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             35jopenf                 Skutch-Whitson - direct

        1    of what they called perhaps revelation writings in my career.

        2    And that this was the most profound and the most succinct and

        3    the most organized that I had ever come across.

        4    Q.  Did you have any discussions about what, if anything, you

        5    might be doing as part of this group in regards to the

        6    manuscript?

        7    A.  Well, I did ask.

        8    Q.  What did you ask and of whom?

        9    A.  Well, I asked them, I actually asked them why me.

       10    Q.  Did any of them respond?

       11    A.  They both did.

       12    Q.  Bill and Helen?

       13    A.  Yes.

       14    Q.  What did they tell you?

       15    A.  Bill told me a story of how over the years Helen was really

       16    very disturbed by her role in this, she fought it very hard.

       17    She actually tried to lose her shorthand notebooks, and a few

       18    very funny incidents that are not so funny.  And that she

       19    really was deeply, deeply protective of her reputation and also

       20    protective of her role in scribing this document.  I was

       21    surprised because they seemed to receive me.  It was almost as

       22    if Bill Thetford had said later that day at that meeting that

       23    the family had come together.

       24    Q.  He said that to you?

       25    A.  Yes, he called us a family.

                            SOUTHERN DISTRICT REPORTERS, P.C.

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        1    Q.  Were you plan planning at that point any trip out to

        2    California?  We're now at May 30th.

        3    A.  Well, I hadn't actually decided when to go, but Dr.

        4    Jampolsky was quite adamant that I come as soon as possible,

        5    and I was also going to see Dr. Eleanor Criswell.

        6    Q.  Another doctor?

        7    A.  Yes, she was going to be my advisor in my doctoral degree.

        8    Q.  You were taking a doctoral program in California?

        9    A.  Yes.

       10    Q.  What institution?

       11    A.  This was the Humanistic Psychology Institute, which is now

       12    called Saybrook.

       13    Q.  Did you discuss with Dr. Thetford and Dr. Schucman that you

       14    were going to be going to California at some point?

       15    A.  Yes, I did.

       16    Q.  Did you mention Dr. Jampolsky's expressed interest in

       17    seeing a copy of the manuscript?

       18    A.  I told them both about the conversation that I had on the

       19    phone the night before or the day before when I left their

       20    office.  And Helen asked him questions about is he a real

       21    doctor.

       22    Q.  What questions, to the best of your memory, did he ask

       23    about Dr. Jampolsky; did she ask if he was a real doctor?

       24    A.  Yes, to her a Ph.D. was one thing and an M.D. was something

       25    else, the hierarchy, I don't know.  She wanted to know about

                            SOUTHERN DISTRICT REPORTERS, P.C.

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             35jopenf                 Skutch-Whitson - direct

        1    his background, what work we had done together, just what he

        2    was doing with his life and why he was so interested.

        3    Q.  What did you tell Dr. Schucman?

        4    A.  I told her a little of his background, that he was

        5    extremely interested in this particular field, and that I felt

        6    that he didn't have any prior spiritual training or spiritual

        7    interest, but he may have caught my bug, the enthusiastic bug.

        8    And that when I went to California, I would like to take the

        9    document with me to show it to him.

       10    Q.  He was a Stanford educated M.D. psychiatrist, correct?

       11    A.  Yes, also University of California also.

       12    Q.  And you made that clear to Dr. Schucman?

       13    A.  Oh, yes.

       14    Q.  Did you value Dr. Jampolsky's views professionally in your

       15    ongoing discourse with him?

       16    A.  Very much.

       17    Q.  What did Dr. Schucman or Dr. Thetford say in your response

       18    to show Dr. Jampolsky the manuscript?

       19    A.  There was some discussion about it.  Dr. Schucman finally

       20    agreed with Dr. Thetford that 3,000 miles away was far enough.

       21    She really didn't want this to compromise her reputation.  They

       22    asked me not to use their real names.  We decided upon Dr. B

       23    and Dr. H.

       24    Q.  I guess that would be Dr. Bill and Dr. Helen?

       25    A.  Well, I usually used to say Dr. B and Dr. H, but as events

                            SOUTHERN DISTRICT REPORTERS, P.C.

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             35jopenf                 Skutch-Whitson - direct

        1    transpired, other things --

        2    Q.  They told you they did not want their names associated with

        3    it, correct?

