1980 Deposition of Susan Alamo





I, Susan Alamo, hereby certify that I have read the above and foregoing deposition given by me in Case No.
CIV 79-2173, filed in The United States District Court, Western District of Arkansas, Fort Smith Division, DON WYLIE, ET AL V. TONY ALAMO, ET AL, on this ____ Day of March, 1980, consisting of one hundred, forty-three (143) Pages, and that the facts and matters therein contained are true and correct to the best of my knowledge, information and belief.





Q. State your name, please, ma’am.
A. Susan Alamo.
Q. Mrs. Alamo, my name is Charlie Garner, and I am the attorney for Don and Kathy Wylie and Richard Hydell. The purpose of this deposition is, as probably Mr. Gean has told you, for the purposes (not legible). That means just what it says, (not legible). It’s not for the purpose of asking you embarrassing questions, although some may be embarrassing both to me or to you, but that’s not the purpose of it. It’s rather to acquire information which I think will be useful in presenqint the plaintiff’s side of the lawsuit. If I ask you any question which you don’t understand, I want you to please ask me to ask it again, or repeat it, or ask the Court Reporter, because certainly if you don’t understand the question, it would be impossible for you to give a proper answer. So, please feel free to confer with Mr. Gean at any time you want to or ask me to repeat the question, or the Court Reporter. So, with that understanding, we will proceed. Incidentally, would you rather me to call you Mrs. Alamo or Mrs. Susan or what had you rather, however?
A. It really doesn’t make any difference.
Q. All right. Thank you. Mrs. Alamo, when were you born?
A. I really don’t know.
Q. Do you–where do you think you were born?
A. Either Fort Smith, or Joplin, Missouri. And I’m not sure which.
Q. Do you recall or do you have any idea as to the year?
A. No. I went–my first year of school with Roy Gean, you could ask Mr. Gean, and I’m sure he would know more about it than I would.
Q. All right. Where is your first memory of being in Fort Smith or Joplin?
A. Fort Smith.
Q. And did you start to school in Fort Smith?
A. Yes. My father died in Van Buren. I was two-and-a-half years old when he died. And I understand that I started to school at DuVal at five.
Q. All righty. What do—
A. But there are no records of my birth, so I don’t know.
Q. How old do you consider yourself?
A. Twenty, going on twenty-one.
Q. Well, when—for purposes of Social Security, how old are you?
A. I don’t have any Social Security, I’m a housewife. Twenty, going on twenty-one.
Q. All right. When did you start to school at DuVal?
A. I was five years old. I don’t know–I don’t know the year. Mr. Gean would know, I–I don’t know. I don’t remember the year. As a matter of fact, we have discussed it and I don’t know. Q. All right. Do—what was your name when you were born, please, ma’am? A. Mr. Garner, I was Susan Fleetwood, you see I am an Indian. I was Susan Fleetwood, from the time I was 15 years old, until I became Susan Alamo. So, you’re asking me about something, Let’s say, from fifty to fifty-five years ago. My name is Susan Alamo.
Q. Do you know the name under which you were born? A. I know what people say, but that would be hearsay, you know, and –
Q. That’s all right. Tell me what people say your name was?
A. Well, Mr. Gean, I don’t see that that has anything whatsoever to do with this case he’s talking about something from fifty to fifty-five years ago.
Q. Well, what were you known as in school?
A. Edith.
Q. Edith, what, please, ma’am?
A. Horn.
Q. Who?
A. Horn.
Q. H-O-R-N?
A. Right.
Q. Mrs. Alamo, what was your father’s name?
A. My father is deceased.
Q. I understand. But what was his name when he was living?

Charles, is that material?

Yes. Sure.

To this particular lawsuit?

Sure. I’d hate to pick a juror that was her father’s best friend.

Well, that’s true. In that light, yes, that’s fine.

A. I don’t think you would do that, Mr. Garner. You see, my father enlisted in the Armed Forces to defend this Nation, and he sailed with the first ten thousand, and fought in Division Number One with General Pershing’s groups, so I was born several years after that, after he came back from the service. My father has been dead since I was two-and-a-half years old, so the probabilities of your finding anyone in the local area that was a friend of my father’s would be–

Q. What name did your father go by?
A. My father’s name was Samuel Edward Horn.
Q. And what was your mother’s maiden name, please?
A. Mr. Gean, what—

If it’s in regard to deciding a jury, that would be all right.
A. McAlister.

Q. What was her given name?
A. Geneva.
Q. And were they both from around here?
A. No. My father was originally from the east, and my mother’s family pioneered the Ozark Mountains.
Q. In what area, please, ma’am?
A. From McAlister, Oklahoma; Gravette, Arkansas;
Benton, Arkansas; the whole Ozark Mountain region, and have intermarried into families for years. I understand that the Lucases also were relatives of my father, that, I’m very vague about. I really don’t know them.
Q. All righty. So, you started to school at DuVal in Fort Smith, Arkansas, do you recall what year?
A. No, I don’t.
Q. Do they have any records at DuVal?
A. I really don’t know.
Q. How many years did you go to DuVal?
A. One year.
Q. And then—that, I assume, would be the first grade?
A. No. I think they had a pre-school grade at that time.
Q. All right. Where did you start the first year, what we call—
A. DuVal.
Q. —first grade?
A. First grade at, oh, I don’t even know what the name of it would be. My mother purchased some property in the ridge area and there was a small local school near there. Do you know what that school would have been?

If you don’t know, just say I don’t know.
A. I don’t know.

Q. All right. And how many years did you go there, please?
A. I think one.
Q. You think one year there?
A. Yeah.
Q. And then, where did you attend the second grade?
A. Dyer.

Charles, what difference does it make about her going to school, or not going to school, as far as the lawsuit is concerned?

Well, some of her classmates may be on the jury,

Well, that’s possible.

Sure it is. My age and your age—

Is that what you’re trying to find out, Charlie, just in regard to—

Yeah. Background material, sure.

—interrogation concerning the prospective jury.

Sure, sure, of course.

Okay. We’ll have jurors from down in that area.

You’re right, we will.
Q. Now, Mrs. Alamo, you went to the second grade at Dyer, you say?
A. Yes, now–I am really vague on it. You are talking about a long time ago. I think I went one year to a little local school, in that ridge area. The school has been torn down, I understand, for years, and I don’t even remember what the name of it was.
Q. Were you living in that area at that time?
A. My grandfather and grandmother and my mother purchased a lot of property up in that area. My dad left quite a lot of money at the time he died and my mother purchased quite a lot of property in that area.. And my grandfather and my grandmother maintained that farm, and we went to school there, I–I am not sure; I think it was one season. I had a teacher, Hazel Inman.
Q. All right. And then where did you go to the second year to school?
A. It must have been Dyer.
Q. And the third?
A. Dyer.
Q. What school do you recall going to or attending after Dyer?
A. None, night classes.
Q. Well, I’m talking about as a–as a juvenile?
A. None.
Q. How far did you go to school in Dyer?
A. That was eight grades, I think, seven or eight grades. I don’t even remember that.
Q. Through the eighth grade, you think?
A. I don’t know. I think it was seven or eight grades, and I don’t remember, because most of my education I got years ago in night classes at–

You don’t need to go into that.

Q. No. Where did you go to high school then after you left Dyer?
A. No, I didn’t—I didn’t attend high school.
Q. You did not attend high school. And when you were in Dyer, I assume that you went–you just told me approximately the eighth grade, you would be about what, then—thirteen, fourteen, fifteen years old, something like that?
A. No, I wasn’t that old. I had gone to DuVal, Mrs. Zinneman placed me in the second or third grade during the first year, I don’t remember, and then I made two grades at Dyer somewhere along in there, I don’t remember exactly when. I had tuberculosis when I was nine years old.
Q. And who treated you for that, please, ma’am?
A. Dr. Kennedy.
Q. At where?
A. St. Edwards Hospital.
Q. Were you cured?
A. The Lord cured me.
Q. All righty. How long did you have TB?
A. My father died with tuberculosis. He contacted it from poison gas overseas in Europe.
Q. Well, you had it–you told me you had it when you were nine. And I asked you the question, how long did you have it?
A. Well, I was—I was saved and baptized, for six months, somewhere along that period of time.
Q. And along–this would be when you were nine or ten?
A. I was nine years old.
Q. And you think you were cured when you were nine?
A. Yes, I do.
Q. All right. And did you have any other diseases up until, say, you were fourteen or fifteen years old?

Now Charles, I’m going to object to that. You don’t have to answer that, diseases hadn’t got anything to do with this.

Well, she was the one who brought it up, Roy, I wasn’t trying to—

She was talking out loud, trying to figure out how long she was in school—


–in Dyer.

Q. But do you recall finishing–did they have a graduation ceremony, Mrs. Alamo that you recall?
A. No.
Q. Had—do you recall why you did not go to high school?
A. No.
Q. All right. When was the first time you married, please, ma’am?

I object. I am going to object to any activity of Susan Alamo’s until the time the Alamo Foundation was organized. I think it’s not relative under the rules, Charles, and I’m going to instruct you, Mrs. Alamo, not to answer anything, other than basic questions concerning who you are and where you lived in regard to your life, and except since the foundation of the Alamo Foundation, which is one of the party Defendants and which is your activities in the Alamo Foundation is the basis of this lawsuit.

Q. Mrs. Alamo did you–do you have any children?
A. Two.
Q. And what are their names, please, ma’am?
A. Mr. Garner, I have a son, who is a business man. Christian Foundation has nothing whatsoever to do with that.
Q. What—what is–just give me his name.
A. He knows his name.

Q. Well–I–we can–it’s a proper question.
A. Charles Brown.

Q. And where is he, please, ma’am?
A. All right. He’s a sales person.

I don’t think that’s material, you don’t need to answer that. If you want to take his deposition, why, Charles, we’ll try to get it for you and your daughter’s name?
A. Susan.
Q. Brown?
A. Mick.

Q. How old is Mr. Brown, your son?
A. I really don’t know.
Q. Do you recall when he was born?
A. Yes. I’m fifteen years older than he is.
Q. But you don’t know how old you are?
A. No.
Q. So, therefore you don’t know when your son Charles was born?
A. No. I don’t.
Q. How about Susan?
A. Susan was born in 1950.
Q. Do you recall the date?
A. August.
Q. Where is she now, please, ma’am?

Now, that’s not material. The location of your daughter has nothing to do with this lawsuit. We’re not going to have her found and brought into this, unless the Court tells us to.

Q. When—when did you divorce—when did you marry Mr. Brown’s father?

That’s not material, hasn’t got anything to do with this lawsuit, whatsoever.

Q. What was Mr. Charles Brown’s father’s name?

Charles, how, all this happened, if you want to go into matters from the time of the Alamo Foundation was organized, that’s fine. But anything prior to that time, we’re going to object to. Now, that was more, much more than ten years ago. I think it was going on eleven–eleven or twelve years ago that the Alamo Foundation was organized.

Well, Roy, of course, we don’t need to argue. That’s the reason I wanted the Judge here.

Well, he’s not here.

I understand he isn’t.

I was–I was under the impression that he was going to be here, too, Charles.

I wonder if Judge Miller is down there?

I don’t know, I’m sure he isn’t. He hasn’t been back to the office since he–he can hardly walk, he can’t–

I thought he came down some.

I don’t think so, Charles, not in the last month.

In other words, you’re telling me for the purpose of the record that nothing prior to the date that the Susan Alamo—Tony and Susan Alamo Foundation was formed, or incorporated, you’re telling–instructing both of them not to ask–answer?

No. You have asked some questions that have occurred prior to that time, Charles, and we have allowed that, but other matters—you ask them and I’ll object to them individually. Basically, the matters concerning the lives of these people prior to the Alamo Foundation, which is the central theme of this lawsuit. The activities of these people in relation to the Alamo Foundation concerning your clients, that’s the theme of this lawsuit, is not relative under the rules and we’re going to object to them.

Well, for instance, Roy, she told me originally that her–she had two names, Susan Fleetwood and Susan Alamo, I have information that now that her name at one time was Susan Brown, and I also have information that her name—she had another name.

Well, if you want to question her about her activities in the Mulberry area, or in this area, where you are going to have jurors, that’s fine.

Q. Well, okay, that’s what I’m asking you. What was your–Mr. Brown’s name?

Well, these–I think there needs to be some preliminary questioning to that as to whether or not, she–when she left this particular area, and when she came back to this area, Charles.

