Winston Blackmore transcript

8/12/2019 Winston Blackmore transcript

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DEPOSITION OF:Winston K. Blackmore

A PPE A R A N C E SFor the PlaintirT:

Ab.n W. MortcmcnLance L. MilneDEWSNUP. KJNG OLSEN36 Suu1h Slate SlrcctSuile 1400Sail Lake Cil)', ULa J 84111for the Defendant United ErTan Plnn Tn...Jjt by andthrough Bmce R. Wisan Coon-Appointed p ~ i a l

f ~ d u c i a r yJohn Edward Han5CnSCALLEY READING BATES HANSEN RASMUSSEN, P C15 Wesl Soulh TempleSuilc 600Sail Lake Cily, Utah 8410 IJeffrey L ShieldsCALLISTER NEBEKER McCULLOUGHZions Bank Built.Jing1 Suite 900I 0 Ea" SouLh TempkSaiL Lako CiLy ULah 64 133Also Present: Ken \er

INDEX

WITNESSWINSTON K. BLACKMORE

PAGE

Ex.ami n


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DEPOSITION OF:Winston K. BlackmorePage 6

1 Where were you born?2 A l was born right-- well, it was called3 Lister then, Lister, B.C. in Canada, which is now4 Creston.5 Q What year were you born?6 A 1956.7 Q Did you grow up in Canada?8 A In the same place on the same property I have9 lived all my life.

10 Q So a long-tenn resident?11 A Long-te1m.12 Q. Let me ask specifically have you been13 involved with the FLDS Church or polygamist community in14 Canada?15 A Yes, Thave.16 Q Could you tell us about you r background with17 regards to the FLDS Church or its predecessor18 organization?19 A. Well, l was born-- my father was a member of20 the organization and I was born into his family, one of a21 large family, and lived my whole life in our faith.22 Q. And have you -- so you have been experienced23 or knowledgeable about the FLDS Chureh your whole life;24 is that correct?25 A. The FLDS Church didn t even exist prior to

Page 71 19 -- the 1990s, but I have definitely been involved as a2 member and later on as an officer.3 Q. When you say the FLDS Church didn t exist4 before the 1990s, could you explain t us a little bit5 about, you know, the history of the FLDS Church or how it6 evolved to become the FLDS Church?7 A. We were never known as the FLDS Church when8 we were children growing up. And until probably the9 mid- 90s, 94, 95, when we started referring t

10 ourselves as the FLDS Church, somewhere in there, I don t11 know exactly when it was, I discovered-- I discovered,12 beeause I didn t know before that, that there was13 actually a registration in 1991 of the FLDS Church. But14 we didn t really know ourselves as that. And from what l15 understand, we did that for some legal reason. We16 incorporated the name for some legal reason.17 Q. As you grew up, what was the religion called18 or what did you call-- how did yot1 reference your group?19 A. We actually referenced ourselves as members20 of the Church of Jesus Christ of Latter-day Saints21 personally, beeause my father went on a mission for the22 Church and he studied on his mission, he studied the23 basic doe trine of the Church.24 When I was baptized, I was baptized a member of25 the Church and confirmed a member of the Church ofJesus

ill C. Dunford RPR, CSR

M.J. , aka ELISSA WALL v. WARREN JEFFS

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Page 8Christ of Latter-day Saints, but we lived under -- in anorganization known-- well, referred to as The Work, ThePriesthood Work. It was a group of men who had acommission to see to it that we praeticed all of theoriginal principles of our Mormon faith.

Q And one of the principles that distinguishedyour grOllp, The Work, as you were growing up from theoffieial church of Jesus Christ of Latter-day Saints wasthe practiee of polygamy; is that 1ight?

A Yes, it is.Q The praetiee of polygamy would have been a

fundamental principle or practiee of The Work or whatlater became the FLDS Church. Would that be fair to say?

A. Yes, it is.Q And at some point I understand you beeame a

bishop up in Canada?A. Well, first-- the first part of my ministry

was in 1980. I was aetually appointed by our thenpresident Leroy Johnson to be the Sunday SchoolSuperintendent. And in 1984, he offieially ordained me abishop.

Q. Okay. You were a bishop of what size or whatcongregation? Can you give us some understanding ofthat?

A. The size --we got up to around a thousandPage 9

people, but we were probably less than half of that tobegin with.

Q. But how broad of an area were you bishopover?

A. Tlu-ee, three eonununities; a community inCreston, a eommunity in Cardston, Albe11a, and also acommunity in Rosemary, Alberta.

Q. What-- would I eall those FLDS communitiesor what-- how would you characterize-- you re talkingabout communities that were practicing yom same faith 01religion; is that right?

A. Yes, I was, but they were-- these peoplewere all LDS, you know, that s where they were-- howthey were bam and became about who were just trying topractice, you know, their original fundamental principlesof their faith.

Eventually we had a community in northem Idahoand I was also bishop of that.Q. Okay. Eventually the association of thegroup became known as the FLDS; is that right?

A. Yes, it did.Q. You served in the capacity o being an FLDSbishop; is that right?

A. Yes.Q Were there any other FLDS bishops in Canada

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DEPOSITION OF :Winston K. BlackmorePage 10

1 or were you the bishop for all of the FLDS g roups in2 Canada?3 A. Twas the bishop for them and looked after4 them .5 Q. How long did you serve in the role o f being6 an FLDS bishop -- the FLDS bishop in Canada?7 A. From '84 to 2002 .8 Q And can yo u tell us about your duties or9 res ponsibilit ies as a bishop over these communities?

10 What wo uld a bishop do in the FLDS Church?11 A. We ll , I received the tithes and the12 offerings, established a storehouse . I loo ke d after the1 3 widows and the fatherless. I looked after the dead . If14 anyone died , I had responsibility to take care, see that15 they were properly taken care of in their-- in their16 death and I was --m y responsibility was to pay for their17 service and see to it that they were -- the famil y was nt18 burdened.19 As a - - I also basical ly looked after the2 0 prope1t y , the Chur ch's property , and was also a2 1 hu sinessman in the process, so ..22 Q What kind of business -- your work has been23 as a businessman?2 4 A Ye s, it has. We were into fanning. We had25 an extensive farming operation and forestry. We

Page 111 manu factured fence posts, traded them , and marketed and2 tn.Jcked them.3 Q. Now, do you have any experience or4 involvement with the UEP Trust?5 A. Well , I was a Trustee from-- o fficial6 Trustee from 1984 -- or from-- I mean I guess I was7 unofficial from '84 to '86, beeause I did look after the8 property.9 Q. So if I understand right , you were bishop10 beginning in I984. Is that right?1 1 A. Yes.12 Q. And then I bave see n in the declaration where1 3 you indicate you we re appo in ted as a Trustee of the UEP

14 Trust in 1986. Is tha t correct?1 5 A. Yes, I was, first in February, and then on1 6 the passing of President Johnson, I attended the first1 7 Trustee meeting that I went to.1 8 Q. That would have been in 1986?19 A. Yes.20 Q. So you served as a Trustee of the UEP Tmst21 fo r how long?22 A. O fficially, from '86 to 2002, officially.23 Q. And you say officially. Te ll us what2 4 happened in 2002.25 A. Well, in 2002, Warren Jeffs had me dismissed

J i C . Dunford RPR, CS R

M. J . aka ELISSA WALL v . WARREN JEFFS

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Page 12from the Church and supposedly from my duties, but Iwasn't notified of the dismissa l of my duties unti l lateron that year when I got an official notiee. But nothingreally changed for me. I s ti ll did what I was doiog.Q. Have you eontinued to serve as a bi shop inCanada after 2002?

A. Yes, I sti ll do have quite a good-sizedcongregation still.

Q. Your service as a bishop si nce 2002, has thatbeen in connection with the FLDS Church or has that beenseparate from --

A . No, it s separate from 01em.Q. So ifl understand correctly then, in 2002,

Warren Jeffs dismissed you as the FLDS bishop in Canada? .A. Yes, he did.Q. But you continued to serve those who were

wanting to be involved wi th your congregation from thattime forward?

A. Yes, I d id. ln fact, this is tbe 30th year.Q. So you have been serving as the b ishop up in

Canada for 30 years?A. Th irty yea rs .Q. That's a long time to be a bishop.A. I wou ld like to retire-- I mean have

somebody else do it. It's no t a fun job, as you know.Pa ge 13

Q. I want to ask you about being a Trustee inthe UEP. Did the UEP Trustees hold yearly meetings?

A. We generally had a meeting, it could havebeen over a dinner meeting or at the attorney's office orat- - down around our con ference, our annual confereneein April. We had-- sometimes it was quick and sometimesit was quite long.

Q. You a re saying annual conferenee. Thosewould be conferences of the FLDS Church, in Aprilconference of the FLDS Church; is that eorrect?

A. They would be after when we began to berecognized as t hat at our conference.

Q You are saying you had conferences before itwas recogni zed as the FLDS Chureh?

A. Yes, we did.Q. Let me as k, when you participated in those

Board of Trustee mee tings of the UEP, what types ofmatters did you discuss?A. We mostly discussed the status of the currentlawsuit. In fact, that was our predominant discussion.We discussed where we were at in our cunent sui t. Wewere fighting one from '87.

Q. You're saying there was a lawsuit invo lvingthe UEP Trust going back to 1987?

A. Yes, there was.4 (Pages 10 t o 1 3)

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DEPOS ITION OF: M.J . aka ELISSA WALL v. WARREN J EFFSWinston K. Blackmore

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Page 14Q. So when you talk about a ctUTent lawsuit, you 1

weren't talking about this M.J . -- 2A. Oh, no 3Q. --litigation that we're here on today? 4A. No, we were talking about a ten-year suit 5

that we were involved in 6Q. Generally, tell us the nature of wbat that 7

lawsuit was about. 8A. It was about property. There was a concem 9

for some of the people that did not -- there was a split 1 0in 1982 in our -- among our people and that's where the 11Centennial Park people came from and ours Some of those 12people were-- felt very threatened in their homes. It 13was 44 different families that had homes on the UEP and 14they felt threatened in their homes. 15

And so by 1987, I believe it was '87, it then -- 1 6I was served in Canada as a Trustee to defend an action 17from a group of people who were try ing to be secure in 18their homes. 19

Q. And that lawsuit went on for many years? 20A Ten, and it occupied pretty much all of our 21

time and our thinking and ow money and our conversation. 22It dominated our conversation. 23

Q. As a Trustee of the UEP Tntsl, were you 24involved in deeisions with regards to arranged marriages 25

Page 15by the FLDS Church? 1

MR. MORTENSEN: Object to the form. Go 2ahead. 3

Q. (BY MR . HANSEN) He may state an objection 4for the Judge to decide later, but you can go ahead and 5answer. 6

MR. MORTENSEN: Sorry, I should have wamed 7you. 8

THE WITNESS: just need to know the rules 9here. 10

Q. {BY MR. HANSEN) Right. Right. 1 1A. So was I involved in-- yes, I was.Q The question would be was the UEP Trust

involved in decisions with regards to marriages -MR. MORTENSEN: Objection to the forrn.