        4    A.  That's correct.

        5    Q.  They did authorize you to show it to Dr. Jampolsky?

        6    A.  Oh, yes.

        7    Q.  Were any restrictions, observations made about what could

        8    be done with it with Dr. Jampolsky?

        9    A.  The document was to remain in my possession and he could

       10    look at it.

       11    Q.  What was your purpose and intent with their permission in

       12    showing it to your acquaintance, professional acquaintance,

       13    friend, colleague Dr. Jampolsky?  What was your intended

       14    purpose in showing it to Dr. Jampolsky?

       15    A.  He was a trained professional in the field.  I guess some

       16    people could say hearing an inner voice is crazy, and he was

       17    very interested in that sort of thing.  I wanted his opinion

       18    about the value of the manuscript.  And I also wanted to see

       19    whether or not we could get something from it together as a

       20    working team.

       21    Q.  Did you obtain authorization from Dr. Schucman or

       22    Dr. Thetford at this meeting, May 30, 1975 to show it to

       23    anybody else?  "It" bean the manuscript.

       24    A.  I believe I told them at that meeting or it could have been

       25    the day after or the day after that, that I had a very good

                            SOUTHERN DISTRICT REPORTERS, P.C.

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             35jopenf                 Skutch-Whitson - direct

        1    friend in California who was also a professional associate,

        2    Dr. James Bolen, who was the publisher of a magazine in the

        3    field that we were interested in.  And with their permission, I

        4    might like to show it to them.

        5    Q.  Is it Dr. Bolen?

        6    A.  No, it is not.

        7    Q.  James Bolen.  What was his position at the time in 1975?

        8    A.  He was a publisher and an editor of a magazine that was

        9    well distributed.

       10    Q.  What was the name of the magazine?

       11    A.  At that time it was called Psychic Magazine.

       12    Q.  And what was the nature, if you will; what type of magazine

       13    was it?

       14    A.  He reported on research in the field.  It was a popular

       15    magazine, so it was in lay people's terms.  He did excellent

       16    interviews with people who were known to be working in the

       17    field, people who were subjects in the field.  He would view

       18    articles from medical journals or scientific journals in lay

       19    language.  And just impart information in a way that was

       20    dignified.

       21    Q.  And you keep saying the field.  He published a magazine in

       22    the field.  What field?

       23    A.  I call it consciousness research, because that's what it is

       24    called today.  In those days it was psychic or parapsychology

       25    or paranormal.

                            SOUTHERN DISTRICT REPORTERS, P.C.

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             35jopenf                 Skutch-Whitson - direct

        1    Q.  And you expressed to Drs. Schucman and Thetford some

        2    interest at this meeting or in the next few days in showing it

        3    to a publisher of a magazine in this field?

        4    A.  Yes.

        5    Q.  What was their response?

        6    A.  They were a little hesitant until I told them something

        7    about it.  And I'm not sure if it was that day or the next day

        8    because I met with them many days before I went to California

        9    or subsequently where the question came up again what my role

       10    was, why was I there.  It didn't seem like an accident, and

       11    Bill said the family, so I asked more about that.  And he said

       12    that they were very aware during the scribing of the document,

       13    more towards the end, but certainly when it was over, that this

       14    was not to be for them alone.  That this was too important and

       15    helpful a document for just their own personal use.  And he

       16    said we always knew that some day we would probably have to

       17    publish it or have it published.  We didn't know how to go

       18    about that, so Helen who was used to communicating with this

       19    internal voice asked the question, is this just for us?  And

       20    she felt her answer, so she said, was very clear, she would

       21    write it down.  No, it is not just for them.  Is it also for

       22    the public?  Yes, it was to be for the public.  And how would

       23    this happen?  And she said that that inner voice told her

       24    someone would come and take it along its way.

       25    Q.  You said a couple of things.  You said there was some talk

                            SOUTHERN DISTRICT REPORTERS, P.C.

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             35jopenf                 Skutch-Whitson - direct

        1    that it wasn't just for them.  Did they tell you it was to be

        2    freely disseminated?

        3    A.  Oh, no.  They didn't want anyone to see it.  Well, Bill

        4    Thetford wanted me to see it.

        5    Q.  But at the same time, you're saying they had some sense

        6    that at some point they felt that it had some need to be

        7    published; is that right?

        8    A.  Yes.

        9    Q.  Did Dr. Schucman at any of these meeting in late May or

       10    early June give you any authorization to show it to anyone, the

       11    manuscript to anyone other than Mr. Bolen and Mr. Jampolsky?

