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             35lMpenT                 Puryear - direct

        1             THE COURT:  Sustained.

        2             MR. ROSENBERG:  Thank you.

        3    Q.  Again, both you and your husband were at that particular

        4    dinner meeting?

        5    A.  Yes.

        6             MR. FABIAN:  I have no further questions.

        7             MR. ROSENBERG:  If I might, your Honor.

        8             THE COURT:  Sure.

        9    CROSS-EXAMINATION

       10    BY MR. ROSENBERG:

       11    Q.  You and I have never met other than I would say a minute or

       12    two minutes out in front of the courthouse -- courtroom today,

       13    correct?

       14    A.  Correct.

       15    Q.  Never spoken before then, have we?

       16    A.  No, we have not.

       17    Q.  And you're aware, obviously, because of the setting we are

       18    in, this is part of a court proceeding, a litigation, correct?

       19    A.  Correct.

       20    Q.  Did you ever have your deposition taken in this case?

       21    A.  No.  Only interviewed over the phone.

       22    Q.  Interviewed by whom?

       23    A.  By the attorney Larry and by Monte.

       24    Q.  And you have never, to my knowledge, given an affidavit in

       25    this case?

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             35lMpenT                 Puryear - cross

        1    A.  No.

        2    Q.  Now, you mentioned that you were familiar with A Course In

        3    Miracles since sometime, it sounded like the early 1970s when

        4    you were in school?

        5    A.  Yes.

        6    Q.  And I'm sorry.  I was doing my best.  I didn't write down

        7    the name of the school.

        8    A.  The National School of Spiritual Science.

        9    Q.  And what years did you attend that school?

       10    A.  From 1972 until 1977.  I actually graduated in '74.

       11    Q.  But you were still there fairly regularly from '72 to '77?

       12    A.  Right.

       13    Q.  Which of those years was it that you heard for the first

       14    time about A Course In Miracles?

       15    A.  The early beginnings when I was a student.

       16    Q.  Could be '72, '73, '74?

       17    A.  '72, '73, '74, those years.

       18    Q.  Could it have been '75?

       19    A.  No, I don't believe so, because I heard about it before I

       20    graduated.  And --

       21    Q.  So that was '74?

       22    A.  Right.

       23    Q.  And you were told that this book had been created, if you

       24    will, from the words of Jesus that a woman had taken down,

       25    correct?

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                                                                           462

             35lMpenT                 Puryear - cross

        1    A.  Right.

        2    Q.  Now, I wrote down in my notes, but I want to make sure that

        3    it's correct, you have said that at that time -- and I think

        4    I'm quoting -- that no copies were available?

        5    A.  I said we didn't have any at the school.

        6    Q.  So you never saw in any form in 1974 any form of a

        7    manuscript or a booklet called a book of A Course In Miracles

        8    at that time?

        9    A.  No.  We just heard about it.

       10    Q.  When was the first time that you personally saw the book, A

       11    Course In Miracles?

       12    A.  When it was in its published form.

       13    Q.  And I think you said it could have been '77 to '79?

       14    A.  Somewhere in that time.  I was on staff at the ARE clinic

       15    '77 to '81, so it was one of those years.  Probably, the first

       16    two or three years.

       17    Q.  And you jump ahead to 1983, May, interestingly, exactly 20

       18    years ago, correct?

       19    A.  Correct.

       20    Q.  That's when you had this lunch or dinner with Judy?

       21    A.  Um-hum.

       22    Q.  In San Francisco?

       23    A.  Right.

       24    Q.  And in this dinner meeting -- again, I'm looking at my

       25    notes, but it's your testimony that counts -- I wrote down that

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                                                                           463

             35lMpenT                 Puryear - cross

        1    you said that Judy said, we never planed to copyright the book,

        2    but we found we had to do it, or words to that effect?

        3    A.  Right.

        4    Q.  So Judy explained to you that there came a point in time

        5    when they decided they had to copyright the book?

        6    A.  Right.

        7    Q.  And it was their intent to do so?

        8    A.  That it wasn't originally their intent but if they didn't,

        9    someone else could copyright it and they would have to pay to

       10    use it, were the words that she used with me.

       11    Q.  They understood at some point, from what Judy told you,

       12    that they had to copyright it?