1 21 31 4

Asked 15and answered. 1 6

Q (BY MR . HANSEN) --performed in the FLDS 1 7community. 18A. The Trust wasn't. I mean I was as an 1 9officer. 20

Q YousaytheTrustwas not? 21A No . 22Q. What do you mean? 23A. The Tn1st is a land holding trust . My office 2 4

as a bishop was involved-- I was involved in making 2 5

J i C. Dunford RPR, CSR

those deeisions on a bishop's level.Q So as a bishop, you were involved in

marriages; is that right?A. Yes, I was.

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Q As bishop, have you participated or perfonneda number of wedding ceremonies?

A. Yes, I have.Q. In addition to the ones you performed, have

you attended cere monies perfonned by others in the FLDScommunity?

A. Yes,Ihave.Q. In any of those ceremonies has there been any

reference to the UEP Trust that you ca n remember?A. Not that I can remember, no.Q. Do you as you look back over the years that

you were involved as a bishop and during the time thatyou were a UEP Trustee, do you reca J the UEP Trust everbeing invo lved in a marriage in the community?

MR. MORT ENSEN: Objee t to the form.THE WITNESS : No . Repeal that so that-- is

the Tntst itself involved in the marriage ?Q. BY MR . HANSEN) Yes.A No, the Trust wasn't.Q. Wh en you had Trustee meetings, would the

Board of Trustees discuss whether certain maniagesPage 17

sho uld be performed or not perfonned?A. No, they did not.Q. Would those have bee n diseuss ions that wo uld

be held by individuals i n their FLDS Churchresponsibilities?

IIMR . MORTENSEN: Object to the form. Ca lls

for a legal conclus ion.Q BY MR . HANSEN) I mean if there we re

d iscussions about who was to be married and who wasgetting mani ed.

A T hey were always discussed --MR MORTENSEN: Same objection.THE WITNESS: --privately.

Q (BY MR. HANSEN) Let me ask you about aco uple of document s that are titled Declaration ofWinston Blackmore. I think we are going to have thosemarked as exh ibits now. I ll show you a copy.

(Exhibit Nos. I and 2 weremarked for identification.)MR HANSEN: I have a copy for everyone.MR. MORTENSEN: Thanks.Q. BY MR . HANSEN) I show you what bas been

marked as Exhibit No. I and Exhibit No . 2. There's No . Iand No.2 . The se are copies of Exhibit No. 2.

MR. MO RT ENSEN: Thanks.5 Pages 14 to 17)

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DEPOSITION OF: M.J . aka ELISSA WALL v. WARREN JEFFSWinston K. Bl a ckmorePage 18

1 Q. (BY MR. HANSEN) Let me ask you, 12 Mr. Blackmore, I have handed you these two documents. 23 And for distinguishing purposes, the Exhibit I up at the 34 top identifies-- well, they both say Declaration of 45 Winston Kaye Blackmore ; is that eorreet? 56 A. That's conect. 67 Q. One is Winston Kaye Blackmore and the other 78 one is Winston Blackmore ; correct? 89 A. That's what I see on there. 9

10 Q. Maybe that's one way we ean distinguish them. 1011 Let me ask you, have you had a chance to 111 2 review-- have you seen these documents before? 1213 A. Yes, I have. 131 4 Q. And have you reviewed them recently? 1 415 A. Yes, lhave . 1516 Q. And your si gnature is contained on page of 1617 Exhibit No. I? 1 71 8 A. Yes. 181 9 Q. And it's also on the last page of Exhibit 192 0 No. 2; is that correct? 2021 A. That's correct. 2122 Q. Do you remember being involved with these 222 3 documents? 2324 A. Yes, I do. 2425 Q. Let me ask you about the first document. 25

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Page 19Exhibit 1 indicates that it was signed on September 5th, 12007. 2

Can you tell us about the circumstances of having 3your signature on that document? 4A. Yes, I ean. 5

Q. Please tell us about it. 6A. I got a call from Roger Hoole and - - 7Q. And who is Roger Hoole? 8A. I don't know who he was actually representing 9

before M.J. He never did tell me who M.J. was. But I 10had met with Roger before a time or two and was quite 11familiar with Roger. And he asked me if he could-- I 12think they were in the co untry anyway, Greg and -- Roger 13and his brother, Greg, and they wanted to drop by. They 1 4did. 15

Q. Can we stop for a second?A. Sure.

161 7

MR . HANSEN : Have you got yours rec ording? 1 8Can we go off the record for just a minute? 1 9(Short pause.) 2 0

MR . HANSEN : Let's go back on the record and 2 1I ll just explain that. 22

We are back on the reeord and I'd like to just 23explain that I jus t took a break from the record a minute 24ago because I noticed that my video recording appears 25


Page 20that something had happened. It was not working up tothis point. But counsel for M.J. is likewise videotapingthis.

So Counsel , do we have an agreement that we canMR . MORTENSEN: We'll share each other's

videos.MR . HANSEN: --share eaeh other's videos?

Okay. Very good. Sorry for that interruption.Q (BY MR. HANSEN) Let us continue. You were

just goi ng to explain to us about the circumstancessurrounding this declaration of Winston Kaye Blackmorewhich is in front of you as Exhibit No. 1.

Mr. Blackmore, could you please explain furtherwhat happened in that situation?

A Yes, Roger ca lled me and he asked if he andGreg could drop in and have a conversation. And when wedid , we met in my office at my home. And some of myfamily, he met-- we met with some of them.

They came a little bit late in the evening whenwe were gathering for our evening prayers and whatnot, sothey came back in the morning.

But in the meantime, Roger told me, he said, Mywork with this case is done. That's just what he said.

Q. Meaning his work, not Winston's work?Page 2 1

A His work, his work is pretty much done. Hehad done whatever he had done and he would like to set upa fund of some sort for people who were trying to leave.Because in our community, no one had any mechanism toleave. There's people who wanted to leave and had no wayto go.

So I myself, I made an agreement of some sortof mechanism that-- and he explained. His explanation 11was that it cou ld be a fund that was set up that wou ld behandled by the UEP, that a suceessful applieant could IImake an applieation to the Trustees of the UEP for somemeans to go. And they would be -- if they weresuceessful, they could get this grant or whatever it was 11that they could get.

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He had an affidavit prepared -- I mean asta tement prepared, which he read to me. And r old himtwo or three times some of the stuffdoes not sound like IIme. And so we went over it and the next morning heeame baek with a draft of it. And he was -- he was in ahurry to go. They were-- they bad missed their fl ight,and they truly were.

Q. The flight from Canada to--A The flight out of Spokane. They were right

down to the time to do it.6 (Pages 18 to 21 )

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DEPOSIT ION OF: M.J. , aka ELISS A WALL v. WARREN JEFFSWins t on K. Blackmore

Page 2 21 And so Roger asked me, Could you just sign the 12 back of this? And you can phone me over the phone, go 23 over this. 34 I said, I need to go over this with some of my5 family and a couple:: of the brethren. Because I wanted 56 to go over it with Brother Johnson who was then our 67 bishop in the south and some of my family members to look 78 at it to see , you know, what stuek ou t towards them . 89 I also explained very plainly to Roger that 9

10 under-- the definition of underaged marriages is -- is 1 011 not-- I mean there's under the age of what? Under the 111 2 age of majority or under the age of consent? 1 21 3 So -- and to m e, when I showed this th ing to my 1 31 4 family, their-- the whole context of it is mi slead ing in 1 41 5 a way that we're not --we have not defined under the age 1 51 6 of eonsent or under the age of majority. Aud that 1617 basically taints the whole statement. 1 71 8 And so -- also when I showed it to 8 ishop 181 9 Johnson, he basically pointed out to me that no one 1920 ever-- I mean the United Effort Plan Trust was a trust 2021 that we got a lot. Thats what we did. That the Trust 2122 did not build houses for people nor had any obligations. 2 22 3 We bad --we were assigned a lot and the responsibility 2 324 on building a hom e and managing that lot depended on the 22 5 individual who had the lot. 2 5

Page 231 And that was bas ically his input into there, plus 12 the fact that I managed the United Effort Plan property 23 in Canada. The president of the Tru st and the president 34 of the Church didn't manage it. I did .5 Q. As the bishop, you were managing it? 56 A As the bishop of the property. So to be-- 67 basieally to have any kind of couneetion made there would 78 be totally false. 89 Q. So at the time that you signed the last page 9

10 of this declaration, Roger Hoole bad expressed to you 1 011 that yo u would have-- you made it elear that you had to 1112 review the document? 1 213 A. Yes,Idid. 1314 Q. And think about it, that it wasn't to be used 1415 until it was detennined if there were changes that needed 1516 to be made? 1 617 A Roger told -- 1718 MR. MORTENSEN: Objeetion. Leading. 1819 THE WITNESS: Roger told me that i f did not 192 0 like that , he wouldn't even use it. And I called him 2021 right away and I didn't get through to him . I left a 212 2 message twice. 2 22 3 Q. (BY MR . HANSEN) Why did you call him? 2 32 4 A. I ealled him to tell him that this was not 2 425 accurate. And I didn't hear anything back from him, and 2 5

i l l C. Dunford RPR, CSR

Page 24so 1 thot1ght that he hadn't filed it.

Q. So when you reviewed this document the nextday and considered it, it was your opinion that this wasnot accurate, it was not a coneet statement of yourknowledge or experienee; is that right?

MR. MORTENSEN: Objection. Leading.THE WITNESS: That's right. And l told him

that on a voice message and I told him later in person.Q. (BY MR . HANSEN) When did you find out that

Roger had used this declaration?MR. MORTENSEN : Object to the fonn .