Well, I tried to find out when Mr. Brown–

You’re not going to get any juror’s from outside of the State of Arkansas that I’m under the impression that all of the things you are now questioning her about occurred outside the State of Arkansas,

Well, I understand that Mr. Brown’s father still lives in Alma. Now, that’s my information and I can’t find it out unless I ask her, Roy.

A. I was a fourteen-year-old girl. I do not know whether that man is dead or living. I have not seen him since I was fourteen years old.

Q. What was his name?

Did she give you the name of Mr. Brown?

No. She gave me the son’s name.
A. Well, I’m not going to answer that because Mr. Gean has told me not to and I don’t see that it has any bearing, whatsoever.

Q. How long has he been gone? How long have you— when’s the last time you saw him?
A. I was fourteen years old.
Q. So, that was more than fifteen or twenty years ago?
A. I would say so, yes.

Well, Roy, my information is that he still lives in Alma. Now, I don’t know whether he does or not.

Q. Do you know where he lives in Alma?
A. No, I don’t.

Well, I —
A. Nor have I seen him.

I don’t even know who he is.
A. I would not recognize the man if I met him on the street.

Okay. Are you instructing her not to answer?

She says she doesn’t know where he lives.

Well, I’ve asked for his name.

Q. What was his name, when you were fourteen years old, as best–
A. You told me not to answer.
Q. Well, go ahead and answer that.
A. Tom Brown.

That’s the information I have, and my information, again, Roy, is that he lives in Alma,

Well, he might do that.

I don’t know.

She said she didn’t know.

Q. All right. That, I take it, was your first marriage to Mr. Tom Brown?

Now, Charles, we’re not going into the marriage of this person–this woman, unless the Court instructs us to do so, unless you want to ask her if she had any other husbands that lived here in the State of Arkansas with her. I would be willing to let her answer that question.

Well, if you could prove to me that they didn’t have any relatives, Roy, or they weren’t know, or–

Q. Did you have — were you married to anyone that has lived in the State of Arkansas, other than Tom Brown and Tony Alamo?
A. Never.
Q. Do they have any relatives here?
A. None.
Q. Do you know of any relatives of Tom Brown that lives in the State of Arkansas?
A. Oh, I don’t–I would imagine there would be several of them.
Q. But do you know who they are and where they would be located? A. Not at all. I know one sister that lives in Fort Smith.
Q. Of Tom Brown? Is that the only relative you would know–
A. Yes, I don’t—

Q. What’s her name, please, ma’am?
A. Isaacs.
Q. First name?
A. Pauline.

When did Judge Williams say he’d get back?

He’ll be back here the twenty-he finishes in Harrison on the 28th day of April and will be back here sometime in May.

The what day of May?

Sometime in May,

Where will he be going?

He’ll be in Harrison, Arkansas.

All that time?

That’s what I was told. He will finish in Harrison, Arkansas, on about April the 28th and will return to Fort Smith, sometime in May. Today he is in Omaha, Nebraska, at some sort of a Chief Judge’s meeting.

Q. Do you recall your first place of employment, Mrs. Alamo?

Now, Charles, if it was in the State of Arkansas, tine, of course, people that were employed with her now are entitled to know, if it was in the State of Arkansas and they were prospective jurors.
Q. Was that in the State of Arkansas?
A. No.
Q. We are going to object to that.

Well, Roy—

Unless you can show some relationship.

Well, Roy, you understand that part of this course of action took place in California, as you well know, Roy, I hope you know that.

Well, anything after the Foundation Organization, fine.
We’re willing to go into that.

All right.

But you’ve asked about her first place of employment.

Well, is there some reason I shouldn’t know, I mean—

Well, I just don’t think its relative. And I don’t want to go into matters that aren’t relative, I don’t think that it’s proper, that’s the reason that the laws say that matters not relative are not to be presented.

The law says either relative or might be relative, Roy, the way the law says.

Well, we’ll submit it to Judge Williams.

Well, we’ll have to.


Or some federal Judge.

All right.

Because there is no need of me continuing to continue to ask questions and get answers such as I’ve had.

Well, I have told you that we are willing to answer questions that have to do with this lawsuit.

From 1969, forward?

No. We are willing to answer others that have to do with this lawsuit, about some relative—

Of course. Who is to decide whether or not it’s–

Well, I’ll have to decide now and, then, there’s a federal Judge that will decide if you want to present it to him.

Okay. Okay.
Q. You stated that your name was Mrs. Fleetwood, Susan Fleetwood?
A. I said I worked under the name.

I don’t think she said Mrs. Fleetwood.

Q. Oh, I’m sorry. Susan Fleetwood.
A. Right.
Q. All right. How did you acquire the name Susan Fleetwood?
A. I am a relative of the Fleetwood.
Q. Who–
A. My great-grandmother was a Fleetwood.
Q. All right. From over here around Roland—
A. Yes.
Q. Muldrow, that area?
A. Red Cloud.
Q. Was Rex Fleetwood one of your relatives?
A. Yes.
Q. You were never married; I take it, to a Fleetwood, then?
A. No. I was never married to a Fleetwood.
Q. And how long did you go by the name of Susan Fleetwood? A. Many years.
Q. During what span of time, please, ma’am?
A. Many years. From the time I was fifteen until Tony and I were married. I used the name Fleetwood professionally.
Q. Was that the only name you used from the time you were fifteen, until the time you and Mr. Alamo were married?
A. No.
Q. What other name did you go by?

Charles, does that matter?

Well, Roy, it could.

Tell me why it’s relative.

Well, how can I find out about her unless I know what name she went under?
A. Well, I ‘didn’t know you were supposed to be finding out about me.

Q. Charles, if it’s not a name, did you use any other names in the State of Arkansas, other than the ones you’ve already given?
A. No.
Q. You’ve professionally been involved in other activities in other states?
A. Yes.

Of course I want to know what that professional activity is, Roy. I understand she was a singer, or a dancer. I don’t know that it’s true, but I’m entitled to find out.

I think you can find out her occupation, that’ll be all right. I won’t make any objection to that.

Well, I—that’s all I’m trying to find out.

Well, you’re asking about different names that she might have used.

Well, how can I find out what her occupation is, where she worked and so forth, unless I do?

I’ll let you ask her about her names and where she worked.

All right.
Q. What–I think my last question to you, Mrs. Alamo, was that, did you use any other names between the time you were fifteen and the time you married Mr. Alamo and you told me yes. Now, I’m asking you what those other names were.
A. I don’t remember.
Q. All right. What profession were you in when you were using the name Susan Fleetwood?
A. You’re talking about something a long time ago, that involved an awful lot of different things, I don’t remember.
Q. Well, I–you’ve just heard me say, I had understood from someone, and I don’t know who it was, that you were a singer and a dancer under the name Fleetwood.
Is my information correct?

Is that before the Alamo Foundation was organized, Charles?

I don’t-really know.

Well, I don’t see that that’s material until– unless it’s after the Alamo Foundation was organized.

Q. All right. Did you give me the names other than Fleetwood?
A. I told you I don’t remember,
Q. Were you married to any one other than–

Now, Charles, we’re going to object to that unless you ask it in such a way that it has to do with since the Alamo Foundation has been opened.

Mrs. Alamo–Roy, for the purposes of the record, I’m going to do what you suggested here, it seems that we are not getting anywhere and the Court Reporter is charging us by the word here, and there’s no need of me going in and having you keep interjecting and say you are not going to answer and have her confer with you. So, I’ll try to get along as best I can from 1969 on, I suppose.
Q. When was the Susan Alamo—Tony and Susan Alamo Foundation formed, Mrs. Alamo?
A. We were in operation for three years before, or maybe four, before we applied for—three years before we applied.

A charter?

A. I don’t remember, honey. I don’t remember.

Q. Well, ask him, ma’am, if you’d like.

She said three or four years, is that right?

A. Yeah.

Well, I thought he mentioned five.
A. Well, it could very possibly be.

Q. I make no objection, I just want to know.
A. I didn’t make a statement, I asked a question. He is possibly right.
Q. Well, it would be several years, at least.
A. Yes.
Q. And where was this operation you mentioned, please, ma’am?
A. Hollywood,
Q. What year do you–could you best estimate that this foundation or operation, I believe you called it, was formed?
A. The charter or the operation?
Q. No, ma ‘am, the operation.
A. Oh, about fourteen years, no, thirteen–fourteen.
Q. That would be putting it–fourteen years would put it in ‘66?
A. Well, you see, I’m not positive about those I’m saying it would be in that frame of time, some- where.
Q. All righty. I understand. I have trouble thinking, about what happened in ‘66 myself, Mrs. Alamo, that’s not unusual.
A. Yes, I know.
Q. But if you can refer to it as some two or three, four or five years prior to the time that the articles were actually filed, then it would be within that time or frame work.
A. In that frame work.
Q. What did the operation consist of prior to the actual filing of the articles?
A. It consisted of going out into the streets and walking up to drug addicts and hippies, and saying, why are you destroying your mind, your soul and your body, don’t you realize that this is the reason why Jesus died, that you can have life and have it more abundantly? And pointing out the alternatives of the type of life that they were living, that the inevitables were a mental institution, a prison ward, or a marble slab; where, on the other side, there was eternal life through Jesus Christ; and asking them i£ they would like to exchange the lives they were living for One that was-life, and life more abundantly, and we found that they were like sponges, they were ready to make that decision.
Q. How many of you were there in this operation at that time, Mrs. Alamo?
A. Tony and I.
Q. Just the two of you. When did you and Mr. Alamo meet, please, ma’am?
A. About, well–this was before the…the–

Q. Foundation?
A. The Foundation, yes.
Q. Than how much before?
A. Tony and I have known each other for years around Hollywood. We knew all the same people.
Q. When were you married?
A. Tony’s father was a choreographer.
Q. When—he’s not asking you all that, when were
you all, married?
A. ‘66.

Q. Where, please, ma’am?
A. Three times.
Q. All right. Where was the first one, please, ma’am?
A. Mexico.
Q. Where in Mexico?
A. Some small town in Mexico. We wanted a church wedding. We went to Las Vegas and we worked for six months to have a church wedding, we were married in a Baptist Church in Las Vegas.
Q. All right. And where was the third time, please, ma’am?
A. The third–the first time was–as a matter of fact, Tony bought two marriage licenses in one day.
Q. Where, please, ma ‘am?
A. In Las Vegas, because I didn’t feel that we were married with the Mexican divorce and marriage, so I wouldn’t sleep with him. He purchased two marriage licenses in one day. We were married first by a Justice of the Peace and we were married that evening in a big Baptist Church. You’ll find both those licenses there.

In Las Vegas?
A. Right.

Q. Do you recall the date that this occurred?
A. Yes. It was August the 20th.
Q. Of 1966?
A. Right.
Q. And what name did–under what name did you appear on the marriage licenses? A. Do I nave to answer that question?

Yes. That’s all right.
A. Susan Lipowitz.
Q. Susan Lipowitz?
A. Right.
Q. Now, how do you spell Lipowitz, please, ma’am?
A. You spell it with a “P”, Hebrew, pronounced with a “B”.
Q. Well, that don’t tell me much.
A. I’m not going to do your homework for you.

Spell the last name for him.
A. No. Let him—I’m not going to do his homework for him.

Well, he has the right to ask that. What’s the —L-E–
A. You don’t know how to spell Lipowitz?

Q. I go L-I-E-B-O-W-I-T-Z.
A. I only finished the eighth grade.
Q. Yes, ma’am.
A. You’re an attorney.
Q. Yes, ma’am. Did I spell it correctly?
A. L-I-P-O-W-I-T-Z.
Q. I-P-Z?
A. “T” as in Tom.
Q. All right. And what was the occasion for that name?

Is that material?
A. No.

Is it, Charles?

I really don’t know, Roy, yet. .

Well, this is even before the Foundation. Now, let’s go back to when—

No. I understood that the Foundation was formed before she and Mr. Alamo were married.

I think it was in “66. She’s talking about they were married.

Yeah, I know.

That’s when they started their organization.
A. Well, he’s talking about a person that I really had very, very little dealings with, had hardly seen him for a period of time.

That’s not necessary for you to go into that. You’re former- -you were married– don’t know how many times you were married, I don’t think it is material and we’re going to object to it.