       12    A.  At that point, no.

       13    Q.  Did she give you any instructions at all about

       14    disseminating the manuscript?

       15    A.  Oh, yes.

       16    Q.  What did she say?

       17    A.  She said, she would rather I didn't take it, but Bill was

       18    adamant, and I should be very, very careful.  And that I

       19    shouldn't mention her name or Bill's name.  And I should honor

       20    their privacy.  And that was all I could remember.

       21    Q.  But honoring their privacy, did that mean you could show it

       22    to anyone you wanted as long as you didn't mention their name?

       23    A.  No.

       24             MR. FABIAN:  Objection, this is just conclusory

       25    testimony.

                            SOUTHERN DISTRICT REPORTERS, P.C.

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             35jopenf                 Skutch-Whitson - direct

        1    Q.  What did Dr. Schucman state to you on that topic?  It's

        2    part my fault.  It's not a conversation.  It's question and

        3    answer.  So I'll be more precise.

        4             What did Dr. Schucman tell you about disseminating the

        5    manuscript?

        6    A.  She gave me --

        7             MR. FABIAN:  If I could just, so the record is clear,

        8    this goes exactly again to the heart of the issue in this

        9    litigation.  It's hearsay, and I would, again, object as I have

       10    in the past.

       11             MR. ROSENBERG:  It's not hearsay, your Honor.

       12             THE COURT:  Overruled.

       13    Q.  What did Dr. Schucman tell you about the dissemination

       14    about the manuscript?  We're now in late May, early June of

       15    1975.

       16    A.  She told me I was allowed to show it to Dr. Gerald

       17    Jampolsky and I was allowed to show it to James Bolen.  I was

       18    not allowed to show it to anyone else.

       19    Q.  Were you ever given authorization, and I'm talking about

       20    the manuscript, this thesis bound manuscript, were you ever

       21    given authority to make any widespread dissemination of the

       22    manuscript?

       23    A.  Not at all.

       24    Q.  Were you given contrary instructions?

       25    A.  I certainly was.

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             35jopenf                 Skutch-Whitson - direct

        1    Q.  How often?

        2    A.  I think after the beginning they recognized that I was

        3    following them because we spent so much time together.

        4    Q.  The question was how often?

        5    A.  I couldn't tell you that sir.  Many times.

        6    Q.  Any equivocation about the instruction?

        7    A.  Not at all.

        8    Q.  Again, Dr. Wapnick was present during some of these

        9    conversations?

       10    A.  Almost all of them.

       11    Q.  And he will becoming in as far as you know?

       12    A.  Yes, he will.

       13    Q.  Did you go to California following the May 30, 1975

       14    meeting?

       15    A.  Yes, I did.

       16    Q.  About when?

       17    A.  Sometime probably before the middle of June.

       18    Q.  So sometime roughly in the first two weeks of June; would

       19    that be a fair characterization?

       20    A.  Yes, not later.

       21    Q.  Did you bring the manuscript with you?

       22    A.  Yes, I did, in a shopping bag on the plane.

       23    Q.  So these hard bound heavy thesis binders, which I can

       24    barely pick up, you had in a shopping bag?

       25    A.  Yes, I did.

                            SOUTHERN DISTRICT REPORTERS, P.C.

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             35jopenf                 Skutch-Whitson - direct

        1    Q.  And carried them out to California on a plane?

        2    A.  Yes, I did.

        3    Q.  How many other copies of the manuscript did you have at

        4    this time when were you making this plane ride?

        5    A.  None.

        6    Q.  That was the only one you had at that time; is that

        7    correct?

        8    A.  Yes, that's correct.

        9    Q.  Not covering your whole trip to California that doesn't

       10    pertain to the manuscript, I want to focus on the manuscript

       11    you're talking about Dr. Jampolsky.  I want to ask you, did you

       12    meet with him during the first half of June?

       13    A.  Yes, I was staying at his home.

       14    Q.  Did you show him the manuscript?

       15    A.  Yes, I did.

       16    Q.  Dr. Jampolsky had his deposition taken in this case, is

       17    that your understanding?

       18    A.  I believe he did.

       19             MR. ROSENBERG:  And we'll be proffering that later to

       20    the Court, your Honor.

       21    Q.  Tell us what happened when you get to California with the

       22    manuscript and Dr. Jampolsky?