Q. (BY MRHANSEN) At the time that yo u signedit-- you understood that Roger wasn't going to doanything with it until you and he had confirmed that itwas appropriate to use; is that right?

A Yes, and when we confirmed --MR . MORTENSEN: Objeet to the form.THE WITNESS : -- it was appropriate to use,when Roger confirmed it was app ropriate to use, then I

was going to take and have it nota1ized before a notaryand theu send him the eopy of the notarized doeument.

And when I found out-- or months went by, maybesix, maybe six months went by and I never heard anotherthing from him until --

Q. (BY MR HANSEN) Who advised you of that?Page 25

A Mr. Wisan phoned me and he was not happy. Hesaid -- he asked me, What on earth did you do? And Iwas surprised t know -- he sent me a copy of his.Q. Why were you surprised?

A . I was surprised because I wasn't aware thatit was used.Q. Did that co ncern you that the affidavit hadbeen used when you had not approved it?

MR . MORTENSEN: Object t the form. It's adeclaration.Q. (BY MR. HANSEN) Declaration.

A What concerned me was that the purpose thatit was used was for something totally differeut than whatRoger had approached me about. He approached me abouusing this declaration to set up a fund to help peoplethat wanted to leav e this community go, not to-- not todo any other reason.

Q. And the second deelaration, the declarationof Winston Blackmore, wbich has been marked as ExhibitNo. 2, that's a document you are familiar with as well?

A. Yes, I am.Q. And do you recall the eireumstances aroundthe creation of that declaration?

A. Yes, I do. It was on -- it was afterMrW isan called me and infom1ed me of the filing of this

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DEPOSITI ON OF: M.J. , a ka ELISSA WALL v. WARREN J EFFSWinston K. BlackmorePage 26

1 first one that --I told him that is not the intent. 12 That was not what our-- my understanding was. That was 23 not what Roger agreed with me to do. 34 He bad agreed that if there was anything in here5 that I did not like, that that would be omitted from 56 there. I did not take it to a notary and have it swom 67 to, whieh was what the next step of our program was going 78 to be. And l had no opportunity to do that. And it 89 shocked me to discover that it was in something totally 9

1 0 different than our conversation. 1 011 Q. So it's fair to say you spoke with Mr. Wisan 1112 about that first declaration, you continued to feel that 1 21 3 it was not a fair and accurate statement of your 1314 testimony; is that correct? 1415 MR . MORTENSEN : Object to the form. 151 6 THE WITNESS: That s correct. 161 7 Q. (BY MR. HANSEN) So was the second 1718 declaration, the de claration of Winston Blackmore 1819 prepared to try to correct the record with regards to 1 92 0 your first declaration ? 2 021 A. Yes, it was. 212 2 Q And you have had a chance to review this 2 22 3 declaration; is that correct? 2 324 A. Ycs,Ihavc. 242 5 Q Is this declaration a true and accurate 2 5

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Page 27statement of your knowledge and experience regarding the 1issues contained therein? 2

A . It is regarding those issue s. 3Q. Okay. Do you mind reading the second 4

paragraph of tha t Exhibit N o. 2, which is your 5declaration? It's dated July 18, 2008. Could you read 6for us Exhibit 2? 7

A. Sentence two? 8Q. Excuse me, sentence No.2. 9A. In Exhibit 2? 10Q. Right. 11A. ln February of 1986, I became a Tn1stee of 12

the UEP Tmst (the 'Trust' or the UEP ), and served in 13that capacity until mid-2002. I also served from August 1 4of I 984 until May of 2002, as the FLDS Bishop of Canada. 15Even today, I continue to perfonn the duties of a bishop 16for hundreds of fundamentalist Mormons (I am no longer 17affiliated with the FLDS Church, having been 18disfellowshipped by Warren Jeffs after the death of his 19father, Rulon Jeffs). 2 0Q. And that's a statement contained in sentence 21No.2 that you ha ve just read; is that an accurate 22statement? 2 3

A. Ye s, it is . 2 4Q. And still true today? 25


Page 28A Still true.Q Some of these other things you have talked

about. I ll move fotward.Do you mind reading paragraph No. 10? Yeah, itis paragraph marked No. l 0 of that declaration.A. The same one?Q. Yes.A. I emphatically declare that any underage

marriages that occurred amongst FLDS people were not onaccount of any doctrine of the FLDS Church or MannonFundamentalism. Unde rage marriage is not and never hasbeen fundamental to our faith, nor has the doctJine orpractice of underage matTiage ever been taught to ourpeople. By stating in my earlier declaration thatunderage marriage is a 'practice' among the FLDS people,I did not mean to imply tha t underage matTiage wascommon, regular, everyday, or ordinary amongst the F L ~people. Historically, it did happen, but was a rareanomaly.

Q. What was written in that sentence No. 10, isthat a true statement?

A. It is a true s tatement.Q. Let me ask-- let me ask about the firSt

sentence there where it says, I emphatically declarethat any underaged marriages that occuned amongst the

Page 29FLDS people were not on account of any doctrine of LlleFLDS Church or Mormon Fundamentalism.

Let me ask you, are you aware of any doctrine -that underage marriage as being a doctrine of the FLDSChurch?

MR. MORTENSEN : Object to the fonn .THE WITNESS: Jam not aware of any . There's

no doctrine.Q. (BY MR. HANSEN) And you have been invo lvedin this religi on and Mannon Fundamen talism for your wholelife; correct?

A Yes. My mom was 16 when she married my dadwho was 27 in the Cardston Temple.

Q And as far as it being a doctrine of theChmch --

A. No .Q. - -underage marriage, it's never been adoctrine?A. No , il has not been a doctrine.

Q. I guess you state that again in paragraphNo . 11 . Would you mind reading paragraph No. l I?

A l completely disavow any statement in mySeptember 5, 2007 declaration which could be read tosupport the proposition that underage marriage has everbeen a doctrine or practice of the FLDS Church, or within

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DEPOSITION OF: M.J. , aka ELISSA WALL v. WARREN JEFFSW nston K. BlackmorePa ge 30

1 the scope of a UEP Trustee's duties. 12 Q Was that a true statement? 23 A. Yes, it is. 34 Q Okay. And underage marriages were never 45 something within the duties of a UEP Trustee, were they? 56 MR. MORTENSEN: Object to form. 67 Q. (BY MR. HANSEN) I guess that s what you say 78 in paragraph l I. 89 MR. MORTENSEN: Same objection. 910 Q. (BY MR . HANSEN) Am I reading that right? 1011 A. Underage -- not a Trustee. 1112 Q. You also make mention --I'll have you tum 12

13 to paragraph 17 of your affidavit. Would you mind 1314 reading that paragraph? 1415 A. Prior to the second session of the FLDS 1516 general conference of April 1998, our leader and 161 7 keyholder, President Rulon Jeffs, announced to a small 1718 group of priesthood brethren, that included me, Sam 1819 Barlow, LeRoy Jeffs, and Wendell Nielsen, that the State 192 0 of Utah had enacted a new law regarding underage 2 021 marriage, and that the Church fully intended to comply 212 2 with that law. President Jeffs publicly declared the 2 223 Church's intent to comply with that law to the 2 32 4 congregation in a later session of that same conference, 2 425 which I attended. 2 5

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Page 31Q. Paragraph 17 of your deelaration, is that a 1true and accurate statement? 2A Yes, it is. 3Q. Do you have recollection of being in this 4meeting that you talk about here? 5A Yes,Iwas. 6Q. Tell us what you remember. 7A The circumstances that we spoke of prior to 8that had to do with the State of Utah raising the age of 9

consent, the age which parents could consent to ha ve 10their children be manied. 1 1And I think it was raised -- if I remember right, 12it was raised from the age of 14 to the age of 16. And 3his declaration was that, We are not going to 14pa11icipate in any maniages that are not according to 15the law of consent, parental consent. 1 6Q. And that was in February of 1998 when-- 17A. No . 1 8Q. -- when that meeting -- excuse me, it was 1 9April conference? 20A. Apiilofl998. 21Q Where would that mee ting-- was that down in 22

the-- 23A. That was his residence in Short Creek in 2 4Colorado City -- or Hildale. 2 5

= = = = = = = =


Page 32MR . MORTENSEN: Whose residence?THE WITNESS: In Rulon Jeffs' residence.Q (BY MR. HANSEN) And at that time what was

Rulon Jeffs' position in the Church?A. He was the President of the Church.Q And he made that statement to a small groupof you who were priesthood holders in that meeting youare referencing in paragraph-- at the beginning ofparagraph 17; is that right?

A Yes.Q You mentioned -- in the last sentence yousay, President Jeffs publicly declared the Church's

intent to comply with that law to the congregation in alater session of that same conference, which I attended.A. I attended all of the sessions.Q. Okay. So you are saying there were twodifferent occasions where you heard Rulon Jeffs-

A. Yes, I did.Q. --make that declaration that the FLDS Churchwould be complying with the laws of the State of Utahwith regards to marriages complying with the laws of theState of Utah; is that correct?MR. MORTENSEN: Object to the form.Misstates his testimony.

Q. (BY MR . HANSEN) As far as the age ofPage 33

consent?A. The age of consent.Q. l11at same year, Rulon Jeffs had some hea lthissues; is that correct, in '98?A. Yes, he did. He had a stroke in August of

'98. Q. And you are up in Canada. The Church isheadquartered -- the FLDS Church was headquartered downin Hildale?

A. Yes.Q From your interaction , did you ob serve anychanges in the leadership of the FLDS Church as a result

of Rulon Jeffs' stroke and his illnesses?A. Well, from the time that he had his stro keand was unable to do anything really, theresponsibility -- the bishops pretty mu ch had to do their

jobs the best that they could without any contact withhim. And when we were able to contact with him, hedefinitely was not in any sort of position hea lth-wise todiscuss things with him.His son, Warrell, who was ca retaker of his fatherthrough that time began to help his father rememberdifferent things. And he announced several times, I'mmy father's memory . Ididn't agree with that, but

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Page 34that's what happened. 1

Q Were yo u involved in any way in spring of 22001 with the maniage of Elissa Wall and Allen Steed? 3

A. No, I wasn't. 4Q. Did Warren Jeffs or Rulon Jeffs ever talk to 5you about that maniage taking place? 6

A. No. 7Q. Was the marriage of Elissa Wall and Allen 8

Steed, before it happened, was it ever addressed in any 9meeting of the UEP Trustees? 10

A. No, it wasn't. 11Q After the marriage took plaee -- the wedd ing 12

took place and Allen Steed and Elissa Wall were still in 13the arranged marriage, did you ever have any diseussion 14with Wanen Jeffs or Rulon Jeffs or anyone else in the 15FLDS Church about Elissa Wall and her marriage to Allen 16Steed? 1 7

A No, I didn't. I didn't know anything about 18

Page 36Church was coucerned.