You’re not going to allow her to answer to the name of Lipowitz?

I don’t think its material. That’s the name that’s on the marriage license.

Q. Okay. And are the marriage licenses, please, ma’am, recorded in Las Vegas?
A. Oh, yes, sir, both of them.
Q. Do you recall where in Mexico?
A. No, I don’t.
Q. Do you recall when?
A. It was in ‘65.
Q. Do you recall what town?
A. Yeah. It was a small town out of–oh–what is the–right out of San Diego, in one of the small towns there.
Q. Tijuana?
A. In that vicinity.
Q. Do you recall it as being Tijuana?
A. No. It wasn’t Tijuana.
Q. It was not?
A. No. It was one of the small towns around there.
Q. Well, as I recall, is Tijuana the first town you come to after you leave?
A. I think so. I’m not sure about that. I’ve never cared about any part below the border and—

If you don’t know, just say you don’t know.
A. —I could not truthfully tell you and there’s no use in me even attempting, because I felt that it was a complete farce, to begin with, and that it had no actual meaning whatsoever.

Q. All righty. After you all were married in Las Vegas, I understood you to say that you all had worked there six months, what were you doing there, what was your occupation there?
A. We were employed.
Q. Where please, ma’am?

What difference does that make, Charles? Well, you organized the foundation—

You’d organized the foundation when she and Mr. Alamo were married they—

A, January of “69.

Q. That’s when you organized it?
A. Yeah.
Q. Chartered, but you all were actually involved in the operation before then?
A. We were soul winning, yeah. We were soul winning.

Q. Where were you employed in Las Vegas, you and Mr.—
A. Well, I don’t see and I hope that my attorney doesn’t see.

Well, I don’t see that it’s material, Charles.

Well, now, I understood that they were operating the Foundation, at this time.

Q. Were you?
A. No.

A. We were just witnessing.

A. No. We were evangelizing, as a matter of fact; we were the speakers for the Full Gospel Christian Business Mens. We were speakers for the CBMC, the largest Southern Baptist Organizations, for various mission works and operations. But, no, the Foundation had not been–the charter of the Foundation had not been established until ‘69.

Q. I understand. But you told me that you and Mr. Alamo were operating in behalf of the Lord some two, three or four, or five years prior to that time.
A. I’ve been doing that for a long time.
Q. All righty. But you and Mr. Alamo were together?
A. Right,
Q. For that length of time.
A. Right. We were–
Q. And you were–
A. Witnessing everywhere.
Q. Witnessing and so forth?
A. Holding evangelistic meetings.
Q. Yes.
A. And–
Q. Now, I am asking you where you were employed at the time you and Mr.—

She said, Charles that she was—they were involved in evangelism, going from meetings to meetings.

Q. Oh, you weren’t employed then, I take it?

That was their employment.
A. We were in evangelism, we were going from meetings to meetings, we were employed.
Q. By whom?
A. Self-employed.

Q. Is that an evangelistic endeavor?
A. No, no, no, Tony had management of an operation, which has absolutely nothing to do with anything about us today, whatsoever.
Q. Was he involved in the Foundation?
A. No way. No way.

Okay. Well–

Q. What kind of operation?

Now, Charles, we are not going to go into anything that these people did before the Foundation was organized and they were involved in it.

Well, I mean, she said he was managing some operation, I’m just wondering if it–
A. Well, it wasn’t a gambling casino.

Q. You don’t have to go into it, it’s not material. Did it have anything to do with the Foundation?
A. Nothing.
Q. Or leading up the Foundation?
A. Nothing whatsoever.

We are going to object to it, Charles.

Q. How did you come to the form, then–

With that understanding, Roy, I’m going to–I guess you want me to get to ‘69. You don’t want me to–

If they were involved in the organization of the Foundation before it was actually incorporated, I think you can go into that.

They told me that they did it two, three, four, or five years prior to the date the association was formed.

Well, I don’t know—what she means was, I don’t think that she means that they were actually involved in–
A. I said that we were evangelists.
Q. –the Foundation, they were witnessing and doing things of that nature. Whether that was a foundation, I really don’t know. But they were witnessing before that.

Well, what’s the difference in witnessing before the Foundation was formed and witnessing afterwards?

Well, one was on behalf of the Foundation, through the vehicle of the foundation, and the other was just personal appearances and things of that nature.
A. That’s right. Just personal evangelism.

I guess. The way it appears to me from what she has said.

Well, are you still going to keep me from asking questions from ‘66, say, from the time they got married, up until– want to know where they lived, what they did, where they got their money, how they got it, and everything about them.

Well, I don’t think that’s material, unless they had some connection with your clients, Wylie–the Wylie’s and Hydell’s.

Well, obviously, they did.

At that time, in ‘66? I don’t know, it hasn’t been asked yet, I never asked them that.

All right. I’ll—
Q. Which one of the three of the Plaintiff’s that I represent, Mrs. Alamo; Don Wylie, Kathy Wylie, or Richard Hydell, did you meet first?
A. Kathy.
Q. And where did you meet her and when?
A. It was in ‘66.
Q. Where did you meet her?
A. A boy picked her up off the street.
Q. What boy?
A. Just a boy–a Christian boy around Hollywood, I don’t even remember what his name was. She was sleeping in ladies’ restrooms and she said she hadn’t had any food for a couple of weeks.
Q. How old was she at the time?
A. Mr. Garner, I don’t know.
Q. Was she on dope, was she a dope addict or user?
A. Oh, they were all messing with drugs, whether she was–you know, whether she could have been considered a user or not, I don’t know. She–the typical hippie type with the toothbrush in her pocket and sleeping in restrooms, without a change of clothes, whether–you know, I—
Q. She had no job then, I take it?
A. No.
Q. And at that time, were you and Mr. Alamo married?
A. No.
Q. You were not married at that time?
A. No.
Q. Where were you living at that time?
A. I had quite a large…very ultra modern apartment in Hollywood. And I took her in, I felt sorry for her.
Q. Do you recall the address of this—
A. No, I don’t.
Q. —apartment in Hollywood?
A. No.
Q. Do you recall where Mr. Alamo was living at the time?.
A. No, I don’t.
Q. Pardon?
A. No, I don’t.
Q. Well, you knew each other?
A. Tony and I have known each other for years around Hollywood and Beverly Hills.
Q. Well, you were dating. I guess that’s a good way to put it at this time, weren’t you?
A. Yeah. But we had known each other long even before that. We knew the same people. The Hollywood area is like Alma, you know, to the people that really live there, it’s like a small town, everybody knows everybody.
Q. Well, was Mr.Alamo living in Hollywood at the time?
A. Oh, yes.

At the time Chat she met Kathy?

A. No, I don’t think so. I think he lived in San Francisco at that time.
Q. All righty. So, you took in Kathy in 1966, do you recall the boy’s name that picked her up off the street?
A. I couldn’t tell you if my life depended upon it. It was just one of the hippie boys, that had become a Christian, and it was during the Christmas Holidays, and he found this girl wondering down Hollywood Boulevard, that hadn’t eaten for two weeks, and she was crying, and they were putting up the Christmas trees on Hollywood Boulevard and she told us later that she had kept crying out in her heart, and saying, I believe that there must be a God, if there is, help me. And the boy saw her and saw her crying and he went to her and he said they were holding some evangelistic services up here, why don’t you come with me? And he brought her, and that was the first time I ever saw Kathy.
Q. Were you one that was holding the evangelistic services?
A. Yes.
Q. Where, please, ma’am?
A. It was Wilcox—I couldn’t tell you the address, if I had to.
Q. Was it in a tent or a building–
A. No.
Q. Or a—
A. It was in a building.
Q. Or a theater?
A. A building, building. We were just going out into the streets. I had been doing that for years, that wasn’t anything new for me, I had been doing that for years. And she didn’t have anyplace to go. I fixed food for her, I fed her, Mr.Garner, I adored the girl.

You’re volunteering a lot of information; just try to answer his questions so we won’t elongate this thing. I must ask you to get right to the point on his questions. If he wants to know about it, he can ask.

Q. Was the building on Wilcox under rent?
A. Yes.
Q. You were renting it?
A, Uh-huh (yes).
Q. As an evangelistic hall?
A, No. No. It was–they were modern apartments at that time. It’s a sort of a rundown area now, but they were very modern apartments with pools at that time. No, it was an apartment.
Q. You mean the Wilcox Building, where you were — is preaching a fair statement, Mrs. Alamo?
A. I wasn’t preaching there, Mr. Garner. We were witnessing.
Q. Okay. Witnessing then. Were–
A. I had evangelistic services all over the country. I was speaking at–again I’ll go back and tell you again, CBNC and Full Gospel Christian Business Mens, churches, large evangelistic groups, even missions, on the lower east side of Los Angeles.
Q. Well, this ministering, that you were talking about, when you first brought Mrs. Wylie, was on Wilcox street and it was in your apartment, I take it?
A. Yes.
Q. How many were there at that time that you were ministering to?
A. Let me tell you. I picked up about ten of those urchins, and I had all ten of them.
Q. All righty, and were they all living in the apartment on Wilcox?
A. No, but I fed them there. Kathy, I kept there.
Q. Did you know her as Kathy at that time?
A. No.
Q. What did you know her as at that time?
A. Phyllis Gromoski.
Q. All righty. And Phyllis Gromoski and Kathy, as we are talking here, are one and the same person, correct?
A. Well, from what she says.
Q. Pardon me?
A. From what she says.
Q. Well, I mean we’ve been talking about Kathy all the time and you just told me that you knew her as Phyllis Gromoski?
A. Yes.
Q. So, it must be the same person, right?
A. Yes.
Q. Now, you kept her there, does that mean that she made her home with you?
A. No. I kept her there for about, oh, I would say about a week, and the police came up and arrested her and they took her to jail.
Q. And what did they arrest her for, do you recall?
A. She had—she had been hanging around…she had been hanging around a place in Hollywood that they sold liquor. And–
Q. Was she–how old was Ms. Kathy at this time?
A. Well, I would presume that she was a minor, because she was arrested as a minor.
Q. All righty. And she was taken to jail. How long did she stay in the jail?
A. Oh, Mr. Garner, I don’t know. I would say—

Don’t guess, if you don’t know.
A. I would say a month. I got attorneys and everything to try to get her out of it, to try to get her out of there.

Q. Well, did you ultimately bail her out or did the attorneys bail her out, or—
A. The attorneys. They eventually got it reduced. They reduced the charge, and I think it was finally reduced to just a minor being in a –
Q. Bar or something?
A. I would say. See, I—I hate to answer anything that I’m not that positive about, but I know that the charges were reduced and I brought her back to the apartment.
Q. Well, it’s perfectly all right, Mrs. Alamo, for you to say I think this is what happened, or–
A. Well, I do think.
Q. And I think she was a minor at the time, and I think that–
A. I’m not–

But you’re under oath, swearing to these things, too, Mrs. Alamo and if you don’t know, say you don’t know.
A. Well, I’m saying that I don’t know. I’m being very vague because I am, and, now, she could have been in jail for two weeks, she could have been there for a month, she could have been there for sixty days, I am not sure but I know that there was a reduction on the original charge and that we were able to get her out of there and I took her back to the apartment.

Q. Was she fined or was she sentenced, or do you recall?
A. I couldn’t tell you that, if I had to. I just don’t remember, I don’t remember.
Q. All right. So, you got her out and brought her back to the apartment and then what happened?
A. Oh, she hung around there for a couple of weeks and she met a fellow and–
Q. What happened?
A. She went to live with him.
Q. Who was the fellow she met?
A. A man by the name of Eddie Seay.
Q. Eddie Seay?
A. Uh-huh (yes).
Q. And do you recall where they were living, where they went to live together, Mrs. Alamo?
A. Tony and I were gone. Tony and I went away and we were gone for–from around that vicinity there. I would say maybe six months. We were walking up Hollywood Boulevard one day and we met Kathy, it was pouring down rain, she hardly had on enough clothes to keep her from freezing to death and said she was hungry, she said that this boy, this man that she was living, with, had broken this leg and that she only had enough money to get a sandwich for him. We took her across the street to Howard’s-it’s a Howard Johnson’s now, but I don’t think it was a Howard Johnson’s at that time.


