Susan Alamo “I Don’t Remember”
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IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS FORT SMITH DIVISION
DEPOSITION OF: SUSAN ALAMO APRIL 22, 1981
LOCATION: FEDERAL BUILDING FORT SMITH, ARKANSAS
SIGNATURE OF DEPONENT
I, Susan Alamo, hereby certify that I have read the above and foregoing deposition given by me in Case No. 79-2173, filed In The United States District Court, Western District of Arkansas, Fort Smith Division, Don Wylie, et al v. Tony and Susan Alamo Foundation, on this __ day of May, 1981, consisting of Twenty-seven (27)
Pages, and that the facts and matters therein contained are true and correct to the best of my knowledge, information and belief.
SUSAN ALAMO
STIPULATION
IT IS HEREBY STIUPLATED AND AGREED BY AND BETWEEN THE PARTIES HERETO THAT THE DEPOSITION OF SUSAN ALAMO MAY BE TAKEN BEFORE JOAN DOUGLAS IN THE MATTER REFLECTED IN THE CAPTION PAGE HEREOF BY THE PLAINTIFFS FOR DISCOVERY PURPORSES.
ALL FORMALITIES WITH REFERENCE TO NOTICE, TAKING, TRANSCRIBING, SIGNING, FORWARDING AND FILING OF SAID DEPOSITION ARE HEREBY WAIVED, BUT THE RIGHT TO OBJECT AT THE TIME OF THE READING OR OFFERING THEREOF ON THE GROUNDS OF INCOMPETENCY, IRRELEVANCY, IMMATERIALITY, FORM OF THE QUESTION, OR OTHERWISE, IS EXPRESSLY RESERVED.
SUSAN ALAMO, HAVING FIRST BEEN DULY SWORN, TESTIFIED, AS FOLLOWS:
DIRECT EXAMINATION
MR. GARNER:
Q. You are the same Susan Alamo, who gave a deposition on March the Twenty-seventh, 1980, in this same room?
A. Yes.
MR. GEAN:
I think that’s the right date, Charlie.
MR. GARNER:
That’s what it shows on the front
MR. GEAN:
Yeah, that’s what it shows.
MR. GARNER CONTINUES:
Q. And you’ve told us, Mrs. Alamo, that your son’s name
is Charles Brown?
A. Yes.
Q. Do you know his address?
A. He lives in Shreveport, Louisiana.
Q. Where in Shreveport?
A. They’ve bought a new house in Shreveport.
Q. Pardon?
A. They have bought a new home in Shreveport, I don’t know exactly what the address is.
Q. What was his old address?
A. I don’t remember what his old address was.
Q. Do you recall when they bought the new home?
A. No, I don’t.
Q. For whom does he work?
A. He’s self employed.
Q. In what business?
A. Sales.
Q. What kind of sales?
A. Mr. Garner, I don’t know, it’s some sort of chemical that I wouldn’t even have any awareness of, that has something to do with yachts, I don’t know.
Q. Can you secure his address for me?
MR. GEAN:
Is that important, Charles?
MR. GARNER:
Yes, I think it is.
MR. GEAN:
Do you intend to use him as a witness?
MR. GARNER:
I just don’t have any idea, but I’d like to speak at him.
MR. GEAN:
Well, she doesn’t know now, we’ll–
MR. GARNER CONTINUES:
Q. Do you know his address now?
A. No, I don’t.
Q. Can you secure it for me?
A. I…don’t know.
MR. GARNER:
Well, Roy, are you refusing to do that? I mean Judge Williams is here today, we can go back and –
MR. GEAN:
Well, if—there’s a possibility I can get it, I just don’t know. She says she doesn’t know, I’ll make an attempt to do so, if the Court directs me to do so, I can get it for you.
MR. GARNER: Well –
MR. GEAN:
I think you could file a –
MR. GARNER:
– she knows he’s bought a new home, she’s obviously in contact with him –
MR. GEAN:
Well –
MR. GARNER:
– some way or another.
MR. GEAN:
Yes.
