
  that is something the church was giving to them as
  part of the arrangement when they moved there,
  right?
       A.   Absolutely.
       Q.   Just like they were going to give their
  talents and their efforts to do work there at the
  community, right?  They weren't expecting to be
  paid for the work they do their on the farm any
  more than the church was expecting to be paid for
  furnishing them a home, right?
       A.   That's right.  There is nobody paying
  anybody.  They didn't pay me anything.
       Q.   Right.
       A.   Can I say something to you one more
  time?  They gave offerings, sir.  They did not pay
  anything.  They weren't buying anything.  They
   gave offerings, like you walk into your church and
  you say I'm going to give you $1,000 this morning.
            MR. CHAPLIN:  We have that established,
  Brother Stair.  We have that established.
            THE WITNESS:  You better believe it.
       Q.   Now, you said you didn't make any
  promises or representations as to the use of the
  funds that they offered?
       A.   That's right.
       Q.   Are you saying that you could have done
  anything with those funds and it would have been
  appropriate?
       A.   No.  I didn't say that.  I --
       Q.   I am asking you if you are saying that.
       A.   No.  I would do the appropriate thing
  with it.
       Q.   Now, where do you draw the line?  Could
  you have, for example, used those funds to gamble?
            MR. CHAPLIN:  I am going to object to
  that based on what is Christian-like and what is
  not.
            MR. UTSEY:  Okay.  Well, I understand
  your objection.
       Q.   Could you have used those funds to
  gamble?
             MR. CHAPLIN:  I'm going to object.
       A.   I could have stole every dime if I
  wanted to, but I didn't because I have a God in
  here.  I have a righteous in me.
            I could be like a lot of other crooks
  out there, like lawyer crooks and like any other
  crooks, like preachers that have been crooks, yes,
  I could have, but I haven't done that and I didn't
  do that.
       Q.   Why not?
       A.   Because I'm not that kind of a man, sir.
       Q.   Would that have been consistent with the
  purposes for which these people donated those
  funds?
            MR. CHAPLIN:  I am going to make an
  objection based on the fact --
            MR. UTSEY:  You can object to the form
  and that is it.
            MR. CHAPLIN:  Right.  Okay.
       Q.   Would that have been consistent with the
  purposes for which these funds --
       A.   Sir, I am going to answer your question
  straight out one more time.  I am a preacher of
  the Gospel.  I am a servant of the living God.  I
  get on the radio and I present the message that
   God tells me, and I ask the people to support this
  with their offerings.
            I tell them it has to be free will
  offering.  You give it cheerfully and willingly.
  If you don't do it that way, I don't want it.
            And when I get your offering, I am going
  to continue to pay this radio broadcast and stay
  on the air and preach the Gospel.  That is what
  I'm going to do, and that is what we have done,
  period, with no exceptions.
            And we don't make no -- somebody gives
  much, somebody gives little, it doesn't make any
  difference.  The amount has nothing.  I don't get
  paid and nobody else gets paid.  We are serving
  the Lord.
       Q.   Are the purposes that you use those
  funds for Christian purposes?
       A.   Absolutely, or Christian principles,
  yes.
       Q.   With respect to the instance where you
  were arrested for second-degree sexual assault,
  did that relate to your relationship with --
            MR. CHAPLIN:  I am going to object based
  on the protective order that I'm about to file,
  the motion I'm going to file.
             MR. UTSEY:  Well, let me ask the
  question before you object.
            MR. CHAPLIN:  Well, I think the nature
  of the question already alerts me to the fact
  that --
       Q.   Well, let's put it this way.  Did the
  ministry or did it not pay for your legal fees
  associated with these criminal charges?
       A.   Absolutely.
       Q.   They did?
       A.   I am the president of the organization.
  They had a right to.
            MR. CHAPLIN:  Just answer yes or no.
       A.   Yes.
       Q.   Did the criminal charges arise from your
  relationship with Stacey Belford or Laquiela
  Jones?
       A.   Sure.
       Q.   Was your relationship with Stacey
  Belford one that you would say was a Christian
  relationship?
       A.   No.
       Q.   Was your relationship with Laquiela
  Jones one that you would say --
       A.   I was derelict in my duty.  That is why
   I made the confession, yes.  I did the Christian
  thing about it.
       Q.   Right.  I understand that.  But the fact
  that you were accused of wrongdoing was not a
  Christian purpose, was it?
       A.   I was in a Christian position.  I was a
  minister of the Gospel.  I was operating in a
  Christian position, so therefore it had to do with
  the Christian principle, yes.
       Q.   Is it your testimony that the use of the
  ministry's funds to pay for your criminal defense
  in that matter was for a Christian purpose?
       A.   Sure.
       Q.   And why?
       A.   Because I'm a Christian and I was doing
  Christian work.
       Q.   So anyone who is accused of a criminal
  act, even if they are guilty --
       A.   I can't speak for anyone else.
       Q.   -- as long as they are a Christian --
       A.   I can't speak for anyone else.
       Q.   As long as they are a Christian --
       A.   I can't speak for anyone else.
            MR. CHAPLIN:  Objection.  Calls for
  speculation.
        A.   I can't speak for them.  I can only
  speak of my situation.
       Q.   Because you are a Christian, that makes
  it a Christian purpose?
       A.   Because I was in charge of this
  Christian organization, yes, and the men around
  me, because they were my brothers.  I would pay
  for others if they were charged.  I would do it
  for you if you were part of the community.
       Q.   Are my clients Christians in your eyes?
            MR. CHAPLIN:  Objection.  How would he
  know?
            MR. UTSEY:  In his eyes I asked him.
       Q.   Are my clients Christians?
            MR. CHAPLIN:  What basis would he have
  to answer that on?
            MR. UTSEY:  Listen, you can object to
  the form, but that's it.  I have let you bend the
  rules every -- Mathias, this has been the worst
  deposition I have attended in a long time with
  your constant input.  We can read the rules if we
  need to.  All you can say is object to the form.
            MR. CHAPLIN:  Object to the form.
       A.   I don't know.  I can't say yes or no.
       Q.   If they are Christians, would the money
   that they are requesting be paid back to them be
  used for a Christian purpose?
       A.   No, it's an offering.  They gave an
  offering to a church.  Then I would have to give
  everybody their money back if that would be the
  case, wouldn't it?  No, no.
       Q.   And what would be wrong with that?
       A.   Because it's not the rights -- it's not
  something you do that is right.  When you give it,
  you give it and you give it and it's free.  That's
  it.  They weren't buying nothing.  They weren't
  buying service.  They weren't paying for service.
  They were giving.  They were giving, free will
  giving.
       Q.   For what?
       A.   For the cost of Christ to be preached,
  and for me to be free so I can preach it.  And to
  defend me, the charges were both thrown out.  None
  of them were ever proven.
            They called me back so I could preach.
  That is a Christian thing.  It was used to put the
  preacher back doing the job he was doing all
  along.
       Q.   Is it important that those charges were
  dismissed?
        A.   You better believe it.
       Q.   Why?
       A.   Because they weren't true.
       Q.   Oh, okay.  What was true, then, about
  your relationship --
       A.   I committed adultery.  I told you, sir.
       Q.   No, you didn't, because your lawyer
  wouldn't let me go into all of this.
       A.   I told you I committed adultery.  I did
  tell you that.
       Q.   You slept with --
       A.   I told you I committed adultery with the
  two women.  I told you.  What do you mean I didn't
  tell you?  Are you going to sit over there and say
  I didn't tell you that?  You would do that, sir?
       Q.   No.  I want to know the details of your
  relationship with Stacey.
       A.   Details, nothing.  I committed adultery.
  That was it.
       Q.   How old was Stacey Belford when you --
       A.   What difference does that make?
       Q.   Because --
       A.   She was a woman.  She was a grown woman.
       Q.   You told me that the charges against you
  were not true.
        A.   They were not true.  I did not rape the
  girl.  I did not commit sexual --
       Q.   How old was Stacey Belford when you had
  sex with her?
       A.   I have no idea, but she was of age, I
  can tell you that.
       Q.   How about Laquiela Jones?
       A.   If they were not of age, then those
  charges would not have been dismissed.
       Q.   Do you know how old Laquiela Jones was
  when you had sex with her?
       A.   She was probably 18, 19, 20.  I don't
  know.  I don't really have any idea.
       Q.   How about Stacey Belford?
       A.   All in the same bracket.
       Q.   And is it your testimony that these were
  consensual sexual relationships?
       A.   Absolutely.  Can I ask you a question?
       Q.   No.
       A.   You don't know the charges?  You don't
  know the case I went through here?
       Q.   Did you induce either of them to have
  sex with you based on any sort of --
            MR. CHAPLIN:  I am going to renew my
  objection based on the form and the protective
   motion I'm going to file.
            MR. UTSEY:  Well, he just testified the
  charges weren't true.  I have a right to ask him
  what --
       A.   They weren't true.  They weren't true.
  I did not rape them and they did consent.
       Q.   Were you charged with rape?
       A.   I was charged with second-degree sexual
  conduct.  That is what I was charged with, second
  degree, and they were both dismissed and thrown
  out because I did not do that.
            It was a consensual simple act of
  committing fornication or committing adultery.
  That is what it was.  It was not a rape or an
  assault.
       Q.   In order to induce sexual acts with
  either of them, did you suggest to either of them
  that God would --
       A.   No, no.
            MR. CHAPLIN:  We are going to object to
  the form of the question.  Do not answer.
       Q.   -- there would be divine retribution
  against them if they would not engage in sex with
  you?
       A.   No.
        Q.   Did you make them any sort of promises
  of divine reward if they would have sex with you?
       A.   No, no.
       Q.   Were both of them, when they had sex
  with you, in their right mind?
            MR. CHAPLIN:  Do you want to continue
  with this?
       A.   May God have mercy on your soul.
            MR. CHAPLIN:  I renew my objection.
       Q.   Were either of them in their right mind
  when they had sex with you?
            MR. CHAPLIN:  Objection.
       A.   They were both in their right mind.
       Q.   Were either of them under the influence
  of any sort of medication --
            MR. CHAPLIN:  Objection.
       A.   I have no idea.
       Q.   -- illnesses or other substances?
            MR. CHAPLIN:  Objection.
       A.   I have no idea.
       Q.   So you had sex with them and you didn't
  know any of this?
            MR. CHAPLIN:  Objection.
       A.   I have no idea.
       Q.   And you didn't know at the time you were
   having sex with them?
       A.   I had no idea.  We didn't discuss that.
            MR. CHAPLIN:  Objection.
       Q.   Did you observe their conduct prior to
  that?
            MR. CHAPLIN:  Renew my objection based
  on the protective order that we agreed I would be
  filing immediately after this regarding those two
  cases that are 40J.
       A.   This is a civil case, sir.  This is not
  a criminal case.
       Q.   Well, the civil case relates to the
  money that you claim you spent on attorneys' fees
  for what you claim was not true.
       A.   The money had been spent and accounted
  for.
       Q.   And you claim that these allegations
  were untrue, so I'm trying to find out what is
  true and what isn't true.
       A.   The truth is that the allegations that I
  raped the girls on criminal assault was not true.
       Q.   What did happen?  Tell us what happened.
       A.   I committed adultery.
       Q.   Well, there is a lot to that.  What did
  you do?
        A.   No, I just committed adultery.  I just
  committed adultery.
       Q.   Did you approach them or did they
  approach you?
            MR. CHAPLIN:  I'm still going to renew
  my objection to form.  I think that we agreed
  that --
            MR. UTSEY:  I understand you objected to
  the form.  We can have a standing objection to the
  form.
            MR. CHAPLIN:  All right.  And I am going
  to instruct my client not to answer.
       Q.   Are you going to answer the question?
       A.   No, I'm not going to answer.
            MR. UTSEY:  Well, then we can deal with
  that on the protective order.
            MR. CHAPLIN:  Okay.  Fine.
       Q.   You understand that if the judge rules
  in my favor we will have to come back and do this
  again?  Do you understand that?
            MR. CHAPLIN:  Yes, he understands that,
  and I do too.
       Q.   Your attorney asked you earlier whether
  you entered into any contracts, express or implied
  with my clients, and you answered no?
        A.   No.
       Q.   What is your understanding of what would
  have been necessary to --
       A.   The answer is no.
       Q.   What is your understanding --
       A.   That is my understanding, no.
       Q.   What is your understanding of what a
  contract would be in that context?
       A.   A signed agreement or a verbal
  agreement.  We did not do that.
       Q.   You had no agreements with them?
       A.   No.  The only agreement I had, that they
  understood what they were going to live under and
  that's it, and that's it, and they did
  understand.  And if they say they didn't, they
  lie.  They did understand.  And that is the only
  agreement they had.
            And then they agreed to it because they
  gave their money.  They gave what they gave
  because they agreed to that with the situation.
  They understood it and they agreed to it.
       Q.   Was that a contract?
       A.   They gave the money.  They gave an
  offering.  It's not a contract.  There was no
  signing on my part or theirs.
             I did not agree with them how I would
  use the money and they did not agree with me on
  paying it.  They just gave an offering.
       Q.   When you say that there was no contract,
  are you saying that there was nothing in writing?
       A.   That's right.
       Q.   Is there anything else that makes you
  say there was not a contract?
       A.   Yeah.  I said it's not a contract.
       Q.   Why?
       A.   Because I just said so.
       Q.   What you just said?
       A.   Yeah.  I just said it wasn't a contract.
       Q.   Is there any other reason that you say
  there was no a contract?
       A.   No, no reason.
            MR. UTSEY:  That is all the questions I
  have.
            MR. CHAPLIN:  Let's just stop there.
            MR. UTSEY:  All right.  That is, of
  course, subject to my right to resume should we
  prevail on the protective order.
            MR. CHAPLIN:  That's fine.
         (The deposition was concluded at 4:40 p.m.)
                      -  -  -


   STATE OF SOUTH CAROLINA  )
                           )
  COUNTY OF CHARLESTON     )
 
       I, Nancy Ennis Tierney, Certified Shorthand
  Reporter and Notary Public for the State of South
  Carolina at Large, do hereby certify that the
  witness in the foregoing deposition was by me duly
  sworn to testify to the truth, the whole truth and
  nothing but the truth in the within-entitled
  cause; that said deposition was taken at the time
  and location therein stated; that the testimony of
  the witness and all objections made at the time of
  the examination were recorded stenographically by
  me and were thereafter transcribed by
  computer-aided transcription; that the foregoing
  is a full, complete and true record of the
  testimony of the witness and of all objections
  made at the time of the examination; and that the
  witness was given an opportunity to read and
  correct said deposition and to subscribe the same.
 
       Should the signature of the witness not be
  affixed to the deposition, the witness shall not
  have availed himself of the opportunity to sign or
  the signature has been waived.
       I further certify that I am neither related
  to nor counsel for any party to the cause pending
  or interested in the events thereof.
       Witness my hand, I have hereunto affixed my
  official seal this 21st day of December, 2006, at
  Charleston, Charleston County, South Carolina.
 
 
 

  _______________________
Nancy Ennis Tierney
CSR (IL)
     My Commission expires
     April 6, 2014
DEPONENT CORRECTION SHEET
DEPOSITION OF: RALPH GORDON STAIR
TAKEN ON:      December 4, 2006
 
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            Ralph Gordon Stair          Date
 

 

 

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