A. Hody’s, that’s right.
Q. Hody’s?
A. Hody’s.
Q. How do you spell that now?
A. H-O-D-Y-S.
Q. H-O-D-Y-S. All right, go ahead.
A. And we fed her. And while we were feeding her, I talked to her. And she said that she had had a little job as a waitress, but that something had happened, that she had lost her job and that she had worked a very, very short time. Something had happened and she had lost her job. But their rent was due, that Eddie had broken his leg and I said, Well, Kathy, you know it’s obviously that, you know, you’re not doing any good the way you’re going and just, you know, there can’t be any good come from it. You’re living in adultery, there isn’t any–you have no–obviously, there is no advantage to this arrangement to you, whatsoever, and it’s destructive. We drove her back to the apartment, it was raining.
Q. Still on Wilcox now?
A. No. No. They were living over in a building across off Hollywood Boulevard and more towards the Santa Monica–more towards Santa Monica, in that vicinity. Her sister, Mary, a married man by the name of Buddy Wayne, the father of six children that had hung around Hollywood. Kathy and Eddie were living together. There was no furniture in the house. There was no gas, there was no lights, there was no water. I begged Kathy to come with me and she did.
Q. Well, when you say begged her to come with me, you mean come with us, would that be more proper?
A. Right. Right.
Q. And where were you and Mr. Alamo living at that time?
A. Malibu.
Q. And did she move with you or come with you?
A. Mr. Garner, I used the word, me, because Tony was never fond of Kathy.
Q. All right. I wasn’t trying to—you had just simply said that you and Mr, Alamo were together, we met her, the rain, and she was cold, and that you all took her somewhere and fed her–
A. I also begged Tony to let me take her home with me.
Q. Okay. Fine. And he did, I take it?
A. Well, he did and he didn’t.
Q. All right.
A. You know.
Q. But at any rate, you exercised a woman’s prerogative and–
A. Right. And–
Q. —and took her?
A. And I took her.
Q. All righty. And at that time you were living in
A. Yes. This must have been, really some two years later, actually. It would have to have been about two years later from the time I had seen Kathy, from the time I had got her out of jail. It must—it would be in that frame of time, from–I would say close to two years.
Q. All righty. It would be approximately ‘68, then?
A. Yeah. Yeah. It would have been in ‘68, during the first part of ‘69, somewhere along in there.
Q. So, you took her to your apartment, or did you have a home in Malibu?
A. Home.
Q. Home in Malibu. Did you own the home?
A. Yes.
Q. You–I take it, it was in both yours and Mr. Alamo’s names?
A. Yes.
Q. Joint tenants, or—
A. Uh-huh (yes).
Q. Husband and wife, so forth. And did Kathy move in with you at that time?
A. Yes.
Q. And how long did she stay living in with you?
A. Well, Tony and I were so caught up in our soul winning and our evangelism and we were using our money to feed the hippies, and we lost our house. We lost that house.
Q. You mean lost it, by what method, please?
A. Well, we really didn’t really care about keeping it, to be very truthful with you, because it was in the Malibu area and our work was in the Hollywood—Beverly Hills area, and we were spending most of our time over there. And, Mr. Garner, we would pick those kids up, they didn’t have shoes on their feet, most of them.

Now, you’re volunteering most of it. He’s not asking you that, answer his questions as briefly as possible, if he needs some information
A. But we spent—we fed them, we fed them and we clothed them and it seemed that if we got ten, the next thing we knew we had twenty. You know, the young people at the Foundation never worked for five or six years, after—even after the charter, we wouldn’t let them,

Q. Did Kathy continue at her work as a waitress?
A. No. Kathy got a little job at a pie house.
Q. A pie house?
A. Yeah. In Santa Monica. But that was a very, very short time. And after that, she got a little job in a tiny little restaurant in downtown Los Angeles, I think about ten seats or something like that. That, too, didn’t last very long, that was a very short period of time, both of them, very, very short period of time.
Q. Where was her next job at. Were you supporting her all this time?
A. That was her last job.
Q. The pie house and the restaurant, whichever one she lost first was the–
A. That’s right. That was her last job,
Q. By that, I take it to mean the last gainful employment she had?
A. Yes.
Q. Was she–what is your word, Mrs. Alamo, for becoming a Christian? Accept the Lord, or what is your terminology for that?
A. To be born again.
Q. To be born again? All right, was Kathy born again?
A. Mr. Garner, I thought she was.
Q. When?
A. I thought she was. Can I explain the reason why—

Don’t explain anything, just-

I have no objection, Roy.


If it would suit Mrs. Alamo better, let her explain it. I’m not trying to tell her—

You’re paying for all this, Charles, for her thoughts.

That’ll be all right. She’s got an idea in her mind about what she wants to say.
A. Well, I want to be truthful with you. I don’t want to just simply answer questions that I don’t know what I’m saying—

Q. Well, you said you thought she was. That’s about, she was—
A. I thought she was. I–Kathy, when she first came, told her story of how she came from a family of fifteen kids. The mother and father were both alcoholics, that the father had raped the little girls from the time they were infants.

Q. Including Kathy?
A. Oh, yes.
Q. All right.
A. That if they told the mother, the mother was an alcoholic, she would take their hands and put it over the fire and accuse them of lying about their father. That they were—well, that actually, two or three of those children were supposed to have been killed, buried in the back yard, the mother and father going to jails and they put them into orphanages, and so on and so forth. The reason I am telling you this, Mr. Garner, I always made every excuse in the world for Kathy. I fought Kathy’s battles all these years, because every time anyone went after Kathy, now, she would say that they would get out of the jails or wherever they were incarcerated, and that the only food they would have would be cases of vegetables, without any labels on the cans, and they would eat cold in the morning, and maybe two cans of beans, a can of peas, two cans of tomatoes, whatever. This broke my heart, you know, I mean the thoughts of little kids being thrown into an old car, dragged by drunks, back and forth across the country. Everything that Kathy became involved in, I always found an excuse for Kathy. When every body else was after Kathy, I always said, Look at the way she was raised. She never had a chance.
Q. Well, do you think that she was born again during the first visit with you?
A. Yes, I do.

Just what visit are you talking about, Charles?

Q. Well–
A. The first time she came.

The first time when she told us she met her during the Christmas Holidays in 1966—
A. Yes, I do.

When they were putting up Christmas trees, Roy.
A. Yes, I do.


Q. All right. How long did she stay with you that time?
A. Very-it was a very short time, until they arrested her. They arrested her and–
Q. And which she–and when she got out, were you still in town at that time?
A. Oh, yes. She came back. I took her back to the apartment, yes.
Q. But then, I understood that you had been gone for six months, you and Mr. Alamo?
A. No. You didn’t understand that. That was after that.
Q. Oh. We’re still talking about when you took her–I thought that you told me that you–you all had been gone for a long time and then you came back and you found her walking down the street in the rain?
A. No. You didn’t understand that way, Mr. Garner. I explained to you that you–

He might have understood it that way. Try to straighten it out.
A. –to the apartment and that she hung around there for awhile. And that was when she met Eddie Seay. That was what I said. Then I said the next encounter, I had with her, was possibly from a year and a half to two years later. I met her on the street.

I think you did say six months to begin with but I think you changed it to a year and a half to two years.
A. Roy, it could have been from six months to two years.

A. When I thought about the time of the house, I thought wait a minute, it would have to be a two- year time–

Two years?
A. –period in there.

That’s—that’s the confusion.

Well, the first time you met her, you told me that you weren’t married. And the second time, you told me that when you were walking in the rain, you and Mr. Alamo were married—
A. Yes.
Q. — at that time.
A. And living in Malibu.
Q. Yes. And you took her home with you that time?
A. Uh-huh (yes).
Q. That was the second time you had met her, the second encounter with her, so to speak?
A. If you’re not including the time that she got out of jail and came back.
Q. Well, yes.
A. This would have been the third time.
Q. Yeah. Okay. So—
A. Come on. I’m tired, you know, I’ll answer anything, if it’s reasonable.
Q. Then you–she got her job in the pie house and the restaurant and she lost the job and, then, did she live with you and Mr. Alamo permanently, from then on out?
A. No.
Q. Where did she live after that?
A. We had one quite large place on Carlos Avenue and we had another one on Crescent Heights.
Q. Well, is Carlos Avenue, what kind of a place was it?
A. It was a large house, there were a bunch of hippie kids living there.
Q. All right.
A. And then Crescent Heights, the same thing.
Q. Did you–did you own the house on—
A. No. We didn’t. ,
Q. You were renting it or leasing it?
A. Leasing it.
Q. And how long did you least that house?
A. Oh, I don’t remember. I don’t remember. Let’s say about three years, three or four years, between Carlos Avenue and Crescent Heights. I don’t remember.
Q. What was the purpose of the Carlos Avenue house, that was to furnish a home for the wayward, or–
A. Oh, yeah. Sure. That’s what they were both of them. Yeah.
Q. Did you furnish a home, Mrs. Alamo, and keep–I don’t know whether you call them sinners, in the same house as you would the born again?
A. No, Mr. Garner. I kept the boys in one building, and the girls in another.
Q. Okay. Then, would you keep the boys, who were the sinners, if that’s the proper word, and the boys, who were born again, in the same house?
A. Yes.
Q. In other words–
A. We didn’t have sinners. Sinners —

That distinguishes from being born again, right?
A. Yeah. We didn’t have any. Sinners would be interested in that type of operation. Those kids were praying, they were studying Bibles, and they were—

A. –witnessing. So, there wasn’t any–there wasn’t any sinners.

Q. Well, let me say this to you, Mrs. Alamo, to ease your mind; It’s my understanding that there was no sex involved between your sinners and non sinners-
A. None ever.
Q. –or Christians and non Christians, or born again and not again, so I’m not asking any questions—
A. I know you’re not.

Charles, they didn’t condone it.

A. We had one person that was caught in adultery in the Foundation. We’ve had one.

Q. Well, I won’t—I say that to you to relieve your mind, and I’m not trying to create any impression that there was, because its ray understanding that there was not a –
A. There wasn’t.
Q. –what I call hanky-panky.
A. We had one person that was caught in the Foundation committing adultery, one and only one.
Q. And what was his name?
A. Her name was Kathy.
Q. Oh. It was a woman,
A. Uh-huh (yes).

Q. Kathy Wylie?

Q. Okay. And you’re talking about Kathy Wylie?
A. Yes.
Q. Okay, Let’s go back. We’ll get to that in a minute, talk about your Carlos house, now, and you rented it, you say, and you rented it for three or four years?
A. Uh-huh (yes). Oh, I didn’t—no, wait a minute. I’m not sure of that period of time, I’m really not. We had Carlos Avenue, we had Crescent Heights, and then we had Sagass. And we had Crescent Heights a long time after we had Sagass, so I don’t know. I really don’t know.

Q. He’s asking about Carlos Avenue.
A. I don’t know. I couldn’t answer, if I had to. I don’t know. I would say that between Carlos Avenue and Crescent Heights. I would say five years, now, I could be wrong, it could be four years, but I’m not sure.

Q. To your best judgment?
A. That would be about that period of time.
Q. Now, what did—after Kathy lost her job, either in the pie house or the restaurant, or both, what did she do then?
A. Nothing. She went out with the witnessing groups to witness. I took her home with me a lot.
Q. How did she eat or survive?
A. Oh, we had ample food, always.
Q. There was none of this, as I take it, from what you say, robbing garbage cans or eating bad food, like you were talking about awhile ago?
A. Mr. Garner, there was never anybody that robbed any garbage cans, but I can tell you who went to the back doors of supermarkets and asked for food to feed them. It wasn’t them; it was Tony and I.
Q. All right.
A. We also went to churches and begged for money to feed them. We also went to the large Southern California Baptist groups and asked for money to feed them, full
Gospel Christian Business Men, we supported those kids completely and absolutely. They never did one day’s work in five or six years, nothing. The only reason that they ever took jobs and went to work or that we ever opened businesses, they started getting married. They are young people and having children. Well, it isn’t much of a testimony to Christ to have a bunch of young people wandering around the streets with babies on their backs, talking about Jesus Christ, so we were forced to begin to set up homes for them. Before that time, they never worked a day.