       13    A.  Right.

       14    Q.  Did she tell you what date that decision was reached?

       15    A.  She did not.

       16    Q.  So it could have been May of 1975, June of 1975, you just

       17    don't know?

       18    A.  No.  The only kind of time frame is that she said they had

       19    made lots of copies.

       20             MR. ROSENBERG:  I move to strike.

       21    Q.  No need to volunteer.  I asked you if you knew what date

       22    they decided to place -- did you know what date they decided

       23    they had to copyright it?  And your testimony is you don't

       24    know?

       25    A.  Correct.

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             35lMpenT                 Puryear - cross

        1    Q.  Judy talked about Xeroxing and copies being passed out,

        2    correct?

        3    A.  Yes.

        4    Q.  How would you characterize Judy at this lunch?  Was she

        5    pleasant?

        6    A.  Very.

        7    Q.  Kind of different.  I've known her now for years.  Kind of

        8    engaging?

        9    A.  Engaging.

       10    Q.  Likes to talk, and I mean no criticism of my client.

       11    A.  Normal in that way.

       12    Q.  Not shy about conversing?

       13    A.  No.

       14    Q.  Enthusiastic in her retelling of this story?

       15             MR. FABIAN:  Your Honor, I believe I was cut off when

       16    you got to the state of mind of the individual.

       17             THE COURT:  Sustained.

       18    Q.  How would you characterize her mode of communication?  What

       19    did you observe?

       20    A.  That she seemed to honestly answer the questions that I had

       21    about it.

       22             MR. ROSENBERG:  I move to strike that.

       23    Q.  I must say you seem very anxious to help the defendants.

       24             MR. FABIAN:  Objection, your Honor.  I move that be

       25    stricken.

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             35lMpenT                 Puryear - cross

        1             THE COURT:  Come on.

        2    Q.  Let me ask you this.  How many copies -- I'm not asking

        3    what Judy told you.  I'm asking from your own knowledge.  How

        4    many copies of the course were copied and distributed before

        5    this was copyrighted, from your own knowledge?

        6    A.  I don't know.

        7    Q.  One?

        8    A.  From what I understand, many more than that.

        9    Q.  From your own knowledge.

       10    A.  I don't know.

       11    Q.  All you know is what Judy, according to you, said that day,

       12    correct?

       13    A.  That, and the information at the clinic about how they were

       14    being copied and used before they were copyrighted.  That's

       15    all.

       16    Q.  What information was that?  Did you testify about that on

       17    direct examination?

       18    A.  I don't know.  All I know is I mentioned at the clinic they

       19    talked about that.  And I met Reed Erickson, who helped to fund

       20    the printing of it some years later.

       21    Q.  In 1976?  Do you know?

       22    A.  Do I know what?

       23    Q.  That Reed Erickson helped fund the printing in 1976.

       24    A.  I didn't know what year he did it.  I saw it in a video,

       25    but he talked about it.

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                                                                           466

             35lMpenT                 Puryear - cross

        1             MR. ROSENBERG:  If I could approach.  I want to find

        2    an exhibit here.

        3    Q.  Have you ever seen this version, which is Exhibit 6, the

        4    gold or yellow copy of A Course In Miracles, this type of

        5    version?

        6    A.  I saw a copy that looked similar to this, but it was not in

        7    book form.  It was flat with the pages like that, yes.

        8    Q.  But two to one, basically?  It was like this, but not bound

        9    together?

       10    A.  Right.

       11    Q.  And when did you see that?

       12    A.  I saw that about two and a half years ago when we were

       13    cleaning out our library at our home.  And I said to my

       14    husband, what is this?  And he said, this is a copy of A Course

       15    In Miracles.

       16    Q.  What you described could be one of the copies that ARE was

       17    making.  Was that your understanding?

       18    A.  That was my understanding, but I'm not positive about that,

       19    but that was my understanding.

       20    Q.  What it was was a Xerox of this form, Exhibit 6?

       21    A.  Something like that.  It was typed, not computer generated,

       22    but typed.

       23    Q.  So to the best of your memory this looks very much like

       24    what you saw that day?

       25    A.  It could have been.  It was typed.  It was two pages side

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             35lMpenT                 Puryear - cross

        1    by side and I think something like that.

        2    Q.  So that was your understanding, that that's what the ARE --

        3    when you talked about it, the facility, when you heard that

        4    they had made copies, that's what you understand you were

        5    looking at at that time, a couple of years ago?