MR . HANSEN: ] think that's all the questionsI have. Thank you for your time, Mr. Bla ckmore.

THE WITNESS: Okay.EXAMINATION(BY MR MORTENSEN)

Q. Mr. Blackmore, I ha ve a few questions I'dlike to ask.

Just for the record, I'm Alan Mortensen withLance Milne. We represent Elissa Wall i n this matter.

You have referred to the UEP Trust as a landholding trust only; is that eorrect?

A. TI1at s all I ever knew it to be.Q. Okay. Let me hand you a copy that of the

Trust.MR . HANSEN: Do you want it marked?MR . MORTENSEN: Yeah, let's mark it as

Exhibit 3.19 it. 1 9 (Exhibit No .3 was marked for identification.)20 Q. Were you aware of Elissa WaH's complaints or 20 MR. HANSEN: Do you have a copy for me?2 1 fnts trations or disagreement with the marriage? 21 MR. MORTENS EN: I do. Oh, is that- -22 A. At what time? 22 Q. (BY MR. MORTENSEN) M r. Blackmore, have you2 3 Q. At the time that it was going on. 2 3 seen- -24 A. No. 2 4 MR. HANSEN : We can give him the marked copy25 Q. As a Trust ee of the UEP Trust, did you ever 2 5 and I'll take that one.

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Page 35take any action to force Elissa Wall to be in an illegal 1matTiage with Allen Steed? 2

A. No, l didn' t. 3Q. Do you have knowledge with regards to the 4

act ions of other Trustees of the UEP Trust acting in 5their capacity as Trustees o f the UEP Trust to compel 6this marriage of Elissa Wa ll and Allen Steed? 7

MR. MORTENSEN: Object to the fonn . 8THE WITNESS: No , J don't. 9

Q (BY MR. HANSEN) Was there a difference in 10the administration of the UEP Trust and the 11administration of the FLDS Church matters? 1 2

A. Oh . yes. 13Q. Why do you say-- can you explain to me when 14

you say, Oh, yes"? 15A. Well, the UEP Trust is a land holding trust. 16

And the matters that we took care of for them were to 1 7preserve its integrity, preserve the case, the court case 18that we were fighting, and to deal with lots and taxes. 1 9

And, you know, the president in most cases, he 20didn't even want to hear about it. He wanted --he told 2 1me two or three times in my whole tenure that I tried to 22ta lk to him about UEP in Canada, Just go do, do what you 23need to do and don't bother me about that. And , you 2 4know, he certainly didn't act that way as far as the 2 5

J i C . Dunford RPR, CSR

Page 37Q. (BY MR. MORTENSEN) Mr. Blackmore, have you

seen this document before?

not?A. Yes, I have.Q. And your signature is on this document, is itA. Yes, it is.Q. On page -A. Fi ve.Q. -- 5. And do you recall signing this?A. Yes, I do.Q. You have testified tha t you we re a b ishop-

you have been a bishop for a lmost 30 years; COITect?A. Yes, correct, 30.Q A bishop is a priesthood office within the

priesthood fundamentalists in the FLDS Church; co nect?A. Yes, it is.Q. As part of that priesthood office, you

administered the UEP Trust in Canada?A. Yes, J did.Q. And if understand your testimony correctly, II

Rulon Jeffs, the prophet -- he was also the prophet, was IIbe not?

A. Yes, he was.Q. And as prophet, he would be the person that

could receive revelation on who marries who; correct?10 (Pages 3 4 to 37)

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1 A. Con ect. 12 Q. And he's the only person that was authorized 23 to instnct peop le on who to marry; is that conec t? 34 A. That's not correc t. 45 Q. Who else within the FLDS pries thood structure 56 could in struct people to marry? 67 MR HANSEN: I'll object that it is vague as 78 to time. 89 Q. (BY MR. MORTENSEN) Let's go baek to 1998 to 9

10 the time period that Rulon Jeffs died. Who was 1011 authorized to instruct people to get maTied? 1112 A. I was . 1213 Q. As a bishop? 1314 A. As a bishop. 1415 Q. Soyoueould-- 1 516 A. I could consult with the parents and the 161 7 people. 1 718 Q Okay. So you were authorized as a bishop, 1819 which is a priesthood office -- 1920 A That's right. 2021 Q. to have people enter into polygamist 212 2 maniages? 2 223 A. Yes, I was. 232 4 Q. As a bishop, during that pre-2001 time 2 42 5 period, did you ever -- well, you instructed people that 2 5

Page 391 were under the age of 18 to marry; correct? 12 A I never instruct-- I visited with people who 23 were under the age of 18 and I also visited wi th them 34 with their parents. 45 Q. So you instructed people under the age of 8 56 to get married? 67 A. Well, 1 gave them permission if that s what 78 they chose to do, what it came to. 89 Q. And you would defer to their parents to give 9

10 parental consent? 1 0A. Yes. 11

12 Q. And you had the right as the bishop if that 1213 family was living on FLDS or UEP Trust property to eviet 1 314 them if they didn't follow your instruetions, did you 1 415 not? 1 516 MR . HANSEN: Objection. Vague. Overly 1617 broad. 1718 THE WITNESS: I never evicted anyone, so .. 1819 Q. (BY MR . MORTENSEN) That wasn't my question. 1 920 My question was you had the authority to have people move 202 1 off of the UEP Trust property if-- 2122 MR . HANSEN: Objection. Laek of foundation. 2223 Calls for specu lation. Misstates the facts. 2324 Q. (BY MR. MORTENSEN) --if you felt that they 2425 were not following your instruetions? 25

- - --

ill C . Dunford RPR, CSR

Page 40A You know, that never did ev er come up for me

that I can reca ll.Q. You have never kicked anyone off of UEP

property up in Canada?A. No, I haven't.Q. Has-- did you ever-- were you ever

instructed by Rulon Jeffs to have people leave UEPproperty up in Canada?

A. Not to my recollection.Q. All right. Let's tum to Exhibit 1 --or

Exhibit 3. When you signed this docu ment, you agreed 'with it, did you not?

A Actually we didn't even read the documentuntil it was read to us the next day. We met for asigning session and that's what we met for.Q. So you signed this without reading it?

A. Yes, I did.Q. But you have since read it; correct?A. Oh, yes, I have read it.Q. And you don't disagree with anything in it,

do you?A The only thing that I disagree with is I know

that Rulon Jeffs would have never signed it.Q So you don't think Rulon Jeffs' signature is

his?Page 4 1

A. lt is his . I saw him sign it. But he-- hehad a stroke. Warren introduced him as his father beingreduced to the capacity of a child in our meeting. Wesigned, we did our signature, and it went.Q. You at no time went to Warren Jeffs and RulonJeffs and said, "Take my name off that document ?

A. No , 1 didn't.Q. You were an adult and had tha t capacity to dosuch if you disagreed w ith it once you read it the nextday; correct?

A . Yeah .Q. But you never did that?A I did not, no.Q. Okay. In the second paragraph it says, "The

United Effort Plan Trust is a spiritual step towardliving the Holy United Order."

The Holy United Order is a doctrine of the FLDSChurch, is it not?A. It's a doctrine of the LD S Church and in theDoctrine and Covenants.

Q That wa sn't my question, sir.A. Yes, as a mainstream-- I mean as a

fundamental M01mon, yes, it is a part of their faith.Q. And at the time it was part of the FLDS

do ctrine; correct?11 (P a ges 38 to 41)

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25

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Page 4A. CotTect. 1Q It says, ''It ex ists-- on the next sentence 2

lt exists to preserve and advance the re ligious 3doctrines and goals of the fundamen talist Church of Jesus 4Chris t of Latter-Day Saints, previously known as 'The 5Priesthood Work,' or 'The Work' (the 'Church'). 6

You agree with that sen tence, don't you? 7A. Yes , I do 8Q. So the United Effort Plan exists to preserve 9

and advance the religious doctrines and goals of the 1 0Fundamentalist Church of Jesus Christ of Latter-day 11Saints? 12

MR. HANSEN: I'll object that the document 13speaks for itself. 14

MR. MORTENSEN: Mr. Blackmore can speak. 15Q (BY MR . MORTENSEN) So I'd like you to speak. 16A. Just get it over to where we are again. 17Q The second paragraph, second sentence. 18MR. HANSEN: On page 1. 19

THE WITNESS: I'm on a different one. 20Q. (BY MR. MORTENSEN) Where it says the UEP 21

Trust exists to preserve and advance the religious 2 2doctrines and goals of he Fundamentalist Church of Jesus 23Christ of Latter-Day Saints, previously known as The 2Priesthood Work, or ''The Work (the Chureh ). 2 5

Page 4You agree with that, don't you?

MR. HANSEN: You agree that that's what thedocument says?

123

Q. (BY MR. MORTENSEN) No, you agree with that1

45tatement.

MR. HANSEN: Then I'm going to object. Vague 6and ambiguous as to time. You are saying back in 1998?

Q. (BY MR. MORTENSEN) At the time you signedit, you agreed with that; eorrect?

A We didn't even go through it, but I signedthe document.

Q. And you agree with that statement, don't you?A I don't entirely agree with it.Q. What part don't you agree with?A. The FLDS Church didn't even exist when the

7B9

1 01 1121315

Un ited Effort Plan Trust was organized. 16Q. Okay. So if it read it exists to preserve 1 7

and advance the religious doctrines and goals known as 1 8the Priesthood Work, you would agree with that? 1 9MR. HANSEN: Objection. I think that 20

mischaracterizes hi s testimony, misstates hi s testimony. 2 1THE WlTNESS : I wouldn't entirely agree with 22

that, no. 23Q. (BY MR. MORTENSEN) What part don't yo u agree 2

that on? 25

i C. Dunford RPR, CSR

Page 44A I do n't agree -- with being a Trustee

appointed under the origina l declaration of the Trust,that's wha t I was appointed under. The origina ldeclaration of trust, th ere was no reference at all tothe Church.