       23    A.  He was very anxious to see it.  And he asked me to read him

       24    a little bit of it aloud.  He didn't have too easy a time

       25    studying or reading because he was dyslexic, and so I started

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             35jopenf                 Skutch-Whitson - direct

        1    reading it aloud to him.

        2    Q.  What did he say?

        3    A.  He said he thought it was the most important thing that

        4    ever happened to him in his life.

        5    Q.  Did you tell him any part of the story about what Helen and

        6    Bill told you about what the course came to be?

        7    A.  I certainly did.

        8    Q.  Did you tell him anything about what could be done in terms

        9    of distributing the course at this time?

       10    A.  Oh, yes.

       11    Q.  What did you tell him?

       12    A.  I told him that these two people were not anxious for

       13    anybody to know about it, and I had to get special permission

       14    since he had asked me as soon as I told him about it.  And I

       15    got that special permission.

       16    Q.  What happened in regards to the course between you and Dr.

       17    Jampolsky during this trip?

       18    A.  Well, during this trip I read it out loud.  I read more to

       19    him.  He read some himself.  He said this is going to be

       20    something I'm going to be working on for the rest of my life.

       21    And then he said he would like to speak to these people.

       22    Q.  What did you say in response?

       23    A.  Well, I called them.  And I said I have Dr. Jampolsky here

       24    who would like to make your acquaintance and like to speak to

       25    you, is that all right?  And they decided it was all right.

                            SOUTHERN DISTRICT REPORTERS, P.C.

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             35jopenf                 Skutch-Whitson - direct

        1    Q.  So there is a telephone call with Dr. Jampolsky and

        2    Dr. Schucman and Thetford?

        3    A.  That's correct.

        4    Q.  To your knowledge, was he given any authority to

        5    disseminate the course in its manuscript form?

        6    A.  From my knowledge, he was not.

        7    Q.  At this time you only had one copy with you, the one in the

        8    black thesis binders; is that correct?

        9    A.  That's correct.

       10    Q.  You have mentioned in your testimony that you had also

       11    sought permission to show the manuscript to a James Bolen, a

       12    magazine publisher and editor, correct?

       13    A.  Yes, that's correct.

       14    Q.  Did you see Mr. Bolen during your trip to California in

       15    early June of 1975?

       16    A.  Yes, I did.

       17    Q.  And is it your understanding that Mr. Bolen is going to be

       18    coming in to testify during these proceedings?

       19    A.  Yes, he will.

       20    Q.  And where did you meet with Mr. Bolen?

       21    A.  I met with him at his office in San Francisco on Beach

       22    Street where he had his publishing office.

       23    Q.  Did he have a partner or colleague who was sort of his

       24    co-publisher or co-editor?

       25    A.  Yes.

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             35jopenf                 Skutch-Whitson - direct

        1    Q.  Who was that?

        2    A.  Mr. David Hammond.

        3    Q.  Was Mr. Hammond, to your recollection, present at the

        4    office of the magazine that day?

        5    A.  He was in and out of the office, yes.  I saw him there.

        6    Q.  Did you meet with Mr. Bolen?

        7    A.  Yes, I did.

        8    Q.  Did you have the manuscript with you?

        9    A.  Yes, I did.

       10    Q.  Which at this point is the only copy that you have?

       11    A.  Yes.

       12    Q.  What happened at this meeting with yourself and Mr. Bolen?

       13    A.  Well, Mr. Bolen -- I told him the background of the story

       14    without mentioning the names of Dr. Schucman and Dr. Thetford.

       15    And he said, let me see it.  And I showed him a portion.  I

       16    didn't take everything out.  I showed him a portion and he

       17    started to read it and he was reading.  He, obviously, wanted

       18    to read more, but he started to laugh in a way that seemed to

       19    me to be slightly inappropriate.

       20    Q.  Did you say something to Mr. Bolen?

       21    A.  Yes, I did.

       22    Q.  In substance, what did you say?

       23    A.  I asked him if he thought it was very funny.  He said, I'm

       24    so close to tears that I'm laughing.  He said this is very

       25    thrilling to me.  He said he had seen many different kinds of

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             35jopenf                 Skutch-Whitson - direct

        1    material, and that this was so powerful to him.

        2    Q.  Were any arrangements made for Mr. Bolen to get a copy of

        3    the course at the meeting?