        6             MR. FABIAN:  Objection, your Honor.

        7             THE COURT:  Sustained.

        8    Q.  But you've testified again that it looked like this, it was

        9    a copy, two pages side by side?

       10    A.  Yes.  The print was bigger, but it looked like that.

       11    Q.  You remember the print was bigger, smaller, but it was two

       12    pages side by side?

       13    A.  Right.

       14             THE COURT:  Forgive me, but you said it was not bound?

       15    Am I correct?

       16             THE WITNESS:  Yes.

       17             THE COURT:  It was in a looseleaf?

       18             THE WITNESS:  It was punched on the end with a cover

       19    over it, and it was two pages side by side.

       20    Q.  Do you know who made that copy?

       21    A.  I do not.

       22    Q.  And do you know -- you have received a hard copy of the

       23    course, correct?  At some point you've seen the hard copy?

       24    A.  Yes.

       25    Q.  And could what you have seen -- I'm now holding up Exhibit

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                                                                           468

             35lMpenT                 Puryear - cross

        1    12 -- could what you have seen been a copy of this?  You notice

        2    the print is a little bit bigger?

        3    A.  Doesn't look the same.

        4    Q.  Looks more like Exhibit 6?

        5    A.  Right.

        6    Q.  Again, I don't want to belabor the point, but it is

        7    important.  Definitely two pages side by side?

        8    A.  Yes.

        9    Q.  And you don't know who made that copy?

       10    A.  No.

       11    Q.  And you don't know when that copy was made?

       12    A.  No.

       13    Q.  And you don't have any personal knowledge other than what

       14    you allege Ms. Skutch said about the copying and dissemination

       15    of the course?

       16    A.  From her and from the people at the clinic that talked

       17    about it.

       18    Q.  That's the extent of your knowledge?

       19    A.  Right.

       20    Q.  I guess I could have said it better.  You weren't part of

       21    any of that process, of copying, disseminating, copyrighting,

       22    anything of that further?

       23    A.  No.

       24             MR. ROSENBERG:  Nothing further.

       25             MR. FABIAN:  If I might for a moment, your Honor.

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                                                                           469

             35lMpenT                 Puryear - cross

        1    REDIRECT EXAMINATION

        2    BY MR. FABIAN:

        3    Q.  Mr. Rosenberg showed you several different types of forms

        4    of the course in different pages.  I am going to show you a

        5    couple of pages --

        6             MR. FABIAN:  Your Honor, might I approach.

        7    Q.  -- which I'm holding side by side, pages 430 and 431.  I am

        8    going to ask you to look at that.  Does that look like the type

        9    of print that you saw while you were at ARE?

       10    A.  More like that, yes.

       11    Q.  And was it this size as opposed to the smaller size that

       12    Mr. Rosenberg was showing you?

       13    A.  The reason that I know that it was was that I have glasses.

       14    I'm slightly farsighted, and I can't read that so easily and I

       15    can read the others.

       16    Q.  When you say that, you're referring to the gold or yellow

       17    cover one?

       18    A.  Yes.

       19    Q.  It was your recollection --

       20    A.  It was larger.

       21    Q.  More like the two pages I'm holding?

       22    A.  Yes.

       23             MR. FABIAN:  Your Honor, for the record, I'm holding

       24    up two pages of the manuscript, of A Course In Miracles,

       25    uncopyrighted manuscript which happens to have pages FP00982

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             35lMpenT                 Puryear - redirect

        1    and 983, which were delivered to us, I believe, by the

        2    plaintiffs in this action.

        3             Thank you very much.  I have no further questions.

        4    RECROSS EXAMINATION

        5    BY MR. ROSENBERG:

        6    Q.  Just to clarify, the copy you were looking at was a

        7    standard-sized sheet of paper, eight and a half by 11?

        8    A.  It was larger than that.  It was larger than eight and a

        9    half by 11 in the long way, as I remember that.

       10    Q.  But not twice as big as eight and a half by 11?  It wasn't

       11    like --

       12    A.  No.

       13    Q.  And there were two pages on each, side by side?

       14    A.  As I remember.

       15             MR. ROSENBERG:  Thank you.  Nothing further.

       16             MR. FABIAN:  Your Honor, the witness may be excused?

       17             THE COURT:  Yes.  Thank you.

       18             (Witness excused)

       19             MR. FABIAN:  Your Honor, I am going to call Kevin Rice

       20    as our next witness.