I'm a person who believes that we should havenever changed the Tmst. And we never would have hadPresident Jeffs not been incapacitated.

Q. Did yo u ever tell that-- make that known toPresident Jeffs?

A. We couldn't--MR. HANSEN: Which President Jeffs?MR. MORTENSEN: The one he refetTed to.THE WITNESS : President Jeffs, in 1998 when

we signed this thing, was not in any capacity to makethat known. But I know for a fact that Tmman Barlowwould not have signed it Craig Jessop would not havesigned it. I would not have signed it. LeRoy Jeffswould not have signed it had we, you know, had hisfather, had Rulon Jeffs, being of his capacity, he wouldnot have signed it He would not have changed thedeclaration as it stands today. And I made it no secret IIamong a lot of people that I did not like the fact that IIwe had to sign this thing.Q. (BY MR. MORTENSEN) But you signed it?

Page 45A But I signed it, yes.Q And you made no -- you didn't stand up in

general conference or priesthood ses sion of generalconference and object to it, did you?

A No, I had no --MR. HANSEN: I'm going to object.

Argumentative. Asked and answered.MR. MORTENSEN: I haven't asked him about

general confere nce.THE WITNESS : No one had that opportunity.

Q (BY MR. MORTENSEN) They don't give you theoppornmity, do they?

A No.Q. Then it says, The United Effort Plan is

under the direction of the President of he Church, whoholds the keys of Priesthood authority .continued fromJoseph Smith to Brigham Young, John Taylor, John Woolley,Lorin C. Woolley, John Barlow, Leroy Johnson, and RulonJeffs.

You agree with that, don't you?A. I think they missed some people, but that's

m y opinion.Q . Okay. So the United Effort Plan was under

the Pres ident of the Chu rch who holds the keys of thePriesthood authority?

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Page 46MR. HANSEN: Asked and answered.

Q. (BY MR. MORTENSEN) Do you agree with that?A. l agree.Q. All1ight. And then it goes on to state thatthe laws -- The doc trines and laws of the Priesthood and

the Church are found in the Book of Mormon, the Doctrineand Covenants, the Pearl of Great Price, the Holy Bible,the sennons of the holders of the keys of Priesthoodauthority, and present and future revelations receivedthrough the ho lder of those keys; and are the guidingtenets by which the Trustees of the United Effort PlanTrust shall act.

You agreed with that when you signed it, did younot?

MR. HANSEN: Objection. Asked and answered.It misstates his prior testimony.

Q. (BY MR. MORTENSEN) Go ahead and answer.A. 1don't agree with it entirely.Q. So you signed it without agreeing to it?A. I think five people signed it without

agreeing to it.Q. I want to know if you signed it without

agreeing to it?A. I didn't know what was in it to agree to it

when I signed it and then I certainly didn't agree withPage

it after.Q Who presented it to you to s ign?A It was just a signing session. We were all

present.Q Okay.A We went to the home of President Jeffs.Q Rulon Jeffs ?A. Rulon Jeffs. President Jeffs, there's on ly

one to me .

47

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Q. Okay. 10A. So that's Rulon Jeffs. And we went to there, 1 1we signed and notarized, and went from there. 1 2

Q. On the last paragraph of the first page it 13says, Rulon T. Jeffs ho ld the keys of Priesthood 14authority and so serves as the President of the Church. 15

You agree with that statement, don't you? 16A. Yes, I do . 17Q. Then continuing on to the next page, 18continuing that paragraph , it s tates, This Amended -- 19

second to the last paragraph-- or sentence in the 20carry-over paragraph, it says, This Amended and Restated 21Declaration of Trust has also been approved by the 2 2Priesthood and sustained by the Church membership. 2 3

Do you recall that at that conference that this 2 4trust was approved by-- 2 5

J i l l C. Dunford RPR, CSR

Page 48A Sorry, could you show me where that was

again?Q The second page, first full sen tence where it

says, Thi s Amended and Restated Declaration of rost hasalso been approved by the Priesthood and sustained by theChurch membership.

A. That was totally inaccurate when we signedit. No one bad ev er even heard of it.

Q. All I want to know is it was the Amended andRestated Declarationof Trust, that it was approved andvoted on by the Priesthood at that conference?

MR. HANSEN: Objection. Asked and answered.THE WITNESS: Pardon me ?MR. HANSEN: You have given your answer. I m

just objecting to him reasking the same question that youhave a nswered.

THE WITNESS : The time-- I'm going torestate my answer. The time we signed this, it was notpresented to the people nor was it accepted by thepeople.

Q. (BY MR. MORTENSEN) Would you look alExh ibit 2. Exhibit 2 is what you claim to be theaccurate dcelaration that you provided in this matter;correct?

A Correct. I thought you are referring to mePage 49

some part of it.Q Look at paragraph 16 In the second sentence

you state, and you have testified under oath here today IIthat it was true and accurate, While it is true that the II199 8 Declaration of Trust was presented, read, andapproved at a meeting attended, the meeting in questionwas an FLDS priesthood meeting. Correct?

A. Correct.Q So the Declaration ofTrust was presented to

the FLDS priesthood holders at the pri es th ood meeting?A. Yes, it was.Q. And you had an opportllnity to vote on it?A. Ye s , we did .Q. And you as a priesthood member had an

opportllnity to vote on it?A. Yes, l did.Q. And you didn't vote no, did you?A I raised my hand with everybody else.Q. Even though you disagreed with it?A Yes.Q. How many bishops were there at the time in

the FLDS Church in 1998 when this was presented? [[A. There was myself and Bishop Fred Jes sop and

LeRoy Jeffs was an acting bishop for Salt Lake and fourof us all were present.

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DEPOSITION OF:W nston K. Bl ackmorePage 50

1 Q. The re was four bishops, and you were one of2 the four?3 A. Yes, I was.4 Q. And you didn't vote against this Declaration5 of Trust?6 A. No.7 Q. Back on Exhibit 3, page 2, the last8 paragraph, the Trust document states, The United Effort9 Plan is the effort and striving on the part of Church

10 members toward the Holy United Order. This central11 principle of the Church requires the gathering together12 of faithful Church members on consecrated and sacred13 lands to es tablish as one pure people the Kingdom of God1 4 on Earth under the guidance of Priesthood leadershi p.1 5 Do you see where that --1 6 A. Yes .17 Q. And you agree with that , don't you?18 A. I don't believe that that's what the United19 Order is personally.20 Q. So you di sagree with that statement?21 A. I di sagree with that statement.2 2 Q. On page 3 second full paragraph on Exhibit23 3, it states, The privilege to participate in the United2 4 Effort Plan and live upon the lands and in the buildings25 of the United Effort Plan Trust is granted, and may be

Page 511 revoked, by the Board of Trustees.2 Do you see that?3 A. Yes, I see it.4 Q. And the Board of Trustees were all Priesthood5 authorities, were they not?6 MR. HANS EN : Objeetion. Overly broad.7 Vague.8 Q. (BY MR . MORTENSEN) I'll go through it then.9 One of the Trustees was Rulon Jeffs ; correct?

10 A. Yes.11 Q. And he was the Prophet?12 A. Right.13 Q. And the President of the Church?14 A. Right.1 5 Q. And both of those are Priesthood -- are16 Priesthood positions; correct?17 A. Correet.18 Q. All right. Wasn't it-- I believe you19 testified in your dee laration that the President of the20 Church was historically also the Trustee of the Trust, of21 the UEP Trust?22 A. Yes.23 Q. So those two positions always ran2 4 simu ltaneotJS with each o ther?2 5 A. As far as I know, they did . - --

J i C. Dunford RPR, CS R

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Page 52Q Again, on the second paragraph, Those who

seek that privilege commit themselves and thei r familiesto live their lives according to the principles of theUnited Ef fort Plan and the Chu rch, and they and the irfamilies consent to be governed by the Priesthoodleadership and the Board of Trustees.

Do you agree with that statement?A. On page 2 or 3?Q. Page 3, second paragraph, full paragraph.

(Witness reviewed exhibit. )MR. HANSEN: Reading in the middle of the

paragraph.THE WITNESS: Those who seek -

(Witness reviewed exhibit.)THE WITNESS: That's not always the case,

because in our 1987 lawsuit, which we ultimately lostptior to this, 44 fami lies were given the privi lege tostay on their -- in their homes that were not a part ofthis Pdesthood group on United Effort Plan Trustproperty.

Q (BY MR . MORTENSEN ) That wasn't my question.My question was you agre e with this statement when yousigned it?

A I don't agree with it, no, I don't agree withit now.

Page 53Q. Okay. Then on the third paragraph full

paragraph on page 3 of Exhibit 3, it states in the secondsentence, Use of Trust proper ty must be within rules andstandards set by the Board ofTmstecs.

Wh at rules and standards were there?A. In our country -- and rea lly, I can on ly

speak for th at -- we had to eomply with the localgovernment, local government zoning and stand ards forwater and sewer and taxes, land taxes.Q. And were those the only ru les and standardsthat you set as the Board of Trustees for the people inCanada?

A. They were the only ones we ever followed thatI know of.

Q. Are they written down?A. No .Q Were they -- so they were never prov ided to

people that were on the Trust property?A. Not to my recollection. I can't recall.Q. It says, The Board of Trustees may require

indi vidu als and their families to relocate to differentloc ations on the United Effort Plan Trust p roperty or toshare a location with others.

Is that your un derstandi ng as what the Board ofTn1stees could do?