A. Yes, and he’s selling the home and he’s moving.
MR. GARNER CONTINUES:
Q. Pardon?
A. He is in the process of selling and he’s moving.
Q. Are you in weekly or daily or monthly contact with him?
A. I see him quite often.
Q. You see him quite often?
A. Uh-huh (yes).
Q. Do you correspond with him?
A. Mr. Garner, if I see him quite often, I must be corresponding with him, if I’m seeing him. As a matter of fact, he spent the night in my home…uh…what is today?
MR. GEAN:
This is April the Twenty-second.
A. Day before yesterday.
MR. GARNER:
Well, are you telling me, Roy, that you will secure his address or phone number.
MR. GEAN:
I don’t know that it’s relevant.
MR. GARNER: Okay.
MR. GARNER CONTINUES:
Q. Now, with reference to your daughter, Susan Mick, do you know where she is?
A. No.
Q. Pardon?
A. No.
Q. Are you in contact with her?
A. No.
Q. When was the last contact you had with her?
A. I don’t remember.
Q. Well, could you give me a ballpark figure?
A. Ho, I couldn’t, I don’t remember.
Q. Is her name still Susan Mick, as far as you know?
A. No, it isn’t, she’s been divorced from Mick for many years, I haven’t the slightest idea what her name is.
Q. Well, for your information, Mrs, Alamo, you told me on March the Twenty-seventh, that her name was Susan Mick, not Susan Brown.
A. Her name wouldn’t be Susan Brown.
Q. Well, you answered that it was Mick?
A. She was married to Ed Mick at one time. They are divorced. I don’t know what name the girl is using.
Q. Do you know where—what town she’s in?
A. No, I don’t.
Q. Do you know what state she’s in?
A. No, I don’t.
Q. Was her name originally Susan Brown?
A. No.
Q. What was her name?
A. Lepowitz.
Q. Susan—she is the natural daughter of Sam Lepowitz?
A. Saul.
Q. Saul Lepowitz.
Q. You at one time were known as Susan Fleetwood, as Susan Brown, and now it’s Susan Alamo, were you ever known by another name?
MR. GEAN:
Charles, is that material?
MR. GARNER:
I think it is. Do you want to go back and talk to Judge Williams now?
MR. GEAN:
I don’t particularly want to talk with him –
MR. GARNER:
Well, let’s just go back and talk with him, we’re having problems –
MR. GEAN:
Of course, this is not his case, but I’d be glad to talk with him about it.
MR. GARNER:
I understand, but he’s made a ruling on it before, and he’s told her to answer these questions.
MR. GEAN:
Well…
(An off-the-record discussion, out of the hearing of the court reporter, follows)
MR. GARNER CONTINUES:
Q. Mrs. Alamo, what names, other than Susan Brown, Susan Alamo, Susan Fleetwood, and Susan Lepowitz have you been known by?
A. I don’t remember.
Q. How many other names were you known by, other –
A. I don’t remember.
Q. How many times have you been married?
A. Mr. Gean, what does this have to do with –
MR. GEAN:
It’s personal history, and he can go into that. I’ve agreed with Charlie, we’ll allow him to do that. That doesn’t mean it is material for the lawsuit, Mrs. Alamo, but we’ve agreed to allow him to go into matters concerning personal history. I’m trying to save Mr. Garner as much time as possible. Judge Williams said just to submit any questions to Judge Wood, as per his directions before, but he suggested that to allow him to go into personal history, and which he-— let’s let him do that, so we can get this out of the way.
MR. GARNER CONTINUES:
Q. How many times have you been married?
A. Three.
Q. To whom?
A. Tom Brown, Saul Lepowitz, Tony Alamo.
Q. Were you divorced from Tom Brown?
A. Are you asking me if I remarried without the beneifit of a divorce?
Q. No, ma’am, I asked you if you divorced Tom Brown?
A. I don’t know what he’s trying to say.
MR. GEAN:
Well, that’s a pretty clear question. Is Tom Brown alive?
A. Yes.
MR. GARNER:
Q. Did you all receive a divorce?
MR. GEAN:
Or an annulment of some sort in some court?