       21     KEVIN RICE,

       22         called as a witness by the Defendant,

       23         having been duly sworn, testified as follows:

       24    DIRECT EXAMINATION

       25    BY MR. FABIAN:

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                                                                           471

             35lMpenT                 Rice - direct

        1             MR. ROSENBERG:  Your Honor, while this, of course, is

        2    Mr. Fabian's witness, I want to object to the testimony.  There

        3    has been an offer of proof given to me and, apparently, and I

        4    don't quite understand it, this witness is going to testify to

        5    a statement that Edgar Mitchell allegedly made to him.  Edgar

        6    Mitchell has not been here.  We may introduce his deposition

        7    testimony, but I don't know how a witness can come in and say

        8    someone who is not a party or what have you told him.

        9             MR. FABIAN:  Your Honor, if counsel is taking the

       10    position that they are not going to introduce Edgar Mitchell's

       11    testimony through deposition, we will consider that.  But it's

       12    on their list.  As a proffer of proof I'll say that

       13    Mr. Mitchell, one way or the other, may have testified that in

       14    fact --

       15             THE COURT:  It is, as they say, rank hearsay, but I'll

       16    take it.

       17             MR. FABIAN:  Thank you.

       18             MR. ROSENBERG:  I just point out, just because I need

       19    to make a record, under Rule 13, if this is for some kind of

       20    prior inconsistent statement of someone who hasn't yet

       21    testified, it requires that it's not admissible unless the

       22    witness is afforded an opportunity to explain or deny the same,

       23    et cetera.  So I renew the objection.  It's rank hearsay, but I

       24    except, as I must, the Court's ruling.

       25    Q.  Mr. Rice, could you please tell the Court your name and

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                                                                           472

             35lMpenT                 Rice - direct

        1    address?

        2    A.  Kevin Rice, 306 North M Street, Lake Worth, Florida 33460.

        3    Q.  Mr. Rice, is it Mr. Rice or Reverend Rice?

        4    A.  Mr. Rice.

        5    Q.  Mr. Rice, could you please tell the Court, briefly give us

        6    your educational background and what you've been doing since

        7    your last schooling?

        8    A.  Yes.  Obviously, I went through high school.  I studied as

        9    a fundamental Christian evangelist under Jimmy Swaggart,

       10    actually, for a couple of years before he had his fall.

       11             And I left after that and studied broadcasting in

       12    Kansas City and left the church, left my broadcasting

       13    television show at the time and basically worked in the

       14    corporate world after I had left the ministry for actually

       15    about three years.

       16             But was introduced to A Course In Miracles almost

       17    immediately after I had quit my job at the television station.

       18    Q.  When did that take place, so we could have a frame of

       19    reference?

       20    A.  That took place probably in 1990, 1991.

       21    Q.  Now, when you say you were introduced to A Course In

       22    Miracles, how did that come about?

       23    A.  Well, I had become very depressed and suicidal with the

       24    particular brand of religion that I had been taught since a

       25    young boy.  And so I sat in my church one morning and I said

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             35lMpenT                 Rice - direct

        1    basically to God, you know, I'm tired, I'm not at peace, I'm

        2    not experiencing the peace that passes all understanding that

        3    you promised, so I'm walking away from it all.  I said, if you

        4    want me to find it, you are going to have to show it to me.

        5             I immediately went home and opened up the book

        6    randomly to find a psychiatrist.  And I went to that

        7    psychiatrist and my first question was, are you a Christian.

        8    And he said, would it matter?  And I said yes, it would.  I

        9    need some secular counseling here.  Anyway, we had an hour

       10    counseling and after an hour counseling, he said you don't need

       11    therapy.  He gave me A Course In Miracles.  And at that point I

       12    just devoured it.  It changed my life since then.

       13    Q.  Now, subsequent to that, what did you begin to do in order

       14    to earn a living or to be involved in the spiritual --

       15    A.  During the formative years of my introduction to A Course

       16    In Miracles I again had left every form of ministry.  I didn't

       17    feel qualified to be a part of it.  So I would say I worked in

       18    the corporate world for probably four or five years, but I had

       19    gone through the study in A Course In Miracles to the point

       20    that I felt I could begin teaching it, so I began teaching it

       21    probably, I'd say, four, five years after first reading it.