Q. Rather than put it–witnessing and so forth?
A. That’s all.

Q. Well, did–tell us how you did this witnessing, please, ma’am?
A. I told you. We would just simply walk up, one to one, encounter people on the streets.
Q. And did the people that did this, that were in your organization, were they the ones that did this?
A. They did it and Tony and I did it too. We all did that.
Q. All of you did it?
A. Uh-huh (yes).
Q. Then, did you have services among your groups?
A. Every night.
Q. Pardon?
A. Every night.
Q. How about in the morning, do you have the services then?
A. We have always had prayer meeting at 8:00 in the morning and 8:00 every night.
Q. Would you—where would these people be living, what do you call the born again, were the—again, I’m confused, did you have sinners and born agains in the same house?
A. You asked me that question.
Q. I know, and what was your answer?
A. I told you—

She said no before. I don’t know what it is now.
A. I told you no.

Q. Well, in other words, you didn’t take anybody in until they were born again?
A. They wouldn’t have wanted to have been in there.
Q. So–so, if they came into your house and stayed, that necessarily predisposed that they were born again?
A. They didn’t have anyplace else to go. But if they stopped using drugs, if they threw their drugs in the trash can, they had no place else to go. They had no money, if the little girls on the streets, if they stopped what they were doing to support their drug habit, they had no way of making money, they had no place to go, so we took them in.
Q. Well, I hope I’m not confusing the issue and I’m not trying to. But, for instance, if I came up and said, I don’t have a place to sleep tonight, and I’m looking for a place to lay my head and a meal, would you take me in?
A. Mr. Garner, I would take you in. You don’t look like an angel to me, but the Bible says not to turn anyone way, that you might turn away an angel, unaware, But I wouldn’t take you, sinner, off the street and put you in with a bunch of young Christian people; no, I wouldn’t. But I would certainly make arrangements for a place for you to be able to stay.
Q. Where would that be?
A. Oh, we have been known to rent rooms for people, and just all sorts of things, but we have never just you know, taken people off the street and put them in there. Like I told you, the Foundation was found out of necessity, it was out of necessity. 1 don’t believe that any intelligent, well-balanced person in the world could go out and look at a thousand drugged-up hippies and say, I’m going to pick them up, because I’ll be able to make a lot of money out of them, I don’t think they would. Because many of them were no more than vegetables, they had overdosed on LSD until their minds were bad. There’s been many of them, who we’ve had to sit up with all night, night after night, and just ask people to gather around and pray that the Lord would restore their mind till they knew what we were saying to them. Because if you ever can get them to where that they can understand what you’re saying, they’ll reach out to Christ.
Q. What would you say to them, Mrs. Alamo, to try to get to them?
A. To make them to understand?
Q. Yes. To make them we born again, so to speak?
A. Well, I’m sure that you wouldn’t say the same thing to every person, every time, because, since we are no things, we are all individual creations of God, and every person has a personality, whether alcohol, full of alcohol, drugs or whatever, I think that you always try to establish something with them as a denominator, you wouldn’t want to die like this.
Q. Well—,
A. You wouldn’t want to bring this kind of grief upon your family, that you would die like this. There is hope for you, just repeat after me, just follow me, Lord Jesus, have mercy upon my soul, a sinner, Lord help me. Have mercy upon me, o Lord, my God, I’m helpless. We’ve seen them repeatedly, if you just stay right there with them that would eventually begin to reach out. I don’t know, there’s something about the human soul that knows when it’s lost. It doesn’t make any difference what condition of—even if you’re not witnessing to them, there is —there seems to be that awareness of God, of searching and a crying out for God. It just seems to be there.
Q. And would you offer them, I suppose, a warm place to stay and a good meal?
A. No. We fed after every service.
Q. I take it your services, as you told me, were in the morning and in the evening?
A. Uh-huh (yes). We fed a meal after every service. It didn’t make any difference whether they stayed there or not, if they were hungry, we fed them.
Q. And if—you fed the sinners and the born again, alike, too?
A. Oh, sure. Well, sure. We never turned anyone away for food,
Q. There would be no discrimination between them?
A. None at all.
Q. Sinner, and &–
A. Oh, no. We fed everybody. Sometimes we fed as many as fifteen hundred meals a day and oftentimes looked at it and looked out at the crowd and say, My God, how in the world can we ever feed all of these people? And we thought it was, you know, funny, that there would be so many there to feed and we’d ask everybody to come and let’s all join hands and pray and ask the Lord to multiply the food, as He did the loaves and the fishes, and I tell you, before the Almighty God, we fed everybody, I don’t know how, but we did. We never turned a person away.

Q. That is for the food, is that right?
A. Right.

Q. Or from help of God or Christianity or—

She did tell you, Charles, I think, and you might be confusing that, as far as spending the night at one of the places, where she kept her Christian young people, she didn’t mix the sinners; I think you said, those that had not accepted Christ?

A. No, of course we wouldn’t. Of course, you wouldn’t. You wouldn’t pick up some homosexual and stick them in among a bunch of Christians and you know, let me tell you, that we did do the very, very best that we could possibly do with what we had. Because we had never started out to be what we were. It was something that was simply forced upon us and that was all there was to it. And when you pick those kids up and you lived with them and around them for all those years, you naturally have an attachment to them.

Q. But you made the statement that you wouldn’t put a homosexual in with a bunch of Christians, what if it was a born-again homosexual?
A. Now, we’re going to get into theology and you’re an attorney, and I’m a preacher and I’m going to get the best end of that deal. So, you best stay where you are.
Q. Well, I was just asking you–
A. There is no such thing. There is no such thing, you know, that is the way I believe–

Q. Let’s let that go at that.
A. Right.
Q. Let’s not get involved in theology.

Q. That’s a good enough answer for me. I was simply curious because you had made the statement that–I wondered what—what you would do with a born-again homosexual?
A. Well, let me tell you, in explaining to you this way, the Apostle Paul said, All things pass away, and all things become new in Christ Jesus. The Bible says you become a new creature in Christ Jesus. Paul says some of you were murderers, you were thieves, you were all these things, but, now… So, there is no such thing as a Christian homosexual, there is no such thing as a Christian drug addict, there isn’t any such thing as a Christian adulterer, you know.

Q. Well, you’ve gone through enough for awhile.
A. There may have been.

You don’t want any more of that, do you?

A. Yeah. Well, I like to tell him that.

Now, she–now, you know all about that.
A. I’d like to tell him chat. I know he doesn’t enjoy it, but I like to tell him that.

Well, Charlie does believe like that, too.

A. Huh?

Let’s not get involved in that.

Q. For your information, Mrs. Alamo, until I was about fifteen I thought I was going to be a minister.
A. I never wanted to be.

Now, see how far he’s backslidden?
A. Uh-huh (yes). I never wanted to be, never, never.

Quite a bit of difference.

Q. Mrs. Alamo, during this time, what was Kathy doing in your organization?
A. The same thing everybody else was doing.
Q. Witnessing?
A. Yeah. No job, actually. Kathy never really worked anywhere. Kathy or Don, either one, any periods of time.
Q. When you would go out and minister and get money and food, and so forth, would they bring it in and give it to you?
A. Would who?
Q. The people that were–you born-again people, who were going out and getting—gathering it up and so forth.
A. I didn’t. Who are you talking about?
Q. Well—

You’re talking about Don or Kathy?

Or others like them, I mean—

A. No. You are throwing me a loaded question. I would like to know, first, who they are.
Q. The members of the Foundation, or—

Now, they are not members of the Foundation, Charles
They are just associated with them.

Q. Okay. Associates. When you–you’ve made the statement, for instance, that you served fifteen hundred meals a day.
A. And I also told you that Tony and I were going to the back doors of the supermarkets and begging for food to feed them and also appearing at various clubs and churches and begging for money to feed them with. So, where is your they coming from?
Q. Okay. Then, my question is you and Mr. Alamo were the only two who were gathering–
A. That is right.
Q. –or begging for food, or–
A. That is right.
Q. –money?
A. Absolutely, right.
Q. Then—
A. Now, years later, after we had grown in to a tremendous organization, had papers, we were getting all sorts of things as write-offs. But I’m talking about Crescent Heights and Carlos Avenue.

Q. Contributions you’re talking about?
A. Right. Of food and everything in the world, write-offs.

Q. When did you really start to get large?
A. From Crescent Heights to Sagass.
Q. And then, I assume when you decided that you were so large, you bought Sagass? A. Uh-huh. (yes).
Q. Where is Sagass?
A. About thirty-five miles out of Los Angeles.
Q. North, south or where?


Q. Is Los Angeles the closest place that you’re near to?

It’s in LA County.

A. LA County.

Q. Oh, it is? And is Sagass a town, or a mountain range, or what?
A. You could call it anything you like. It’s a — I don’t know. It’s a combination of several little places that are more or less strung in together, you know, New Hall, Sagass, Valencia, there’s about four of them.
Q. Well, are they towns or villages?
A. They’re villages.
Q. Or cities, or cross roads, or—
A. Villages.
Q. How large a place is Sagass?
A. Oh, I don’t know. I understand it’s Town tremendously since we left there, I don’t know.
Q. Well, how large was it when you moved there?
A. I don’t know that either.

Are you talking about population-wise, Charles?

Yes or–yeah–I mean—

A. I don’t know.

Q. I mean was it about like Alma, or Van Buren, or Fort Smith, or—
A. I’d say Alma. Again, I’m making a guess.
Q. Why did you pick Sagass?
A. Well, we had to have space for expansion, they’re– you know, we were running into hundreds of people at that time and we had to–had to have room. We had two large apartment houses there, plus a lot of dwellings and we’d grown into the point that we had to have room to expand.
Q. How much land did you buy there?
A. I don’t know. I don’t know. That’s Tony’s department.
Tony takes care of the land department.
Q. Okay. And you say that he—the department or land manager, I guess you’d call him, is that a fair—
A. Tony?
Q. Yes. Is that a–
A. No. I wouldn’t call him a land manager. I would call him… the greatest Christian in the world and the very finest businessman, and the best husband in the world. I would never refer to him as a overseer of land, particularly.
Q. Well, I wasn’t trying to be degrading, Mrs. Alamo, I–you had referred to him as being — as managing–I believe you said he was the manager of that department?
A. And his house.
Q. Okay. And I was–then, my next question was was your organization departmentaled — departmentalized, so that, for instance, you did have a land department that maybe Mr. Alamo was the manager of it and maybe there was —
A. Mr. Alamo is the–
Q. –food department?
A. –manager of everything at the Foundation, everything,
Q. And has been, since it was formed?
A. Yes, he has.
Q. You don’t recall or know what property you have at Sagass?
A. I think I know.
Q. All right. Tell me what you think, then.
A. But my husband sells property, and I could be wrong, So, I don’t know and, therefore, I would be completely inaccurate, possibly, to even answer you, because he has sold several pieces of land.
Q. During the time, from ‘63, I believe, you told me that you finally got back with Kathy and she came into the organization as a born-again, you stated that she didn’t have any jobs. What did she do during the time, other than witness for the Foundation?
A. Nothing. No actual job anywhere, at anytime.
Q. Well, what did she do within the Foundation, did she cook or–
A. Oh, she’d go to the kitchen every once in awhile, when there would be a group of the girls going up there, she’d go into the sewing room every once in awhile, when there would be a group of girls going there. Kathy never stayed with anything for any period of time at all. When we opened the restaurant at Alma, she went in like a fire horse and it didn’t last very long and Don was of the same temperament. You could subpoena a hundred people from the Foundation and they’d all tell you the same identical thing. Kathy spent most of her time, since we’ve been in Arkansas, in the shopping malls.
Q. In shopping malls?
A. Yes. Or wherever she wanted to go.
Q. Did she ever do any shopping for you?
A. Yeah, pick up a couple of bottles of shampoo, maybe stop by the Boston Store and pick up a jar of cream, or –yeah, she sure did, not clothing or anything like that.
Q. That would just be on an occasional basis?
A. Oh, yeah.
Q. How did it happen that Kathy was one of the original subscribers to the–signers of the Foundation?
A. That was really nothing more than just being three persons.
Q. Well, did it indicate any more confidence in her than it did, say, some other member of the organization?
A. None at all.
Q. Who was the attorney that prepared those articles?
A. Oh, I don’t remember. I couldn’t tell you, if I had to, I don’t remember.
Q. Pardon?
A. I don’t remember.
Q. Does he still represent you?
A. No. No. One of them is dead. I don’t know. I really don’t.
Q. At any rate the articles were filed on the date that it’s shown to be filed, is that correct?
A. Well, I would presume so.
Q. Well, I think it’s 1969, March somewhere along in there,



January 30.