A. Yes.
MR. GARNER:
Q. Where?
A. I don’t remember.
Q. Do you remember when?
A. No, I don’t.
Q. Where did you and Mr. Brown live most of your married life?
A. About a month in Alma.
Q. Are you telling me that you and Mr. Brown only lived together about a month?
A. About a month.
Q. Did you have two children as the result of that –
A. No.
Q. Were any children born as a result of that marriage?
A. Charles Brown.
Q. All right. And do you recall what year it was that you all divorced?
A. No, I don’t.
Q. Do you recall where?
A. No, I don’t.
Q. Do you recall a ballpark figure?
A. No, I don’t.
Q. Do you recall when you married him?
A. No, I don’t.
Q. Do you recall where you married him?
A. No, I don’t. I was fourteen years old.
Q. You were fourteen?
A. Right.
Q. Okay.
A. No, I don’t.
Q. Do you—when did you marry—-was Mr. Saul Lepowitz your second marriage?
A. I think I was seventeen, I’m not sure, I don’t remember.
Q. When you married Saul?
A. Right.
Q. You don’t remember whether –
A. No.
Q. – it was your second marriage or not?
A. No. I remember, yes, that it was my second marriage, but I remember I was approximately, I think, seventeen, I’m not sure.
Q. Where did you marry him?
A. Yuma, Arizona.
Q. Pardon?
A. Yuma, Arizona.
Q. Do you remember what year?
A. No, I don’t.
Q. Did you divorce Mr. Lepowitz?
A. He’s dead.
Q. I understand, but my question is did you divorce him?
A. Yes.
Q. Pardon?
A. Yes.
Q. When?
A. I don’t remember.
Q. Do you recall –
A. It was in the early Sixties.
Q. Pardon?
A. It was in the early Sixties..
Q. Do you recall where you divorced him?
A. Las Vegas.
Q. Did you—were any children born as a result of that marriage?
A. Yes.
Q. How many?
A. One daughter.
Q. And that is Susan?
A. Yes.
Q. Do you recall when you married Saul?
A. No, I don’t.
Q. Do you know when Susan was born?
A, No, I don’t.
Q. Do you know where she –
A. Oh, Susan was born in 1950.
Q. Do you remember what date it was?
A. August Nineteenth.
Q. Whereabouts?
A. Los Angeles.
Q. Los Angeles?
A. August the Second.
Q. August the Second?
MR. GEAN:
Is that the date of birth you’re talking about, Mrs. Alamo?
A. Yes.
MR. GARNER CONTINUES:
Q. Of 1950?
A, Yes.
Q. Mrs. Alamo, when did you marry Tony Alamo?
A. The first time in ’65, the second time in ’66, been married three times.
Q. To Tony?
A. Yes.
Q. And when was the third time?
A. August Nineteenth, 1966.
Q. 1966?
A. Uh-huh (yes).
Q. That was the third time, when was the second time?
A. Well, the second time was the same day.
Q. All right. When was the first time?
A. Mexico.
Q. Do you remember the –
A. No, I don’t –
Q. Do you know it was the –
A. No, I don’t.
Q. Don’t what?
MR. GEAN:
Remember the date?
A. No, I don’t.
MR. GARNER:
Q. I didn’t ask you about the date.
MR. GEAN:
Let him finish his question, Mrs. Alamo. Go ahead, Charlie.
MR. GARNER CONTINUES:
Q. Do you know where you married?
A. No, I don’t.
Q. Do you know what town in Mexico?
A. No, I don’t.
Q. Was it a civil ceremony?
A. Yes.
Q. Was it by a Mexican –
A. Yes.
Q. What?
A. I really don’t know.
Q. While you were in Las Vegas, Mrs. Alamo, were you a professional singer or dancer?
A. No, I was not.
Q. Did you work, when you were married, out there, to Mr. Lepowitz?
A. No, I did not.
Q. Was Mr. Lepowitz connected with the Mafia?
A. No, he was not.
Q. Did you ever use any other names, other than the ones I’ve asked you here about, that is –
A. I don’t remember.
Q. Did you ever have a reason to use any other names, other than –
A. No, I did not, other than professional.
Q. Pardon?
A. Other than professional.
Q. Okay. What names did you use professionally?
A. Susan Fleetwood.
Q. And was there a Fleetwood Foundation?
A. Yes.
Q. Where was that formed?
A. Los Angeles.
Q. Do you remember what year?
A. No, I haven’t the slightest idea. No, there wasn’t, that was under the name of Susan Lepowitz.
Q. Susan What?
A. Lepowitz.
Q. Was there a Susan Lepowitz Foundation?
A. Uh-huh (yes).
Q. What year, please, ma’am?
A. I haven’t—I couldn’t truthfully tell you if my life depended on it.
Q. What—what year was that founded?
A. I couldn’t tell you, I don’t remember.
Q. What town was it founded?
A. Los Angeles.
Q. Was it before the Alamo Foundation?
A. Yes, years before.
Q. Do you know how many years –
A. I haven’t the slightest-—I don’t know, no, I don’t know what year or how many years before.
Q. Was it in existence at the time you met and married Tony Alamo?
A. Yes, it was.
Q. Is it still in existence?
A. No.
Q. How was it done away with?
A. I’m not sure, I don’t remember.
Q. Do you know who the attorney was –
A. No.
Q. – that founded it?
A. I don’t, no.
Q. I believe you told me that you were in operation as the Tony Alamo Foundation three or four years before you actually formed the Foundation –
A. Yes.
Q. – is that correct?
A. Yes.
Q. During that time, did you also use the Lepowitz Foundation?
A. No, we never did.
Q. Mrs. Alamo, did Richard Hydell ever buy a mink coat for you?
A. No, Richard Hydell picked up a mink coat, a proto type.
Q. All right. Where did he pick it up, please, ma’am?
A. I don’t remember, it could have been Couture.
Q. Who?
A. Couture, but I’m not sure about that.
Q. What town?
A. Beverly Hills.
Q. Do you remember what year?
A. Oh, God, no.
Q. Who paid for the coat?
A. We paid for the coat.
Q. Who is we?
A. Tony and I.
Q. Out of funds of the foundation?
A. Yes, it was a proto type.
Q. What do you mean, proto type, please?
A. We have them made all the time, show pieces, use them for show pieces.
Q. I don’t understand, would you mind explaining that to me?
A. We’re in the clothing business.
Q. Pardon?
A. We are in the clothing business.
Q. Were you in the clothing business at the time he picked up the mink coat?
A. Yes, we were.
Q. Do you know what happened to the mink coat, do you still have it?
A. Yes.
Q. And it’s still a proto type?
A. Yes.
Q. Do you remember what year it was?
A. No, I haven’t the slightest idea.
Q. Do you remember what it cost?
A. No, I don’t.
Q. Does $15,000 sound right?
A. No, it doesn’t.
Q. Too much or too little?
A. Too much.
Q. All right. Where did you–who did your wigs out there in California, Mrs. Alamo?
A. I never bought any wigs in California, outside of just little shops on the street.
Q. You never bought any special-made ones?
A. Not in California.
Q. Incidentally, are you all off the air, I don’t see you anymore on Sunday?
A. Have you missed us?
Q. Pardon?
A. Have you missed us?
Q. Yes, I have, frankly.
MR. GEAN:
Are you off the air, go ahead and answer his question.
A. Temporarily.
MR. GARNER:
I’m serious about that –
MR. GEAN:
That’s locally?
A. Yes.
MR. GEAN:
You’re talking about locally?
MR. GARNER:
Yes. Well, I say locally, it comes on our TV, I don’t know whether it’s a cable station or –
MR. GEAN:
I don’t know, are you on the air–well, it’s locally, you’re talking about whether they’re on the air or not? MR.
GARNER:
I don’t really know.
MR. GEAN:
Well, she said no, not locally.
MR. GARNER CONTINUES:
Q. Are you on the air, other than locally, Mrs. Alamo?
A. Roy, what has this got to do –
MR. GEAN:
Well, it has to do with the Foundation, now, that’s okay.
A. No, we have taken a leave of absence for awhile.
MR. GARNER CONTINUES:
Q. Are you all now promoting that Dallas-—is that your promotion, the Dallas—Alamo of Dallas?
A. Yes, it is our promotion.
Q. Did Richard Hydell ever buy a Cadillac for you?
A. Richard Hydell never bought any Cadillac for me. Richard Hydell drove from California, to Arkansas, with another brother from the Foundation, and delivered a car that Tony had bought in California.