       22    And that's how --

       23    Q.  Did you become associated with any church group or other

       24    group in connection with this?

       25    A.  Yes, I did.  I was actually teaching at Unity Temple on the

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                                                                           474

             35lMpenT                 Rice - direct

        1    plaza in Kansas City, but I was not affiliated with that church

        2    at all.  I was merely renting that room.  The vice-president of

        3    Unity World Headquarters came to the class.

        4             Then, after a couple of weeks, he invited me out to

        5    Unity Village, which is in a suburb of Kansas City, and I

        6    subsequently became employed with Unity Village and Silent

        7    Unity, which is the world's largest prayer ministry, and I

        8    began teaching A Course In Miracles there for him and his

        9    board's request, which was banned at the time.

       10    Q.  Where are you located today?

       11    A.  I live in Lake Worth, Florida in Palm Beach County.

       12    Q.  What do you do today?

       13    A.  Today I'm the director of operations at Unity of the Palm

       14    Beacher in West Palm Beach, and I lecture and write on the

       15    side.

       16    Q.  In connection with that particular ministry, do you deal

       17    only with A Course In Miracles?

       18    A.  Absolutely not.  We do have a couple of A Course In

       19    Miracles classes.  I don't teach any of them.  I really just

       20    basically travel and lecture at times, but I have given up the

       21    weekly classes.  A couple of other people do that at our

       22    church.  We embrace everybody and that's A Course In Miracles,

       23    Buddhists, Muslim.  We accept and love them all.  And we have a

       24    curriculum that is suited for them all.  So it's not specific

       25    to A Course In Miracles.

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             35lMpenT                 Rice - direct

        1    Q.  Did there come a time -- by the way, is the church that

        2    you're affiliated with in any way connected with the defendants

        3    in this case, Endeavor Academy?

        4    A.  Absolutely not.

        5    Q.  Have you ever been personally affiliated with either of the

        6    defendants in this case?

        7    A.  When you say the defendants --

        8    Q.  It's Endeavor Academy and the New Christian Church.

        9    A.  Yes.  A few years back I had been teaching at Unity Village

       10    for some time.  And Unity's minister had sent me a tape of the

       11    Endeavor Academy and this gentleman, and I became very

       12    intrigued by it.

       13             And so I thought my curiosity got the best of me and I

       14    traveled with a friend of mine, Chris Jackson, up to Wisconsin,

       15    and was supposed to stay there three days, and I stayed there

       16    actually two days and left.

       17    Q.  Is that your total affiliation -- when I use the word

       18    affiliation, it usually means you work with someone.  Is that

       19    your total connection with the Endeavor Academy in terms of

       20    seeing it and being there?

       21    A.  Absolutely.  The only connection.  In fact, I left

       22    prematurely and have had no contact.

       23    Q.  Did there come a time when you had a contact from either

       24    Monte Barber or Kate Forbes?

       25    A.  Yes.  As a matter of fact, I was very surprised to hear

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                                                                           476

             35lMpenT                 Rice - direct

        1    from Kate Forbes.

        2    Q.  Could you relate to the Court what the request was at that

        3    time?

        4    A.  Yes.  There was one phone call, and this was years after I

        5    had been up there, and she said it had come to her attention

        6    that I might know some people in south Florida who might be

        7    privy to receiving copies of A Course In Miracles before it

        8    obtained its copyrights.  I said I was unaware of anyone who

        9    had obtained a copy, but I said, this church has been one of

       10    the first churches ever to teach it.  I said, so I can

       11    certainly ask around.  And I did ask around.

       12    Q.  And did the name Edgar Mitchell ever come up?

       13    A.  Yes, it did, several times.

       14    Q.  And did there come a time when you had a conversation with

       15    Edgar Mitchell concerning A Course In Miracles?

       16    A.  Yes.

       17    Q.  And when was that, sir?

       18    A.  It was in July of 2001.

       19    Q.  And was that a personal meeting or telephone conversation?

       20    A.  That was a telephone conversation.  He is practically my

       21    neighbor.

       22    Q.  How long did that last?

       23    A.  The conversation lasted one hour.

       24    Q.  And had Edgar Mitchell ever been a member or affiliated

       25    with your church?