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Page 5 4MR . HANSEN: I ll objec t. Vague, ambiguous, 1

unclear. 2THE WITNESS : I'm trying to see whether or 3

not that was anything that ever applied to me o r app lied 4to us there. Btlt from time to time, I did have-- if 5there was -- if someone died and they were in a great big 6house, we swapped houses to relocate people to the best 7of their comfort and abi lity. BQ. (BY MR. MORTENSEN) And you would do that as 9the bishop? 1 0

A. I wou ld do that as the bishop and consulting 11with some of the o ther elders there. 12

Q And being an elde r is also a priesthood 1 3pos ition; correct? 1 4

A. Yes, itis. 1 5MR. HANSEN: Alan, when it s a co mfor table 16

time-- 1 7MR.MORTENSEN: Yeah,whydon'twetakea 1Bbreak. 19MR. HANSEN: --I'd like to take a 2 0

five-minute break. 21Let s go off the record and we ll take a five- or 2 2

ten-minute break. 2 3(Short recess.) 24

MR. HANSEN: For the record, it s about 2 5Page 55

1 10:40 a.m. on Feb1uary 28th. 12 MR. MORTENSEN: Ready to go back on? 23 Q. (BY MR. MORTENSEN) Mr. Blackmore, we took a 34 break. Did you meet with anybody during the break? 45 A. No. 56 Q. You didn t meet -- first of all, let me ask 67 you, is Mr. Hansen your attomey for the deposition here 7B today? B9 A. Yes, he is, I guess . I mean he called me to 9

10 the deposition. 1 011 MR. HANSEN : I mean I asked him to come and 1112 appear in this deposition . There s no formal 1213 rep resentation. 1314 THE W ITNESS: No. 1415 MR . HANSEN: Mr. Blackmore has come down as a 151 6 ci tizen of Canada that was asked to c ome and give 1617 test imony. 171B THE WITNESS: Yeah. 1819 Q. (BY MR. MORTENSEN) Let me just go througb a 1 920 couple of housekeeping items and make sure-- clear up a 2021 couple of questions I have from direct examination. 2122 You testified that you were baptized into the LOS 2223 Church; correct? 2324 A. Yes. 2 425 Q. But you were ex-communicated; correct? 2 5

J ll C. Dunford RPR , CSR

Page 56A . I ha ve ne ve r be en ex-communicated from the

Chu rch .Q Wa s your fa ther?A . My fa ther was, I think.Q So as far as you know , yo u re s till a member

on the records of the LOS Church?A. No, I do n't think I was on the records. But

that's what I was baptized and confirmed a member of isthe LOS Church.Q. You don't know i fthe LDS Church has arecord, a membership record, for you?

A . I do n't know what they do .Q During the time period that Presid en t Ru lon

Jeffs was the president of the UEP T rus t, you testifiedthat you had annual meetings?

A. Pretty much. We got together at conference.Q. Were there notes taken?A. I didn't take any, so I don't know.Q Were you ever provid ed notes?A. No.Q Were you ever provided minutes?A. No, I wasn't.Q As part of your meetings, were you ever asked

to approve minutes or approve these meetings?A. I don't -- I can' t recall.Page 57

Q If you were prov ided minutes, wou ld you havekept copies of those minutes?

MR . HANSEN: Objection. Calls forspeculation. Lack of foundat ion.

so --Q. (BY MR . MORTENSEN) You ean answer.A. You know, I can't think of any tha t I haveQ. My ques tion is --

MR . HANSEN: That s my objection. If hedoesn't have any --

MR . MO RTENSEN: John, you can lodge yourobjection, but I don't want you giving speakingobjections and --

MR . HANSEN: I'm just nying to clarify.MR. MORTENSEN: coaching \he witness.MR . HANSEN: If you don t want to hear it

Ill h old my tongue.MR . MORTENSEN : Please.Q. (BY MR . MORTENSEN) If th ere had been minutes

provided to yo11, is that something that you think andbelieve you wo u ld have kept?

A. If had any meet ing-- any minutes, I wou ldhave sunendered them in 2002.

Q. Do you recall providing any in this case?A. In?

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Page 58Q. Do you reca ll providing any to the law firm 1

of Callister Nebeker McCullough? 2A. Any minutes? 3Q. Any minutes. 4A. I can t remember. 5Q. While Pre sident Rulon Jeffs was the President 6

of the UEP Trust, did you ever lodge any objection to 7anything that he was doing as the President? 8

MR. HANSEN: Objection. Overly broad. 9Vague. 1 0

THE WITNESS: To him, personally?Q. (BY MR . MORTENSEN ) Yes. 1 2A. Not to him, personally. 13Q. Did you lodge objections to other people? 14A. I objected to Warren Jeffs. 15Q. And who did you lodge that objection with? 16A. Straight to Warren Jeffs. 1 7Q You told Warren Jeffs that you didn t-- you 18didn t approve of what he was doing as tbe UEP Trust 19

Trustee? 20A. I told him I didn t approve of what he was 21

doing as representing a memory ofhis father. 22Q. Both-- and he was representing tbe memory of 23

his father both as the UEP President and as the President 24of the Church; eorreet? 25

Page 59MR. HANSEN: Objection. Laek offoundation. 1

Calls for speculation. Vague and ambiguous. 2THE WITNESS: I don t think that he ever 3

objected to anything that I was doing in Canada, so my 4objection to Warren was what he was doing with his 5father. I ean t reeall anything other than that. 6

Q (BY MR. MORTENSEN) His father at the time 7was the UEP President, the President of the FLDS Chureh, 8and the prophet? 9

A. Yes. 10Q. And you told Mr. Jeffs that you didn t agree 11

with what was going on with him being the mouthpiece of 12his father; eorrect? 13

A. I told Warren that, yes, correct. 14Q But you never to ld Rulon that? 15A. You couldn t get to Rulon unless you went 16

through Wanen. 1 7Q. And how did Warren respond to that? 18A. He didn t like it. 19Q. And when did you tell him that? 2 0A. I told him that several times. We had 21

several different arguments and I told him that. 2 2Q. Did you ever take any-- did you ever talk to 2 3

any of the other Trustees about your displeasure with 2 4Wa1Ten Jeffs? 2 5


A. A time or two I did.Q. Who did you talk to?A. Truman Barlow.

Page 60

Q. Did you ever take any legal action to try toremove Mr. -- to remove Warren Jeffs as the Trustee ofthe UEP Trust?

A. No, I didnt.Q. Wh y not?A. Because that would have been Church-assisted

suicide.Q. Have you talked --you had mentioned in your

previous testimony that at some point in time you-we ll, st rike that.

At some point in time did yo u hecomc aware thatE lissa Wall wa s not happy in her arranged marriage withAllen Steed?

MR. HANSEN: Objection as to time. Vague andambiguous as to time. Are you going to narrow the timedowu?

Q BY MR. MORTENSEN) Yeah. when did you becomeaware of that?

A. I only mel Elissa Wall last year.Q. Okay.A. And I- - I honestly can t recall at whatever

time. If l would have heard anything, it would not havePage 61

been from her.Q. Do you reeall hearing it from anybody else?A. You know, I just don t know. There s times

you become aware of stuff, but what that timeline is, Idon t know.Q Let me ask you to tum baek to Exhibit I, if

you would .A. Pardon me? What again?Q. Exhib it I. It s the Declaration of Winston

Kaye Blackmore.A. Okay.Q. I want to understand your testimony .Do you disagree with the substance of Exhibit 1

or do you disagree with the pretext in which it waspresented to you?

A. l disagree with both of those, not having theopportunity to conect it.

Q. All right. Is there anything in paragraph 2on page 2 of the Declaration of Winston Kaye Blackmorethat you disagree with?

(Witness reviewed exhibit.)A. My birthday. IQ Is that wrong?A. Lister used to be Lister and now it s Creston

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Page 62Q. And then paragraph 3, do you disagree with 1

anything in that paragraph? 2(Witness reviewed exhibit.) 3

A. No. 4Q. Paragraph 4, do you disa gree with anything in 5that pa ragraph? 6

(Witness rev iewe d ex hibit.) 7A. It's c lose enough. I mean I think it was 8

later than that, but. 9Q Paragraph 5, do you disagree with anything in 1 0

tha t paragraph? 1 1A No . 12Q Paragraph 6, do you disagree with anything in 13

that paragraph? 14A. No. 15Q Paragraph 7, do you disagree with anything in 1 6

that paragraph? 17A Yes, Id o. 18Q What do you disagree w ith? 1 9

(Wi tness reviewed exhibit.) 20A I disagree that-- I think that the Trust 21

itse lf was a land holding trust and the C hurch itse lf was 22an ecc les iastical group to administer the Church to the 2 3people. 24

Q. Paragraph-- or sentence 2 of that where it 2 5Page 63

says, Historica lly, the President of the Church alwaysserved simultaneously as the President of the Board ofTrustees of the Trust (although the titles fo r theseoffices may have been different).You agree with that, dont you?

A. Yes. The President of the Church alwaysserved simultaneously, except for a small period of timewhere on the death of President Johnson.Q. Right. There would be --

A. A vice president. He was the president.Q Paragraph 8, do you disagree with anything in

that paragraph?(Witness reviewed exhibit.)

A I disagree that -- yes, I do disagree.Q. What do you disagree with?A. I disagree that the Church and the Trust was

inseparable, because they were two different, dis tinctthings.Q. And are you talking about the-- what versionof the Trust are you talking about there?

A. The - I'm talking about the one that I was aTn.1stee of.

Q The November 3rd, 1998 Trus t?A. The 1942.Q How about the 1998 Restated Trust?

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Page 64A I already explained that I don't even agree

with the 1998 Declaration of Trust.Q. How about paragraph 12 where it states,

Every President of the Churchffmst of who might havebeen aware; namely Presiden ts Rulon T. Jeffs, Leroy S.Johnson and John Y. Barlow, has perfonned man iagesinvolving underage girls ?

A. I object to that, because not below the ageof consent.

Q So do you make any distinction betweenunderage girls and age of consent?

MR. HANSEN: I'm going to object. You didn'tread the first sentence of that paragraph where itreferences --

MR . MORTENSEN: All right, Ill read--MR. HANSEN: A 11d then you asked him about the

paragraph, so its misleading.MR. MORTENSEN: Okay, that's fair .

Q (BY MR. M ORTENSEN) Historically, thesemarriages have included underage (before the age ofconsent) girls, including some as young as fourteen.Every President of the Church/Trust of whom I have beenaware, namely P residen ts Rulon T. Jeffs, Leroy S Johnsonand John Y. Barlow, has perfonned marriages invo lvingunderage girls.

Page 65A Under the age of majority, not under the age

of consent That's my objection to that.Q Okay. And what is your understanding as to

from the time period that you became bishop until the lawin Utah was changed, what was your understanding as tothe age of consent?

A. r believe tha t the law of Utah changed theage of consent from 14 to 16 That that age-- prior tothat, the law in U tah was, at least to my understanding,that with parental consent, a 14-year-old cou ld bemanied.

After that law, it was 16, a 16-year-old had tohave both parents' consent.

Q. Okay. So are you -- you are aware thatPresidents Rulon T. Jeffs, Leroy S. Johnson, and John H.Ba rlow had performed marriages of girls under the age of16; correct?