        4    A.  Well, he wanted a copy.  And I knew, of course, that Dr.

        5    Jampolsky wanted a copy.  And I called up Dr. Schucman and

        6    Thetford.  There was a three-hour time difference, and it was

        7    their morning and they were at the University.  And I asked

        8    them if it was all right for me to leave a copy with Dr.

        9    Jampolsky and Mr. James Bolen.  And Helen made the remark that

       10    I remember that well, if he publishes something called Psychic

       11    Magazine, I'm not very happy about that.  She did not want the

       12    material connected to something that was loosely called

       13    Psychic.  She felt that was not its genre.

       14    Q.  What did you say to her?

       15    A.  I said to her I trust him, he has given me excellent

       16    advice, he is a publisher, and he knows more people in the

       17    field than I do, and I would like his opinion, and he won't be

       18    able to read it unless I leave him a copy.  Bill was on the

       19    phone and he felt it was all right and she agreed.

       20    Q.  Did you specifically mention in this conversation that Dr.

       21    Jampolsky also wanted a copy?

       22    A.  I believe that this happened a day or two before that, but

       23    I can't exactly recollect.

       24    Q.  But at some point you mentioned to Helen and Bill that Dr.

       25    Jampolsky wanted a copy?

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             35jopenf                 Skutch-Whitson - direct

        1    A.  Oh, yes, he told them on the telephone he did.

        2    Q.  What was that response to the request that you give a copy

        3    to Mr. Bolen, a magazine publisher in this field?

        4    A.  It was all right as long as the caveat as it being kept

        5    under wraps, that it not be published in his magazine, and that

        6    he just study it for purposes of giving me some opinion as a

        7    publisher.

        8    Q.  And how about Dr. Jampolsky, what was Helen and Bill's

        9    response to his request to see the manuscript?

       10    A.  Well, since I had spoken to him direct for quite a while on

       11    the telephone, and I think they were impressed with his

       12    sincerity --

       13    Q.  That's your opinion.  What was said?

       14    A.  I did not hear the conversation with Dr. Jampolsky and Drs.

       15    Schucman and Thetford.  I just know the result of it was that I

       16    was allowed to leave a copy.

       17    Q.  So we're now back in June at the office of Mr. James Bolen,

       18    the office of Psychic Magazine.  Did you discuss with Mr. Bolen

       19    copying the manuscript?

       20    A.  He told me right away he wanted to copy it, which is why I

       21    called them.  So, yes, I came back and told them that it was

       22    all right, and that he could have a copy.  And I do not

       23    remember whether he suggested or I told him that I also would

       24    need a copy for Dr. Jampolsky because I was not going to leave

       25    mine there.

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             35jopenf                 Skutch-Whitson - direct

        1    Q.  Now, did you say anything to Mr. Bolen about what he could

        2    or couldn't do with the manuscript you were going to leave and

        3    the copy he was going to make?

        4    A.  Well, I certainly told him that he was to keep it very much

        5    under wraps.  I had told him that Helen and Bill kept it in a

        6    locked filing cabinet.  And I told him that this was for his

        7    eyes to read and for him to give me an opinion.

        8    Q.  Did he have any response to that instruction, that

        9    observation?

       10    A.  From what I remember, it was totally in accord with the way

       11    he practices profession.

       12    Q.  Was it your understanding that he receive as part of his

       13    role as magazine editor and publisher different manuscripts?

       14    A.  Yes.

       15    Q.  Let me ask you this, did he respond to your discussion that

       16    it has to be kept under wraps?  Did he say he agreed, disagreed

       17    or did he respond?

       18    A.  He agreed.

       19    Q.  What happened that day with the manuscript?

       20    A.  Well, I left it with him.

       21    Q.  And did you retrieve it?

       22    A.  Oh, yes.

       23    Q.  How long after?

       24    A.  I don't remember exactly.  I think it was the next day or

       25    the day after.

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             35jopenf                 Skutch-Whitson - direct

        1    Q.  And you came back to -- where did the retrieval take place?

        2    A.  At his office.

        3    Q.  How many copies did Mr. Bolen make?

        4    A.  I believe he ran off three.

        5    Q.  So he had your manuscript now plus three?

        6    A.  That's right.

        7    Q.  To your knowledge from this meeting you're in his office,

        8    what happened with the three copies?

        9    A.  Well, he gave me one for Dr. Jampolsky.

       10    Q.  Did he give you your own back?

       11    A.  Certainly he gave me my own back, and I believe he retained

       12    two for himself.