Q. Arid you don’t recall the attorney that drew these for you?
A. No. I–
Q. Was he in Hollywood or Sagass, or was he in—
A. Now, if I knew where he was I’d know who he was, wouldn’t I?
Q. I don’t really know.

Not necessarily.

Not necessarily.
A. I don’t know. I really don’t know.

Q. Then don’t say, don’t guess at it.
A. I can’t remember.

Q. You have no recollection of going into some– either imposing building, or some tiny little lawyer’s office?
A. Imposing buildings at all times, with lawyers, always.
Q. In 1969?
A. Always. But just what or who he was, I still can’t answer you, because I don’t know. I don’t remember. I don’t know.
Q. And you don’t recall the town that they were in?
A. Well, it would have had to have been Los Angeles.
Q. All right. And you say that the only reason you did it was because she was handy and just happened to be there?
A. Yeah. And, again, you’ll have to ask Tony about that. I have nothing to do with business matters at the Foundation.
Q. All right. After the Foundation was formed, was there any change in the manner of operation or method of operation, which you conducted at the time?
A. No.
Q. To your best knowledge what was the purpose of forming the Foundation?
A. Because they had no place to go, most of the people there had no other place to go.
Q. Well, I mean–when I say forming the Foundation, I mean forming the articles, filing the articles?
A. Well, to be legal. But the law of the Bible tells you to abide by the laws of the land.
Q. Well, you’re not telling me that you were illegal the three, four, or five years prior to that?
A. No. I’m not telling you that. But in order, we were growing big, and in order to accept donations from people and be able to keep records with the IRS, and et cetera, et cetera and et cetera, we had to do it that way. That was the proper way to do it.
Q. Who was elected the first president of the Foundation?
A. I don’t remember. I don’t know.
Q. Did you hold any office in it?
A. Yes.
Q. What–what officer were you?
A. What am I, honey? (To Mr. Alamo).

A. I’m a secretary.

I was always the President.

Q. Did you have—what would Kathy be, then?
A. What was Kathy, Tony?

If you don’t know just tell him.

A. I don’t know. I really don’t know, Roy, I mean it, I just don’t.

Okay. That’s all right.

She really doesn’t know.

Q. And you say your method of operation did not change after you filed the formal articles?
A. I—what do you mean by method of operation?
Q. Well, just—I don’t know how to break it down any more than just saying your overall operation, your overall picture of the situation.
A. Tell me what you’re accusing me of and I’ll have a chance to answer it.
Q. I haven’t accused you of anything yet, Mrs. Alamo, and we’ve been here almost two hours.
A. I don’t remember. I don’t even know what you’re asking me.
Q. Well, you used the word, operation, first, I didn’t, and—
A. But you’re asking me how it changed?
Q. Yes.
A. I don’t know in what way you mean, I don’t know what you mean.
Q. Well, did it change? Let me ask you that did it change?
A. No.
Q. Okay. Well, then it couldn’t have changed if it didn’t.
A. Well, I don’t—I till don’t know what you mean.
Q. Okay. Did you begin—you’ve told me you started keeping records for IRS, did you—I assume that you’re talking about tax records, and—
A. Right.
Q. —the things that they normally require. Who was the business manager, was that Mr. Alamo during that time?
A. My husband, Mr. Alamo.
Q. Did you do it with checks or with cash?
A. That, you ask the business manager.
Q. All righty.
A. Because I have absolutely nothing to do with that. I could not truthfully answer one question to you, if I had to.
Q. All righty. Was Mr. Alamo just as active in ministering as you were?
A. Oh, yes, he always has been.
Q. Or more so, would you say?
A. Well, I would say just about the same. Would you say about the same (to Mr. Alamo)? About the same.
Q. Well, for instance, you told me originally that you considered yourself a housewife. I assume that you would be housewifing while he would be out sometimes ministering or—
A. No, he ain’t out nowhere, ever, not at any time is he ever out anywhere, other than maybe to Mr. Gean’s office and to the attorneys, and you will always notice that
Mr. Alamo will have from two to five of the brothers with him. He is never out anywhere.

It depends upon what you mean by out. It looks like Mrs. Alamo is taking it to mean different things.

Well, I—
A. I know what he means. I know what he’s saying.

Where I was talking about, say—

You mean witnessing, things like that.

A, Never, never, ever. If he was out witnessing, I was out witnessing, too. I did my little housework, I washed my dishes and we went together. We have always done that.

Q. The laundry? I mean you—
A. He does good with the laundry, as well as being a business man, he does real good laundry, and he washes dishes real good and he makes beds, and does all those things.
Q. Was—I—and this is even true back in ‘69?
A. Yes, yes.
Q. I mean, for instance, you wouldn’t go to speak as a lady to, say, the POE’s or the–
A. No.
Q. —or the Christian Women’s Association—
A. NO.
Q. And he would go—
A. We have never–Tony and I have never done that.
Q. And witnessed to the, say, the—
A. We talked about this in your office yesterday.

Separately, you have never done that?

Q. The Men’s Fellowship—
A. We have never done that. He never has even accepted invitations to men’s groups, although he has been asked many, many times, even when we go to–people that know us know that. We were invited to a club in Fort Smith not too long ago and they made it, the invitation, to both of us. Was it the Rotary-~do they have a Rotary Club?

I think it was.
A. Do yon have a Rotary Club?

Yes, there is a Rotary Club.
A. It was some business men’s group, anyway, they asked us and they made it a joint invitation. Tony and I have never done that. We have never taken separate invitations anywhere and, usually, when you see one of us, you see both of us.

Q. In other words, if you were asked to witness to a group that they couldn’t take both of you, they didn’t get you?
A. Then they don’t need us. Then they don’t need the other- one,
Q. All right. In other words, if there’s no—
A. Oh, let me take that back. I think I went to a lady’s luncheon one time in Sagass.

I was probably in the other room.

A. He was, but that was the only time.

And he was in the other room?
A. And he was in the other room,

Q. And I take it, then, that you would not minister, say— again, I just use this as an example, in Sagass in church on Sunday, and he would be—while he would be ministering at New Hall in church?
A. Never, never. The only time that he would ever go into the church and by ministering in the church was when I was so desperately ill. Sometimes he went in and took the services in our own church, but other than that, never.
Q. And that’s true from the time, January of ‘69, on up to the present time?
A. To today.
Q. All right. Now, let’s talk about—well, let’s talk a little bit more about Kathy and then we’ll be through with her. You say that Kathy went to malls and so forth and so on, and spent a lot of time—well, did she spend a lot of time ministering?
A. No, not after we left California, no.
Q. When did you leave California?
A. I think it’s six years, I believe it’s six years.
Q. Six years. Why did you leave California?
A. My health was terrible. I had terminal cancer, and we went to Nashville, Tennessee.
Q. Why did you go to Nashville?
A. Tony was recording down there. He has a brother that’s in the recording industry, and we were recording down there and I was just terribly ill. We came through Arkansas, we saw that old house at Dyer that I was raised in when I was a kid, and Tony wanted that house. And, as far as medical science was concerned, I had absolutely no chance to live, whatsoever. My sister lives here, my family live here, so I felt at the time that Tony was trying to get me close to my sister, close to home. And it must be six years, because we’ve lived in that house for five years, I’m sure it’s five years, so, it must be six years.
Q. Well, you settled in Nashville, I take it, first?
A. Yeah.
Q. Did Kathy go with you to Nashville?
A. I don’t think so. I don’t think so. I don’t remember, but I don’t think so. No, I don’t think so- no.
Q. How many of you moved to Nashville?
A. Mr. Garner, I think it was Tony and I and about twenty of the boys. I could be mistaken, it’s a long time age. We’ve made an awful lot of trips across country and evangelism every direction of vans of fifty, and—but to the very best of my knowledge, it was Tony and I and about twenty of the boys.
Q. Did you buy a home or other property in Nashville?
A. Well, at first we leased a large house in Nashville. And then we have about ten boys that stay in Nashville, and then we purchased a house that the boys live in.
Q. Are they still living there?
A, Oh, yes.
Q. Are they living in what I would call your home, there?
A. In part of it, yes.
Q. They are?
A. I wouldn’t call it my home. I’ve been there, would say, three months at one time, and two weeks at another and three weeks, and something like that. I’ve lived at Dyer since I’ve been here.
Q. Well, I understood that you have a home, or a house, whatever way you want to denominate it—
A. I have a feeling you’ve been made to understand a lot of things that are not necessarily that way. No, we—

Are you talking about a place, living quarters?

Q. Yes, you and Mr. Alamo.
A. Yes, when we go down there, but we seldom ever go there, we go there on business reasons, we run up and down and take care of what we have to take care of and we’re out of there. But, as far as making it a home, we never have.
Q. And nobody lives in it when you’re not there?
A. Oh, yes, there’s ten boys living there.
Q. Are they living in—the boys, in the section you would live in?
A. No, they are living upstairs.
Q. How large is the downstairs?
A. It’s—that house has been remodeled, there’s three bedrooms upstairs, and two downstairs.
Q. Do you have any property in Nashville, other than that house?
A. A store.
Q. Pardon?
A. Store.
Q. What kind of a store, please, ma’am?
A. Clothing.
Q. What’s the name of it?
A. The Alamo.
Q. And you say that Kathy did not follow you to Nashville?
A. Oh, yeah, she eventually followed down there.
Q. All righty. And then you eventually came to Arkansas, six years ago?
A. She followed us down there, and she threw a fit down there and screamed and cursed and raved in front of a bunch of people and we sent her back to California, and I never spoke to Kathy for a year.
Q. Who did she scream and rave in front of?
A. I don’t know. It must have been fifteen or twenty people.
Q. Can you give me the names of any of them?
A. I’ll get a list of the names of all of them
Q. Okay. Thank you. And this happened –
A. In Nashville.
Q. Nashville, all righty. Now, she came to Arkansas soon after you came here, then?
A. Yeah.
Q. And where did she live when she was here?
A. Oh, here in Fort Smith, on Grand Avenue.
Q. On Grand Avenue?
A. Uh-huh (yes).
Q. And where were you living at the time?
A. Fort Smith. We had two—two, two-story houses on Grand
Q. And were you all living next door or in the same house?
A. I don’t remember. I really don’t even remember that Kathy was even there, to tell you the truth. I think Ann and Richard McClelland—I can’t remember that Kathy was there. She could have been, but I’m not—she came out after that. But when we first came—no, Kathy wasn’t. I don’t believe she was.
Q. Well, after she came back here, did she continue to minister for the Lord?
A. No.
Q. She did nothing of that sort here? What did she do here, please, ma’am?
A. Mr. Garner, I told you what she did.
Q. What?
A. What Godzilla wanted to do.
Q. Well, who is Godzilla, now?
A. Well, I mean that’s the only answer I can give you. If she felt like going to the restaurant and working a shift, she went; if she wanted to go to the sewing room, she went; if she wanted to shop, she shopped; and, as far as any actual job, any place, at any time, I could stand before God and tell you that she had none, or has she ever had any, that I am aware of.
Q. Did she spend any time with your personal needs, so to speak?
A. During the time that I was in the hospital and I got out of the hospital, she was very kind and very good in helping me, during the time I was in the hospital and shortly after I go out. Mr. Garner, I’ve heard this story before. You see, I talk to people all the time that this girl talks to across country. My husband basically took care of me through that illness, that’s the truth.
Q. I didn’t mean to imply that Kathy had taken care of you.

He didn’t ask you, don’t go into all that. Just try to answer as briefly as possibly his questions.