Q. Was it a Cadillac?
A. Yes.
Q. New one?
A. Yes.
Q. Paid for with the Foundation funds?
A. Yes.
Q. Where do you get your eyelashes made?
A. That’s the funniest thing I ever heard.
MR. GEAN:
Well, go ahead and tell him –
A. I don’t.
MR. GEAN:
– I don’t think it’s admissible, but the Judge wanted us to go ahead and try to get this over with, anything that has to do with your personal history, why, let’s try to answer it.
A. That isn’t personal history, it’s harassment.
MR. GEAN:
Well, let him harass, then. Where do you get your eyelashes made?
A. I don’t get them made.
MR. GARNER CONTINUES:
Q. Is William Bill Levy a member of your Foundation?
A. Well, he attends the church, we don’t have members.
MR. GEAN:
He’s not a member of the Foundation, Charles, from a technical standpoint.
MR. GARNER:
Yeah, I’m sorry.
MR. GEAN:
He’s associated, let’s use that word.
MR. GARNER CONTINUES:
Q. He is associated with you all?
A. Yes, he attends the church.
Q. Where is he?
MR. GEAN:
He’s at Alma.
A. Where is he?
MR. GARNER:
Q. Yes.
A. You mean where does he live or where is he?
Q. Well, where does he live?
A. He lives at Dyer.
Q. He’s working, then, here in Arkansas, I take it?
A. Yes.
Q. What is his official position, being associated with the Foundation?
A. Everybody at the Foundation has all different kinds of positions, they’ll be in one place one day and doing
something else the other.
MR. GEAN:
Charles, do you want to take his deposition, if you do, I can make him available for you.
MR. GARNER:
Well –
MR. GEAN:
If you’re just trying to locate him just for the purpose of taking his deposition –
MR. GARNER:
No, I’m just trying-—wonder what his position is.
MR. GARNER CONTINUES:
Q. Does he have anything to do with the finances or check or bank accounts or write checks or anything?
A. No.
Q. He’s never had anything to do with the financial –
A. You’ll have to ask Tony these questions, I don’t have anything to do with any of the business at the Foundation.
Q. And I believe you told me that the Foundation had never made any political contributions, that you know of? A. You will have to talk to Tony about all of the business details of the Foundation. I have nothing to do with the business details of the Foundation.
Q. That’s even though you’re one of the Founders of it?
A. Yes.
Q. You have abdicated your duties to Mr. Alamo?
A. No. That isn’t true. I have my duties, but I am not in control of the business of the Foundation.
MR. GARNER:
I believe that’s all.
A. Mr. Garner, are you finished with me?
MR. GEAN:
Yeah, you can go on back out.
A. I want to say to you, Mr. Garner –
MR. GEAN:
Now–now –
A. Please, Roy.
MR. GEAN:
Let’s not say anything on the record, Susan.
A. Please, Roy, I want it on the record.
MR. GEAN:
All right.
A. I want to say to you that I understand, after I left the room, before, when we were here, that you asked Tony if our background wasn’t similar to that of Kathy’s and Don’s, if we were not raised about the same way. Mr. Garner, my father died when I was two and a-half years old. My mother raised us two little girls, on a government pension. She never had another boyfriend, she never tasted alcohol or tobacco, and I would like it to go on the record that my mother was a lady, well respected and both me and my family resent that terribly.
MR. GARNER:
Well, let me apologize to you, if I did, because I don’t remember asking that, and I have never inferred or indicated in any way that your family was anything other than good people, including you, Mrs. Alamo.
A. Well, I know –
MR. GARNER:
That’s not –
A. – you have even done work for my brother-in-law.
Q. Pardon?
A. You have even done work at times for my brother-in-law.
Q. Who’s that, I don’t –
A. Joe Edwards, Industrial Roofing.
Q. Probably have.
A. And, so, I felt that someone had completely misled you, because my mother was felt about as a saint in the areas that people knew her in, that she raised us children.
Q. Well, I’m sorry, I don’t think I asked the question, but if I did –
A. Well, I just wanted that to go on the record, because certainly there has never been a blemish against my
mother’s character. She was looked at as a saint of a woman.
MR. GEAN:
Is that all?
A. Yes.
MR. GEAN:
Okay. All right.
(DEPOSITION CONCLUDED)