A. No, actually I'm not. It may have been --someone may have told me, but I am not aware of that.Q. You don't have any firsthand k.J1owledge?A I don't have any knowledge of that, no.Q. Have other people told you that?A I've heard it from other people, but I didn't

believe itQ. Have you ever perfonned any marriages of

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Page 66girls that are under the age of 16? 1

A No, I haven t. 2Q Have you ever manied someone who is und er 3

the age of 16? 4A. Yes, I have. 5Q. When was tha t? 6A. Ob, heck, I can t recall, but I know that it 7

was not -- at the time the laws were not changed fo r the 8age of consent. They had their parents consent. 9

Q Who was the person? 10A. Lorraine Johnson. 11Q And how old was she? 12A. She was 15, just about 16. 13Q. Are you still married to her? 14A. Yes, I am . 15Q So she was l 5 years o ld? 16A. Just about 16. 1 7Q. She was 15 years old when you married her? 18A. Yeah. 1 9Q. What year did you many her? 20A. Oh, brother, you are going to get me really 21

in trouble, because I can t remember. I d have to phone 2 2her. 2 3

Q. How o ld were you? 2 4A. It would have probably been 200 I or 2002. 2 5

Page 67Q. And you are cunently 58? 1A Seven. 2Q. Fifty-seven? 3A Yeah. 4Q. So you were in your late 30s? 5A. Yeah, I probably was if I m 57. 6Q. Who married you? 7A President Jeffs 8Q And where were you married? 9A Nevada, I think. On, no, in Canada, I 1 0

believe it was in Canada. 11Q You were married to Lorraine Johnson who was 12

15 in Canada by President-- 13A No, it was in-- it was in Utah. 14Q Where in Utah? 15A Probably right here in Sa lt Lake City. 16Q Do you remember? 17A I cou ld sure find that out, but .. 18Q. Did you get written --first of all, who were 19

Lorraine Johnson s parents? 20A Ray Johnson and Kathy Ann Johnson. 21Q. And did you get their co nsent? 22A. They were the ones who were driving the 23

program. 24Q. Did they put a consent in writing? 25


Page 68A I don t think so, but they were present.Q. Did you go to the courthouse and get a

marriage license?A No, we didn t.Q. Did you go to the marriage -- to thecourthouse and take Lorraine Johnson to the clerk of the

court so the clerk of the comt could determine whetheryour marriage with a 15-year-old was appropriate underUtah law?

A No.Q Did you ever see Lorraine Johnson s birth

certificate prior to ma1Tying her?A. No, I hadn t.Q. Have you eveJ seen her driver s license?A No.Q Did you ever get written consent by Ray orKathy Johnson?A No .Q. And it was Ru lon Jeffs that married you?A. Yes, it was .Q. So you are aware that President Rulon Jeffs

participated in your marriage to someone that was underthe age of majority?A. Perhaps, yeah.Q Perhaps?

A Yeah.Q. You do know that, don t yo u?Page 69

A He-- he gave us his Church bless ing, hisblessing on it.Q As the prop het of the FLDS Church or t hePries thood Work?

A He was doing the bidding of her parents, sothats what be did.Q. But the prophet has to sanction any marriage;correct?

A No, no t every marriage . He did sanction thatone. Q He perfonned it?A Yeah, he perfonned it.Q And your dad also-- your mom was 16?A Yeah.Q And wh ere were they married?A. The Cardston Temple.Q. Was that your dad s first wife?A. Yeah.Q. Le t me ha ve you look at Exhibit 2, the

Declaration of Winston Blackmore.On paragraph 5 -- frrst of all, let me ask, this

affidavit --or this declaration was prepared on behalfof Jeffrey Sh ields, the attomey for the United Eff01t

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1 Plan Trust; conect? 12 A. Correct . 23 Q In paragraph 5 it states, Roger explained to 34 me that some of the potential beneficiaries of the fund 45 of the young women - 56 MR. HANSEN: You need to be careful about 67 writin g on the exhibit. That's the Court exhibit. 78 Q (BY MR. MORTENSEN) If you want a copy you 89 can write on, we can-- 9

10 A. Sorry. 1011 MR. MORTENSEN: No, you're fine. 1112 MR. HANSEN: I don't think he's done mueh. 1213 Ifyou need a notepad, to ahead and have that. 1314 Q (BY MR. MORTENSEN) In paragraph 5 it says, 1415 Roger explained to me that some of the potential 1516 beneficiaries of the fund would be young women who were 1617 seeking to escape or avoid an unde rage marriage. To help 1718 justify their efforts to create the fund, and highlight 1819 tbe need for such assistance, they asked me if I would 1 92 0 give a statement to the effect that underage marriages 2 021 had occurred among our people. Because I was aware of 212 2 such oceurrenecs, I agreed. 2 22 3 You were aware of underage marriages happening 2 324 amongst your people; correct? 2425 MR. HANSEN: I ll objeet. Vague and 25

Page 711 ambiguous as to the term underage marriage. 12 MR. MORTENSE N: I'm using the term he used. 23 MR. HANSEN: He used it when? 34 MR. MORTENSEN: In his affidavit or his 45 declaration. 56 MR. HANSEN: He's already said that's what 67 Roger Hoole prepared, he doesn't agree with it. It's an 78 inaccuracy. So my objeetion's appropriate. 89 Q (BY MR. MORTENSEN) Based on paragraph 5 of 9

10 the declaration, you state on the last sentence you were 1011 aware of such occunences -- because you were aware of 1112 such occunences, you agreed to sign that declaration; 1213 eorrect? 1314 A. Let's just repeat it again, beeause I m still 1415 trying to calculate how old Lmnine was. 1516 Q Yourbrainisgoingfuzzy? 1617 A. And it was in 1999. 1718 Q We won't give her the transcript. 1819 A. Okay. Okay. So go baek here again. 192 0 Q Okay. On paragraph 5, read through that and 2 021 tell me-- 2122 A. ..who were seeking to eseape or avoid an 222 3 underage maiTiage ... 2 32 4 (Witness reviewed exhibit.) 2 425 A. Okay. 25


Page 72Q You were aware that there were underage

marriages that were occurring amongst your people?A. Yeah.Q. And because of that, you agreed that a fundto help these girls escape would be a good thing?A. Or anybody, and l explained to him anybody.

Because at the time in our community there was a couplethat wanted to move and they had no money, no means, noway to move.

So I met with those people and asked them what itwould take for them to move and they figured that itwould take tbem at least $10,000 to move their things and25 to re-establish themselves in ground work.

So what I did at that time was search aroundamong the people to see ifthere s anyone who wanted totake their presence on the property for $35,000 and wefound a person willing to do that. And so that figurewas a figure that satisfied me, that figure of $35,000.Q But you were aware that there were-- thatthere were underage marriages occulTing amongst the FLDSpeople?

A. Yes, underage. Eighteen is underage in-Q. In Canada?A Yeah.Q. In Canada, if hey're under the age of 19,

Page 73they have to -- they also have to go before a courtand--

A. Not a court.Q. -- get permission?A. They just go and they have to have one

parent-- both parents sign for their marriage license.Q. Right. They have to have a parental consentform that they lodge with the court?

A. Yeah.Q. Have you ever seen your people do that beforegetting married?A Oh, yes.Q. Underage-- that are under the age ofconsent?

A. Yeah --under the age of-- not parentalconcept. Yeah, they do. They go and ge t- - i f a16-year-old girl is going to go many somebody, then 1have seen them go and they take their parents in thereand they have them sign on a marriage license and ..

Q That s for the first marriage?A. Yeah, that s for the first marriage.Q On the second marriage, they can t do that,

can they?A. No, but we don t even participate in under

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Page 7 4Q. And as the bishop of the Fundamentalist 1movement in Bountiful , you have prohibited anyo ne from 2under the age of 18 of being married; eorrect? 3A A plural marriage. 4Q. Plural marriage? 5A Yes. 6Q You don't think that wo uld be conect? 7

MR . HANSEN: Objection. Vag ue. Unclear. 8THE WITNESS: I wou ld think what wou ld be 9correct? 10Q BY MR. MORTENSEN ) Entering into plural 11

ma niage under the age of 18 would be a proper-- or 12under the age of 19 would be prop er. 13MR . HANSEN: Objeetion. Vague. 14THE WITNESS: British Columbia is the only 15jurisdiction in North America that has 19. So l don't 16manage whal they do in Idaho or Alberta. 1 7

But my advi ce, I encourage someone if they want 18to be someone's plural wife-- and they do, there's lots 19of people that do-- they get 18, they get their parents, 20and then they come talk. 21

Q BY MR. MORTENSEN) And they eome talk to you 22as the bishop? 23

A They eome and talk to me if hey want to have 24me approve it. 2 5

Page 75Q And for you to approve it, they have to be at 1least 18? 2A. Eighteen. 3Q. But that always hasn't been the case; 4coJTect? 5A. No, it ha sn't. 6Q That changed after Warren Jeffs? 7A. In 2002. 8Q. Prior to that, though, you as the bishop 9would perfonn plural marriages to girls that are under 10the age of 19? 11A. I have to think of who and where, but I would 12have. I would have had the occasion. 13Q. You don 't deny that you did tha t? 1 4A. No , I don't deny that. 15Q. And you don't deny that before you would do 16that the parents didn't bring wi th them a signed consent 1 7

fonn from the government or British Columbia? 1 8A . I don't. 1 9Q. Do you know who the youngest plural bride 20that you have ever maJTied? 2 1A. Lorraine. 22Q. Pardon? 23A. Lorraine.Q. How about perfonn ing the marriage?

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Page 76A. Oh, I ha ve not ever performed anybody-- any

marriages for anybody that was under the age of 18 that Iknew of. But that wasn't my -- it became in 2002, I makepeople show me thei r marriage license-- I mean not theirmarriage license, but their age.

Q Birth certificate or some proof of age?A. Yes.Q Pri or to 2002, you never did that; COJTect?A. No, I never as ked them to provide it.Q Have you done anything-- here you state thatyou were aware that underage marriages were occurringamongst your people; correct?A. Ye s. So long as- - do you want me to put

this disclaimer every time that under the age of-- theyhad their parents' consent , underage with their parents'consent.