A. Well, no, Kathy never had any definite place of employment. And you are at liberty to subpoena two or three hundred people. She was in charge of a work crew, but she was supposed to be figuring out, like the work crews, of how many, in other words, how many of the girls would be available for babysitting, you know, because they switch off and on. Kathy was always into fights with everybody.
Q. Including yourself?
A. Right.
Q. Including Mr. Alamo?
A. Right. With everybody.
Q. And including Mr. Wylie?
A. Right, continuously, it never ceased.
Q. When did you begin to see or notice some dissatisfaction with the Foundation on her part or did you know that she was going to leave, or—
A. Yes, I told her to.
Q. You told her to leave?
A. Yes.
Q. All right. Why?
A. Well, I’ll tell you, that it had actually got to the point with Kathy that it was unreal. It was an absolute impossible situation. She would go and tell the girls that I said to do something. And the girls would do it, and she would come back the next day ranting and raving and just swear that she never said it, she didn’t know anything about it, that they were liars, and the girls would say well, if you even attempt to defend yourself, you have to physically fight her. So, the other girls didn’t want to do that and they would just back out of it and then just get out of it and say Suzy, there’s nothing to it, really, it’s just another of her insane fits. And then, again, I’d go back and say look, girls, it was the way she was raised. She was raised in violence. She doesn’t know anything else, you know, you girls, some of you, you come from good parents, good homes, good mothers; she’s never had anything like that. You know, have mercy on her. Suzy, we can’t take any more, you know, Kathy would attack people, physically attack people, she’s known for that. And it was just—it just simply got to a place that–Don never used to be like that. Don was one of the nicest guys in the world, had the nicest disposition.
Q. So, it just got so bad to where you asked–
A. Oh, she got into it with Tony. She never had any—
Q. With who?
A. Tony. She never had any real encounters with me at all. She’d just keep trying to meddle in everybody’s business and just keep one mess going on top of the other and, so, she got into it with Tony and, because I wouldn’t defend herself against Tony, Kathy came to a place that she thought everybody at the Foundation was nuts, but her. That included me. Everybody was crazy, but Kathy. They were all a bunch of nuts, and we were all a bunch of nuts and everybody was crazy, but Kathy. And it just kept going. She finally got to where that she would bust even through the back door at night into the office with all the men in there and throw terrible fits and get knives after people, throw plates of spaghetti at them, and you name it, she did it. And, then, when she came to me and Tony was a liar, and Tony had done this and that, and I said well, Kathy, what did he lie about? Just a liar, he just lies about everything, and he just, oh, he does this, and does—and I said well, tell me one thing that he does, you know, don’t just basically call someone a liar or a thief or any other thing and then not have anything— everything, just everything, everything about him, everything he does. So, because I wouldn’t side with her, Kathy got it into her head that she was going to take over through Foundation. Now, that’s just what her story was, there’s no doubt about what the deal was with her, that’s what it was. Then, when she went up to Tulsa, she sat up a campaign of writing to people, and calling on telephones and—
Q. What did she get into it with Tony about?
A. Coming into the office at night where the men were trying to get the finance list together and the work sheets, just meddling where she had no business.
Q. When did you finally ask her to leave the Foundation?
A. It was on a Saturday. It was on Saturday and she had gone down and was hanging around the store and I went down and picked her up in the car. Everybody was used to Kathy throwing fits that was just an old one.
Q. How long prior to the time she left did this Saturday occur?
A. That she—I’m talking about the Saturday that she left.
Q. Oh.
A. That she left, possibly that night or the next day, but I anyway, I told her, I said Kathy, you can’t stay here any longer. You’re into it with everybody, and it just doesn’t cease. People left the Foundation over Kathy and came back, bunches of them, after they knew she was out of there, and I said it just can’t go any farther.
Q. How did she leave?
A. They hired a truck.
Q. Pardon?
A. I understand they hired a truck.
Q. Well, do they have possessions in the Foundation, I mean you- what do they do?
A. No, but they have possessions that belong to the Foundation. They—she came in with a toothbrush in her pocket and went out with truckloads.
Q. What was in the truckload?
A. Everything.
Q. Well, that’s pretty all encompassing.
A. Well, we’ll make a list.
Q. Well, you want to furnish me that list or do you want to tell me about it now?
A. No, I’ll furnish it to Mr. Gean and he can furnish it to you.
Q. All righty. Then, I take it, that you know what she took in the truck?
A. No, I don’t know everything that she took. How would you know what somebody had taken over a period of ten years? I know that she has about a two-and-a-half carat diamond ring on her finger that belongs to me, plus another ring that has three, twenty-five point diamonds in it.
Q. Where—you say she took the two-and-a-half carat diamond ring with her?
A. Yes.
Q. And she took one that had three, twenty-five points?
A. Yeah, solid gold band with three, twenty-five pointers in it.
Q. Where did you get the two-and-a-half diamond?
A. Tony gave it to me.
Q. Do you know where he got it?
A. No, I don’t.
Q. The three, twenty-five carat diamond, do you know where you got those?
A. Yes, he bought them from a wholesale jeweler house, jewelry house, in California-
Q. When?
A. 1966.
Q. All right. Were they bought with your own individual money?
A. Oh, yes.
Q. Where did you get that, please, ma’am?
A, It was Tony’s money.
Q. Where did he get it, please, ma’am?
A. Well, that was before we were ever involved in the
Foundation and it was Tony’s personal money. The rings were bought in 1966.
Q. Okay. How, you say that Kathy never did any shopping for you or anything?
A. I never said that. I said that she picked up shampoo,
maybe stopped by the Boston Store, but, as far as actually-doing any clothing shopping for me, no, she never did any clothing shopping for me, that I am aware of or can remember.
Q. How about hair-do’s or wigs?
A. The wigs that I bought came from my friend, Glenda, and Ray Parsons, that have the shop on Towson Avenue and I can assure you that both of them can tell you I never sent Kathy there.
Q. And that—
A. Unless she would happen to be going by the door and I would say Kathy, Glenda did so and so for me, would you stop and pick it up?
Q. What’s the name of the place on Towson Avenue?

House of Hair.

All right.

A. Glenda and Ray Parsons.
Q. I take it that she never picked up any for you in California?
A. Not that I remember. She picked up wigs for herself. She also picked up wigs for herself at the House of Hair, here.
Q. But none in California, that you ever recall?
A. She picked them up for herself.
Q. In California?
A. Oh, yes, sir, she certainly did. As a matter of fact, she got into a fight with somebody one time and one of them got hung up on a—something on the side of a door.
Q. Here or in California?
A. In California, and another time she got into a fight with a woman in a court room and the woman snatched a wig off her head and there was several of the boys with her that time,
Q. What court room was that, please?
A. I don’t remember, don’t remember. The boys would remember.
Q. Were you there?
A. HO.
Q. Oh, you didn’t see it?
A. No, the boys told—well, she told about it.
Q. Do you recall who it was that she snatched the wig off, or—
A. No, a woman. She got into a fight with a woman i: the hallway and the woman snatched the wig off of her head.
Q. Off her head?
A. Yes.
Q. Mrs. Alamo, I understand that you are in the process of building a home, here in Crawford County, is that correct?
A. No, I’m not in the process of building it, it’s built.
Q. It’s completed?
A. Yes, most of it’s completed.

We’re building several.

A. We’re in the process of building several homes.

Q. Well, I understood that there was one particularly large home up there that was your home, or going to be your home?

It’s the Foundation’s home.

Q. Okay. It’s the Foundation’s home. But there’s one in which you were going to live.

Of course, there’s many Foundation homes.

Q. But I understood that it was one you and Mr. Alamo were going to live in?
A. Uh-huh (yes).
Q. Is that correct?
A. Yes, we built a house.
Q. Is it finished?
A. Mostly finished.
Q. Are you moved in it?
A. Yes.
Q. Have you bought your furniture?
A. Oh, I’ve had all kinds of furniture for years. I’ve furniture from all over the place, from California, from Tennessee, every direction,
Q. You didn’t buy any over at Mayo’s or—
A. Mayo’s, where is Mayo’s?
Q. In Tulsa.
A. Mayo’s?
Q. Mayo’s.

That’s a furniture store in Tulsa.
A. Are you talking about five years ago?

Q. I don’t know when, I’m just asking you.
A. Yeah, I bought–I don’t believe this. I bought two chairs and a coffee table five years ago.

In Tulsa

A. Yes.

Q. Does either one of you all have a ring with a diamond “A” on it?
A. No—oh, yeah.

Well, that’s—

Let Susan answer that.

We’ll get to you in a minute.
A. Yeah.

Q. Who has it?
A. Tony has one and I have one, we sell those rings.
Q. With diamonds in them?
A. Oh, yes, sure do. We sell them. The—most of the stars and celebrities have them made with their initials on them. T.G. Shepherd’s having one made with a big shepherd dog, with his initials on it.
Q. But you all have never bought any for yourself, individually, here?
A. Anything we buy, Mr. Garner, anything we wear, we sell.
Q. Well, then, I’ll ask the question, have you bought a diamond “A” ring at Zales?
A. No, Bob Dyer, at Zales, made the original of the—for the rings and made a deal with us to make the rings.
Q. Has he made any since then?
A. Ho, because we could get a better deal on that. We can buy wholesale from the wholesale houses in California. We can buy the diamonds and we can buy the stones, so, there wouldn’t be any reason for it. But he did make the first ring.
Q. Did you have it appraised subsequently?
A No.
Q. Never appraised, okay. Now, you’ve told me about—that the only person that you ever found in the Foundation in adultery or whatever you want to call it, backslid, as we Baptists would call it, was Kathy, is that correct?
A. Right.

And the person with her.


And the person with her.

Q. And who was that person?
A. Ed Mick.
Q. All right. When did this occur?
A. In Sagass.
Q. Pardon?
A. In Sagass.
Q. Do you remember what year?

Seven years ago.

Q. Approximately 1973?
A. It was a year before she married Don.
Q. And what was the occasion for that, Mrs. Alamo?
A. What was the occasion, Mr. Garner? I went upstairs in my house and caught her in bed with Ed Mick. That was the occasion.
Q. In her bed or your bed?
A. In his bed.
Q. In his bed?
A. Yeah.
Q. And what occurred then, did he or she leave or did—was there any punishment or a prayer meeting or what? What do you do when you do something, find somebody doing that?
A. I couldn’t believe what I was seeing, for one thing, that a female could be so cheap in somebody else’s home. She had sneaked in through the den in the back of the house, obviously, during the middle of the night. When I caught them, it hurt Ed terribly. He started crying and told the whole truth of the story. Kathy was living down at what we called Number Two at that time with another girl, in a small unit there. So, I told her to get out of my house that I never, ever wanted to see her again as long as I lived; that I had had quite enough with her; that it was just—that it never ceased; it was one thing after the other. She went back down to where she was living, a couple of days later she came back and got down on her knees, and the tears running, and I’ve been praying and fasting, and God has forgiven me, why can’t you? I took her back.
Q. Did you forgive her?
A. I forgave her and I went right back to the same identical thing, remembering the way this girl was raised. Her morals were crippled when she was a child. She’s never had a chance. Tony didn’t buy that, he didn’t believe it. He said this girl is absolutely no good, she never was and she never will be. She’s phony from the top of her head to the bottom of her feet. She’s out for whatever she can get off of anybody. She uses you, she cons you, and you fall for her foolishness and she’s nothing you think she is. Get rid of her, and get rid of her now, and, if you don’t, you’re going to curse the day you didn’t do it. I couldn’t put her out.
Q. So, she stayed with you another what, five or six years?
A. Yeah. She met Don and we wished them the best of every- thing.
Q. Now, who is Ed Mick, what was he doing living upstairs in your house?
A. We had an awfully large office in the house at that time and two or three of the boys used to stay there at night. And Ed stayed upstairs and, then, there were a couple or three boys that stayed downstairs in the office den part of the house.
Q. That was at Sagass?
A. Yes.
Q. I’ve got in mind the name Mick is—as being some—
A. My daughter was married to him at one time.
Q. Was that what it was? When was this, please, ma’am?
A. Oh, I don’t remember. I don’t remember. That would have been…that would have been three of four years before that, I’m sure.
Q. Was your daughter married to him at that time?
A. Yes, they were still married.
Q. In other words, you—
A. Kathy was still married to Eddie Seay at that time.

Let me ask you, Charlie, is this relevant?

Well, it’s about my client and I don’t want to—

A, You’ll have to excuse me because I have to go to the rest-room.

That’s all right. Go ahead.
(Deposition resumes after a brief recess)

Q. I believe we were talking about that you had asked her to leave on Saturday and she left that Saturday by a rented truck and that you were going to furnish me with a list or furnish to Mr. Gean the list of property that she took with her, which belonged to you or to the Foundation.
A. To me.
Q. To you?
A. The rings belonged to me.
Q. All right.
A, The other things that she took belonged to the Foundation.
Q. Incidentally, I noticed that you’re wearing on your left hand a ring, a beautiful diamond, it looks like it has about thirty or forty diamonds in it, is that yours?
A. Yes.
Q. And where did you acquire it?

Now, Charles, I don’t see that that’s material. I’m not going to let her answer that.