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             35lMpenT                 Rice - direct

        1    A.  Yes.  In fact, he was a longtime member of Unity of the

        2    Palm Beaches, along with Hal Rosenkrantz, the founder of the

        3    church, taught A Course in Miracles for several years there.

        4    Q.  Can you relate to the Court as best you can what you said

        5    to Mr. Mitchell during this conversation and what he said to

        6    you?

        7    A.  I premised the conversation by introducing myself and

        8    stated that I had been contacted by an attorney and this was

        9    the reason why I was calling him.  And I said, are you familiar

       10    at all with the copyright issues coming up with respect to A

       11    Course In Miracles?  And he said no, I'm not.  He said, as a

       12    matter of fact, I've really, since I've taught at Unity, moved

       13    well beyond A Course In Miracles to other fields of study.  So

       14    I gave him a brief summary of the particulars, what was going

       15    on.

       16    Q.  When you said you gave a brief summary, where did you

       17    obtain that information from?

       18    A.  That information was just obtained by my -- when you're in

       19    A Course In Miracles community, I was aware that there was a

       20    court case going on with regard to its copyright.  Where that

       21    information came from, I'm not -- I don't recall.

       22    Q.  So after you gave him a brief background, what then was

       23    said by Mr. Mitchell and yourself, if you can recall?

       24    A.  Again, I said I wanted to be very clear, that I was calling

       25    on behalf of someone else, so you knew that my intentions were

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                                                                           478

             35lMpenT                 Rice - direct

        1    pure.  And I said:  I need to know whether or not you ever

        2    received a copy of A Course In Miracles before it obtained its

        3    copyright, say before 1975.  He said:  Yes, I received it in

        4    1973, he said, and so did others.  And he didn't go into the

        5    particulars when he said the others.

        6             I said:  Well, at the time -- and this was a question

        7    that I was asked to ask.  I said:  At the time that that

        8    manuscript was given to you, were there any restrictions at all

        9    placed upon that, you're giving it away or anything?  And he

       10    said:  No, absolutely not.  He said -- as a matter of fact, he

       11    goes:  I put it in my desk drawer with two or three other

       12    manuscripts that were also channeled.  And he said at the time:

       13    I was kind of not very interested in it and it was perfunctory.

       14    And I said it two more times because I didn't want to call

       15    Katie back and have egg on my face.  I said I need to make this

       16    very clear.

       17             I want to ask you again:  You did receive a copy of A

       18    Course In Miracles before it obtained its copyright.  He said:

       19    Yes, in 1973.  And I said:  There were absolutely no

       20    restrictions that Judith placed upon you in the distribution of

       21    this book or anything.  He said:  No, not at all.

       22    Q.  Now, in connection with this did you then have

       23    conversations about anything else in connection with your

       24    conversation?  I don't need to get into it, but how long did

       25    the conversation last?

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                                                                           479

             35lMpenT                 Rice - direct

        1    A.  The conversation lasted one hour and I would say the

        2    portion in which we spoke regarding the copyright issue took

        3    place was probably ten minutes.

        4    Q.  Now, you don't personally know who gave the book to Edgar

        5    Mitchell, do you, A Course In Miracles?

        6    A.  He told me who gave it to her.  He said that Judith Skutch

        7    gave him a copy.

        8    Q.  In 1973?

        9    A.  1973.

       10             MR. FABIAN:  I have no further questions.

       11             MR. ROSENBERG:  May I, your Honor?

       12    CROSS-EXAMINATION

       13    BY MR. ROSENBERG:

       14    Q.  I am going to represent to you, sir, that Edgar Mitchell --

       15    by the way, he is an astronaut that walked on the moon, is that

       16    correct?

       17    A.  That's correct.  And I respect him highly.

       18    Q.  You think he's an honest man in your conversation with him?

       19    A.  I don't think I know Edgar well enough to make an informed

       20    judgment about him.  I would say in my hour long conversation,

       21    I found him to be a very pleasant individual.

       22    Q.  Mr. Mitchell was deposed in this case.  He was asked by

       23    Mr. Fabian -- I represent this was in September of 2001.  Now,

       24    you testified you spoke with him in July of 2001, correct?

       25    A.  Yes.  It was before September 11.  Yes.  And I took notes

                            SOUTHERN DISTRICT REPORTERS, P.C.

                                      (212) 805-0300

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