Q After 2002, we re you aware of people withinthe FLDS community that were being married that wereunderage?A. I'll tell you from 2000 on, I closed off myphone. I looked a different direetion. I didn't look atthe news. I couldn't have ca red less. And I did th atfor several years before people finally came and startedhunting me out. But I have lost a piece of that historybecause I didn't want to know it.

Pa ge 77Q. On paragraph I0 on Ex hibit 2, on the las t [

sentence you sta te, Historically, it did happen, but wasa rare anomaly.Do you see where I'm referring to?A. Yeah.Q Let me ask you, your father -- your fathermarried a I6-year-old; cotTect?A Yeah.Q. And you married a 15-year-old?A Well, I never touched anybody before theywere 16.Q. When you say touched, is that having

conjuga l --A. L1any way.Q. Conjugal relationship?A. I never had any conjugal relationship. Imean I held a hand, but I would not touch anybody before

they were ..Q. Okay. So you married someone that was 15 ?A. Ye ah, 15 and eight, nine, ten months,somewhere in there.Q. And you are aware that President Rulon Jeffsmarried someone who was underage?A. That would just be hearsay to me.Q Do you have an understanding of that?

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DEPOSITION OF:Winston K. BlackmorePage 78

1 A Only on hearsay. It was beyond my time. I2 had no real contact with any marriages that I had to do3 with that witnessed or were involved with him, the people4 were well-- well older than 20.5 Q. In paragraph 12 it says, .. in no maniage6 ceremony was the UEP T1ust ever mentioned.7 Do you see where I'm referring to?8 A. Okay, I'm there.9 Q. It says, I have perfonned and/or attended10 many FLDS marriages ( estimate the number to be

11 approximately 200), and in no marriage ceremony was the12 UEP Trust ever mentioned.13 The marriage ceremony is a written out ceremony14 that s perfonned by a priesthood officer; correct?15 A That's correct.16 Q. Have you had a chance to read through17 Exhibit 2?18 A. Yeah.19 Q. So the jury can be-- if your testimony is20 presented to the jury, they can rely on paragraph-- or21 on Exhibit 2 to be a tme and accurate copy of what your22 testimony is; correct?23 A Yes.24 Q. Since 2002, have you had conversations with25 Willie Jessop?

Page 791 A. Yes, I have.2 Q. How often do you speak with Willie Jessop?3 A. I went on a bike ride with him last year. I4 talked to him once or twice a year prior to that.5 Q. Has he provided you any documents regarding6 the Elissa Wall matter?7 A. No .8 Q. Has he provided you any kind ofPowerPoint?9 A. No.

10 Q. Has he talked to you about Elissa Wall?11 A. Only to one extent, and that is is to not12 have anything to do with that and -- but Willie Jessop13 does not tell me what to do. He's a person that I speak14 to every now and then, but we gener ally don't talk about15 that.16 Q. Willie Jessop is in the FLDS Church; is that17 correct?18 A. Is he in it?19 Q. He is a member of the FLDS Church?20 A. He used to be. I don t know what his current21 status is.22 Q. All right. Did Warren Jeffs ever assign you23 to perfom1 any marriages up in Canada?24 A. No.25 Q. But Rulon Je ffs did?


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Page 80A Yes.Q. You told us about Lorraine Johnson. Are

there any other women that you took as plural wives thatwere under the age of 19?A Yes.

Q. Who are those or what is -- what are -- morethan one?

A. Are you the media? I mean do I have todisplay my personal family life here? I mean they werein the 1990 era, earlier than 1990 era. It would be twoor three of them, but ..

Q. What are their names?A. Marcia Chatwin and Hannony Quinton.Q. Marcia Chatwin?A. Yeah.Q And who is the second one?A Harmony Quinton.Q. And when did you marry Marcia?A It would have been before 19 -- it would have

been probably 1994.Q. How old was Marcia?A She was just about 18.Q. Was she 17?A Seventeen.Q. W11ere did you marry her?

A. Down in Hildale.Page 81

Q. Did you get any written consent from herparents?

A. No, they were both there.Q. Did you go to the clerk of tl1e court or thecounty clerk and get a marriage license?

A. No, I didn't.Q . Did you ever see her birth certificate priorto marrying her?

A No.Q. And then Harmony -A Quinton.Q. -- Quinton. When did you marry Hannony

Quinton?A. Ninety-four as well -- oh, no, sooner thanthat, probably-- I don t know. It was in the early'90s, maybe just a year before that, '93 maybe.

Q. And how old was Hannony?A. She was 16.Q. And where did you marry her?A. In Salt Lake City.Q. Did you go to the clerk of the court and get

a license?A No .Q Did you get written consent from her parents?

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Page 82A. They were in attendance. 1Q. Just so the juty is clear, you never got 2written consent? 3A. Not written consent, no. They were 4attending. 5Q. Did you ever see her birth certificate-- 6A No. 7Q. --before you manied her? 8A. No, I didn t. 9Q. Any other-- any other plural wives that were 10under the age of 19? 11A. I don t think -- oh, Susan was. 12Q. Susan? 13A. Susan Ga llup. 1 4Q. When did you marry Susan Gallup? 15A. Probably 91. 1 6Q. Pardon? 1 7A. Probabl y 9 1. 18Q. How old was Susan? 19A. Sixteen, just about 17, about 16. 20Q. When is her birthday? 2 1A. Idon tknow. 22Q. Do you know what day you married her? 2 3A. No. 24Q. And you married her in Salt Lake City? 2 5

Page 8 3A. Yep. 1Q. Who married you? 2A. President Jeffs, Rulon Jeffs. 3Q. Who married you and Hannony Quinton? 4A. He did. 5Q. Rulon Jeffs? 6A. Yeah. 7Q. And who maiTied you and Marcia? 8A. He did, Rulon Jeffs. 9Q. So Rulon Jeffs would have married all four of 10your plural wives that are under th e age of 19? 11A . Yes. 12Q. And all of these four plural wives were also 13under the age of 18? 14A. I didnt hear you. 1 5Q. My first question was 19 and now I m just 16lowering it down to 18 . 1 7A. Yeah, yeah, they were. 18Q. Did you ever go to petition juvenile court 1 9here in Utah to marry any of these women? 20A No. 21Q. And you understand, don t you, under the laws 2 2

of Utah, tbat if you had gone to a clerk to obtain a 2 3maiTiage license, you would have been denied one? 2 4A. There was never any intention to go and I did 2 5


Pa ge 8 4not understand that, no .Q. You we re married legally to Jane Blackmore atthe time?

A. Yeah.Q. And under the laws of Utah, you wou ld havebeen denied a maniage license wi th these four wo men thatwere under the age of 18?MR. HANSEN: Objection. Foundation. Callsfor spec ulation.Q BY MR. MORTENSEN) Did you have thatunderstanding?A. I never even thought of that.Q. You didn t research that before youmarried--A. No , l didn t.Q. --any of these young women?A. No. No, I haven t.Q. I take it that at least with rega rd to youmanying someone under the age of 18 is not an anom aly?A. Not und er the age of 18Q. Its happened four times?A. Yeah, witb both parents in attendance.Q. But without sanction or protection from theState of Utah?A. No.

Page 85Q Or protection or sanction from the Province

of British Columbia?A. The Provinee of British Columbia, I had no

eoncem about them and I know nothing about your mles.Q. You don t believe that you are subject to themles of Utah?A. Yeah, I do .Q. You are subject t them?A. Yes, I am.Q But you didn t make any inquiries of whatthey were before you married these four underage women?A. Not those.Q Did you marry a Christ ina Gallup?A Oh, yeah. Yes, I did.Q. And she was 15 years old, was she not?A. She was just about 15, but she s no longer inmy li fe, so ..Q. But you took Christina Gallup as a pluralwife; correct?A. That s right.Q When she was 15?A. Yeah.Q And shes left you?A. Yeah.Q When did she leave you?

22 (Pages 82 t 85)

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DEPOSITION OF : M.J., aka ELISSA WALL v . WARREN JEFFSWinston K. BlackmorePage 86 Page 88

1 A. Two or three years ago. 1 British Columbia?2 Q How about Maryanne Gallup? 2 A. No .3 A. Well, Maryanne Gallup was 16, but she-- we 3 Q. Did yo u take a signed consent fonn from her4 never had anything to do with each other and we later-- 4 parents? II5 we redid our vows and I think she was 19, 18 or 19. 5 A. No, but they were present6 Q. The first time you entered into a plural 6 Q. And who married you and Ms. Fischer? Il7 marriage with her was when she was 16 years o ld? 7 A. President Jeffs.8 A. Yes. 8 Q. How about Shalina Palmer?9 Q And who perfomled that wedding? 9 A. I already told you about her, didn t (?

10 A. Leroy Johnson. 10 Q. I don t believe so .11 Q. And where w s that done? 11 MR. HANSEN : What s the name?12 A. Salt Lake City. 12 MR. MORTENSEN: Sha lina Palmer.13 Q. And what about Christina Gallup when she was 13 Q. (BY MR . MORTENSEN) You married her; co rrect? .14 15, who performed that wedding? 14 A. Yeah.15 A. Leroy Johnson. 15 Q. Where did you marry her?16 Q And what was Mr. Johnsons position with 16 A. Down here in Salt Lake .1 7 the-- 17 Q. She was 15 years old?18 A. He was th e President of the Church. 18 A. I think she was 16.19 Q. And he was the prophet? 19 Q. Is it possible she was 15?20 A. Yeah. 20 MR . HANSEN: Objection. Calls for21 Q And are Maryanne, Christina, and Susan, are 21 specu lation.22 they all sisters? 22 THE WITNESS: Could have been .23 A. Yes, they are. 23 MR . HANSEN: Miss tates his testimony.24 Q How about Edwin Ba rlow? 24 Q. (BY MR. MORTENSEN) Yo u never checked her25 A. Exc use me? 25 berth certificate before?

Page 87 Page 891 Q. Did you marry-- excuse me-- an Edith 1 A. No. No, I didn t.2 Barlow. 2 Q. And who perfonned that wedding?3 A. Who? 3 A. Je ffs, President Jeffs.4 Q Edith Barlow. 4 Q. How about Catherine Broadbent?5 A. Oh, Edith, yeah. 5 A. Yeah.6 Q. She was 17 when you married her, was she not? 6 Q. You married her?7 A. I think she was 18. She might have been, but 7 A. Yeah.8 I think she was 18. 8 Q. She was 17 at the time?9 Q. It s p

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