Well, if she says it’s not the Foundation’s.

Well, she hasn’t said that that ring is not the Foundation’s. She said—she hadn’t said it is, but I just don’t think that that’s relevant.

A. You asked me about the rings that she took I told you they were bought in ‘66.

We’ll let the Judge—if I’m out of line on it, the Judge will straighten me out on it, I just don’t think your personal jewelry has anything to do with this lawsuit. MR. GARNER:
Well, you’re assuming that it’s personal jewelry, I want it under oath.

Well, it’s on her hand.

Yes, but it may belong—

Well, I’m not—I don’t think who owns it and who’s wearing it is material.


Q. Now, let’s talk about Don Wylie. When did Don join the group or operation?
A. I would say in ‘70, or ‘71.
Q. And do you recall how he did it, what was the occasion for meeting him?
A. Yes. He came there and said that he had volunteered for drug experiments in a college in Canada, or someplace he had been. I think at the time he came there, he came from Canada. But, anyway, he said that he had volunteered for LSD experiments. And that they had given him an overdose and that for days he couldn’t remember anything, but just a horrible, nightmarish experience that he had been through, days and nights, that he didn’t recall even what the period of time was, and that they had done this to him several times and that he knew that he had to get away from there, and he had to escape from there, in some way, and that he did go to a—either a plane station or some station, and that while he was sitting there, he picked up a Time Magazine and he read a story about us and he said that’s for me.
Q. Where did he meet you?
A. He came to the Foundation.
Q. And where was it at that time?
A. He came to Crescent Heights. He came to Crescent Heights and he said that his father had committed suicide, that he had been involved in drugs for years before these experimental type of things that happened. I would
presume after some of the disclosures and the articles that have come out the past four or five years, that this is possibly the same thing that the CIA was involved in during that time, during the Casey—William Casey type of thing, that they said that they had to use them, you know, experimented with them.

I don’t think he wants to hear about all that.

Q. You think Wylie was involved in it as a CIA?
A. No, no, no—

He came to the Foundation, Charles, you wanted to know how he came.

A. They were using it as an experimental thing in a—in some college, but he had been involved in drugs years before that, before the experimental type of thing. But what I’m saying is that there have been several documents recently that they were doing that.

Q. Well, did he come to you at Crescent Heights as a sinner, so to speak?
A. Don came to Crescent Heights a person torn absolutely to pieces. He said that his father had committed suicide, drunk, that his father was close enough to him until he
blew his brains all over Don and Don had been taken into custody for it; that the mother had drank herself to death, that the mother was also an alcoholic, and drank herself to death; that he had become all involved in the drug culture and in the experimental type of thing. Don really was a born-again Christian. Don really accepted Christ. I believe with all my heart that everything that Don Wylie did, he did with all his heart. Don was a truthful person, he wasn’t a vicious person, he wasn’t any of those things. Don was not a worker. He would enter into some project, just all fire and exuberance, but it never lasted any period of time. And the other boys always laughed about it. If he’d go down and help out at the service station, it would be like the most important thing in the world, he’d be running to and fro and knocking over buckets that were in the way or whatever. And then that would be very short lived and it would be all over. Don was such a likeable chap that everybody just more or less took for granted Don, they felt sorry for him, they thought that he had a rough time of it at home, because Don either slept in the boys’ dorm most of the time or underneath his house, and he always told the boys his problems and everybody loved Don.
Q. So, I take it, he had no regular job—
A. Never.
Q. —during the time that he was at the Foundation?
A. Never, ever, no. Tony used him as a driver back in Sagass and made the payments for him on a new Lincoln Mark IV.
Q. Made payments for who, now?
A. For Don.
Q. You mean he paid—
A. Tony paid for it.
Q. Bought him one?
A. Did you buy the car you made the payments on?

Leased it with the option, we don’t have to—

If you don’t know, don’t say. Let him get Tony on that.

A. Well, anyway, Tony purchased the car, made the payments on it and Don drove it. Tony more or less gave it to him and said here, you know.
Q. Do you know whose name the title was in?

It was leased to the Foundation.

A. The Foundation.

Q. Okay. Well, then, how did it occur that he and Kathy were married, I mean do you have romancing in the Foundation? I assume that you do?
A. Don was doing some food runs at that time.
Q. What are food runs, please, ma’am?
A. He was taking sandwiches and coffee and things like that around to the different people at the different Foundations and different locations and job sites and, so, Kathy and one of the other girls started riding with him to help to dispatch the food. And stories started filtering- back that Kathy was after Don Wylie. I had no intentions of going through another one of Kathy’s deals, not at all. I had been through enough of them. So, I called Kathy in, I asked her if it was going on. I said now, Kathy, you’re not going to be out running around with Don anymore, because we can’t take another one of your scenes, we’ve had all of it that we can take. If you are really serious about this boy and this boy is serious about you, then get married. Do it the right way. So, they kept seeing each other at the church from time to time and Don came and talked to me about it and I think he talked to you, too, didn’t he, didn’t he talk to you?

Yeah, said she had to get a divorce.

A. And we paid for her divorce.

A. Tony’s in charge of that, I don’t know anything about it.
Q. You don’t know where they are stored?
A. I don’t–no, I don’t know.
Q. Pardon?
A. No, I don’t know.
Q. Has anyone ever made a history of the Foundation, that is, do you have a historian or a—kind of like, I guess churches would call it, or secretary-treasurer, that keeps minutes and kind of keeps a history of the growth–
A. Since it is a law to keep minutes, I’m sure that my husband does keep minutes, since that is a law, I’m sure that he does.
Q. Do you – have—who are the only three members—are they still only Kathy and Mr. Alamo and you, are still the only–
A. Kathy was taken off after the Eddie Seay escapade.
Q. Es—what?
A. Eddie Seay escapade.
Q. Wow, you keep saying Eddie Seay, do you mean by that, C-double-E, or S-double-E or–


A. And the Ed Mick thing.

Q. Pardon?
A. (not legible) she stayed there, because if Don and Kathy went out in the evening, she stayed with their little girl. But she was there with all the existing problems, also, and there wasn’t much of a place she could have hid to have gotten away from it. So, she knows an awful lot about it and his leaving and being gone for days and the fights and the—everything. And, as a matter of fact, she knows about Kathy sticking money in her pocket that she was supposed to have given to the Foundation.

Well, you’re telling what other people told you now.

A. Mr. Gean, not only one person—

I know, but—

That’s all right. Let her tell it, because it’s going to have to be brought out.

A. It will be brought out.

Q. How much was she putting in her pocket or how was she getting the money from the Foundation?
A. She would tell Don that she was—Don would give her money and she’d tell him she was giving it to the Foundation. And she’d go over and buy things on lay-a-way and then go back the next day and pick them up and I’d say my, my—

Just what you know of your own personal knowledge.

A. Tony found that out for him, that they were setting up bogus corporations and depleting the trust. But, for the longest time, Don didn’t really get any money at all. And, then, when it went into litigation, less. I’m sure that Don turned most of what he had over to Kathy and I’m sure that Kathy told him that she gave it to the Foundation.

Q. He didn’t ever give any to the Foundation directly?
A. Before he married her.
Q. He did?
A. Uh-huh (yes).
Q. By check or by—
A. I don’t know. Did Don ever give you money by check?

Some cash, no check.

Q. When—who handled the money for the Foundation, has that been Mr. Alamo or someone under his direction?
A. Tony.
Q. Tony. Would the only money that Mr. Wylie had be that which he got out of trust, as far as you know?
A. Oh, yes, he has returned.
Q. Oh, he’s back in it, again?
A. Oh, yes. He’s back, he’s married, he has a lovely child.
Q. He is not married to your daughter anymore?
A. No.
Q. Okay. Okay. Well, anyhow, after Kathy and Don—did they have a courtship, as we think of it?
A. Oh, yes.
Q. I mean did they date, and hold hands, and go to the movies
A. I don’t know if they held hands or not, I never went with them. I know that they saw quite a lot of each other, to the point that it was becoming nervous. It was a very nervous situation.
Q. In what respect?
A. As in respect of church.
Q. Well, I mean what was nervous about it; I mean I don’t get your point.
A. Well, I told you that we had gone through two previous with Kathy and we were not ready to enter into another one.
Q. Oh, oh, I see what you mean. In other words, you—well, I don’t know what you thought, is there any way you can tell me what you thought?
A. You know what I thought.
Q. Am I thinking that you thought that—that she would create–Was Kathy married at the time?
A. Yeah, she was still married to Eddie Seay.
Q. Eddie Seay. She had married Eddie Seay then?
A. Yes.
Q. The one that broke his leg?
A. Well, when we went back to Hollywood, Eddie Seay began to hang around again, and she was hanging around with Eddie Seay, and I said look, Kathy, you know, everybody in Hollywood knows that you and this boy live together right here on this boulevard, everybody knows it. You’re no witness to Christ; you are nothing, to be running around like this in the streets together, when everybody knows what has transpired between you. So, do something about it, you know, either leave the boy alone, leave this man alone, or do something about it, one way or the other. So, they got married. Kathy’s story was that he had robbed a place in Beverly Hills, whether there is anything to it, I don’t know.
Q. Was he a born again, Eddie Seay?
A. Eddie Seay was a strange person. He has a personality that I cannot explain to you. I don’t know.
Q. Was he living within the Foundation or—
A. Well, after they married, he came and lived in the Foundation for a short period of time, but Kathy was always coming to us that he was robbing places and that he was smoking pot and he was doing this and he was doing that, and finally Eddie just left.
And I take it you didn’t see him anymore for several years? A. Never saw him anymore for years.
Q. Or did you ever see him again after that?
A. We ran on to him one time in Nashville. Well, after Don came to you in ‘70, or ‘71, how long after he was around you was it before he was born again?
A. Oh, Don made a decision for Christ immediately when he came.
Q. You all talked to him and—
A. Oh, yes, immediately. He said that was exactly what he wanted to do with his life, and–yes.
Q. And, then, how long was it had he been in the organization before he and Kathy kind of got attracted to each other or whatever you call it?
A. We had moved to Sagass, we had gone through the Ed Mick thing, I don’t know.
Q. Did it—
A. It could be from two to four years.
Q. Did Ed Mick remain in the organization?
A. Ed Mick left.
Q. At the time of this confrontation that he and Kathy—
A. Yes, Ed left.
Q. And has not returned? another relationship like she had with Eddie Seay–
A. Yes, that’s exactly what I thought.
Q. —and Eddie and cause conjugality—
A. Yes, that’s exactly what I thought.
Q. All right. And, so, where were they married?
A. At the church, at the church. We took them to Beverly Hills and we bought Don a lovely white suit at one of the expensive shops in Beverly Hills, Kathy, a beautiful wedding dress.
Q. White?
A. I would say off-white, you know, I’m not trying to be flip.
Q. And, then, did they have a home within the organization?
A, Oh, yes.
Q. Tell me about their home. I think you described it off the record a few minutes ago, tell me the home that they left.
A. They left a beautiful 100,000…125,000 dollar home, two baths, three bedroom, polished rock floors and a fireplace, furnished in very expensive furniture, name brands, Broyhill, Thomasville. The Foundation paid for that. The Foundation made the payments on the property and the Foundation bought the furniture.
Q. Well, it was all in the Foundation’s name, wasn’t it?
A. Right.
Q. And what was the occasion, you think, for Don leaving, Mrs. Alamo?
A. Don and Kathy had begun to fight between themselves, about everything.
Q. As most married couples do—or beyond that?
A. No, it was beyond that, far beyond that.
Q. Incidentally, do you and Tony have—
A. Arguments?
Q. Squabbles or—
A. If you show me a couple that doesn’t have any, one of you isn’t needed.
Q. Are they pretty good ones, or are they just—
A. Oh, yes, we have several.

Now, that’s not material, Charles. The relationship of Susan and Tony has nothing to do with this.

Q. Okay. Go ahead, he—Roy is always interrupting and getting me off on—
A. Of course, we have disagreements, if you’re two persons, you know.
Q. Probably strong willed.
A. Anyone—I think most of the arguments Tony and I had in ten years was over Kathy. I think the worst argument that we ever had was over me bringing Kathy to Nashville. It was the worst misunderstanding that we ever had.
Q. I assume, then, that since she has gone, everything has— I mean, at least, has been better, put it that way.
A. Yes, I would say it has been better.
Q. