UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT TACOMA

CHERYL LINDSEY SEELHOFF, a married woman, Plaintiff, Tacoma, Washington vs. PAT and SUE WELCH, husband and wife, Defendants.

Docket No. C97-5383FDB Tacoma, Washington September 2, 1998 Trial Volume 3

TRANSCRIPT OF PROCEEDINGS BEFORE THE HONORABLE FRANKLIN D. BURGESS UNITED STATES DISTRICT JUDGE, and a Jury.

APPEARANCES: For the Plaintiff:	BARBARA J. DUFFY GWENDOLYN PAYTON KLEIN Lane Powell Spears Lubersky 1420 Fifth Avenue, Suite 4100 Seattle, Washington 98101-2338
For the Defendants:	RUDY R. LACHENMEIER LORI DeDOBBELAERE Lachenmeier, Enloe & Rall 9600 S.W. Capitol Highway Portland, Oregon 97219
Court Reporter:	Teri Hendrix Union Station Courthouse, Room 3100 1717 Pacific Avenue Tacoma, Washington 98402 (253) 593-6545

Proceedings recorded by mechanical stenography, transcript produced by Reporter on computer.

Excerpt from transcripts Volume 3 September 2, 1998 Pages 446-683


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P.O. Box 1935
Tacoma, Washington 98401

479

1  remember it was the day before I started my discussions. That I
2  know for a fact. Unless there is more than one version of the
3  June 30 letter, this appears to be the same letter.
4  Q. This was a letter you put in your Cheryl Lindsey file?
5  A.  Yes.
6  Q.  You talked to both Joe and Irene in this conversation?
7  A.  To the best of my recollection, yes, I did.
8  Q.  As you sit here today, do you recall, was it a speakerphone
9  conversation, they were on a speakerphone or both on separate
10  receivers?
11  A.  To the best of my recollection, they were on separate
12  receivers. That would be to the-best of my recollection.
13  Q.  They gave you Claude's number in New Orleans, is that fair?
14  A.  That's correct.
15  Q.  Did they ask you to call Claude in New Orleans?
16  A.  I do not recall if they asked me to call Claude or not.
17  Q.  Do you recall if you had asked for Claude's phone number in
18  New Orleans?
19  A.  I do not recall if I asked for it or they provided it.
20  Q.  Do you recall if in this conversation Joe and Irene asked
21  for your assistance in any way to investigate the issues going
22  on with Cheryl Lindsey?
23  A. I'm not sure if they asked -- if they termed they were
24  asking for my assistance. I had understood from them that they
25  had contemplated calling me and, thus, when I called them, I do

480

1  vaguely recall that it surprised me that they knew who I was.
2  Q.  In this conversation did you admonish them or criticize them
3  in any way for not calling you?
4  A.  Not to my knowledge.
5  Q.  Do you recall if you were upset that you didn't learn about
6  this situation until July 1, 1994, after the convention?
7  A.  Yeah, I was disappointed that I did not know about it prior
8  to the convention.
9  Q.  Was there any particular person or individual you were
10  disappointed with?
11  A.  Yes, I was disappointed with Gregg Harris, that he, from
12  what I had determined, had known and was also at the convention
13  with Cheryl, and would not have brought that to my attention at
14  the convention or prior to.
15  Q.  Anybody else that you were disappointed with about not
16  bringing this issue to your attention?
17  A.  Yes.
18  Q.  Who?
19  A.  Cheryl Lindsey.
20  Q.  And you would have expected her to bring a matter like this
21  to your attention?
22  A.  Absolutely.
23  Q.  Anybody else that you were disappointed with?
24  A.  That I recall at this time, no.
25  Q.  How soon after you talked to Joe and Irene Williams on July