       13    Q.  And if you remember, did you reiterate at this meeting your

       14    instruction that it not be diseminated?

       15    A.  I don't remember that.

       16    Q.  Either way you don't remember that?

       17    A.  No.

       18    Q.  We're now in California in early to mid-June.  Now, you had

       19    two now, your own and a copy, correct?

       20    A.  Well, I had given the copy when I got back to where I was

       21    staying to Dr. Jampolsky.

       22    Q.  That was my next question.

       23             So Jim Bolen has two?

       24    A.  That's right.

       25    Q.  You have two as you leave Jim Bolen's office?

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        1    A.  That's right.

        2    Q.  That's a lot to carry, correct?

        3    A.  I had help.  I had a nice friendly taxi driver.

        4    Q.  You go back to Dr. Jampolsky's, correct?

        5    A.  Yes.

        6    Q.  And what do you do with the two copies that you have your

        7    own and the additional copy?

        8    A.  Mine I put where I kept my things, and the other one I gave

        9    to Dr. Jampolsky, and I believe it was gray boxes that you get

       10    from the copy house to put them in.  So we had a stack of them.

       11    I don't remember how many.

       12    Q.  So it is eight and a half by 11, correct?

       13    A.  Yes, sir.

       14    Q.  Like the excerpt, Exhibit 4?

       15    A.  That's right.

       16    Q.  But 1500 give or take pages?

       17    A.  That's right.

       18    Q.  And you gave that to Dr. Jampolsky?

       19    A.  That's right.

       20    Q.  And you previously communicated to him the restrictions on

       21    distributing it?

       22    A.  Yes, I did.

       23    Q.  To your knowledge, how often did you see Dr. Jampolsky

       24    during June, July, August of 1975?

       25    A.  I saw him that week, and then another time that was more

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             35jopenf                 Skutch-Whitson - direct

        1    towards the end of June or beginning of July, and then went

        2    back to New York.  And then I saw him for about six weeks,

        3    staying at his place, from the 23rd of July until almost the

        4    end of August.

        5    Q.  We'll get to those as we go through this.

        6             My question is:  To your knowledge, from your own

        7    observation from what Dr. Jampolsky told you, did he ever

        8    distribute copies of his copies of the course to the public?

        9    A.  From my knowledge, from what he told me, he never did.

       10    Q.  How about Jim Bolen, do you know if he made any kind of

       11    distribution outside of his magazine?

       12    A.  As far as I know, Jim Bolen never made any distribution.

       13    Although he did have an article about it subsequently, two or

       14    three articles.

       15    Q.  And we'll talk about that.

       16             There was this fellow David Hammond, he worked with

       17    Mr. Bolen?

       18    A.  Yes.

       19    Q.  Other than Mr. Hammond and Mr. Bolen, do you know of any

       20    facts that would suggest, evidence, from your own observation,

       21    your own experience, that Mr. Bolen's copy was disseminated?

       22    A.  No, not at all.

       23    Q.  Now, my memory was that when you were going to California,

       24    you were going to see Dr. Jampolsky.  You have talked about

       25    that, correct?

                            SOUTHERN DISTRICT REPORTERS, P.C.

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             35jopenf                 Skutch-Whitson - direct

        1    A.  Correct.

        2    Q.  Mr. Bolen, correct?

        3    A.  Correct.

        4    Q.  And my notes say Eleanor Criswell something with doctoral

        5    thesis?

        6    A.  Yes.

        7    Q.  Did you see Dr. Criswell during this trip in June of 1975?

        8    A.  Yes, I saw her briefly in the library at the office of the

        9    American Humanistic Institute.

       10    Q.  Now, you're aware that Dr. Criswell has been deposed in

       11    this case?

       12    A.  Yes.

       13    Q.  And her deposition will be proffered to the Court; is that

       14    your understanding?

       15    A.  Yes, it is.

       16    Q.  Do you recall that in her deposition, she places this first

       17    meeting with you in July of 1975; do you remember hearing that

       18    or reading that?

       19    A.  That's correct.

       20    Q.  Is that consistent with your memory?

       21    A.  It's consistent with my memory that I did meet her in July,

       22    but I also met her in June.

       23    Q.  So if Dr. Criswell testified that your first meeting was in

       24    July, that's not your recollection?

       25    A.  No, it is not.

                            SOUTHERN DISTRICT REPORTERS, P.C.

                                      (212) 805-0300

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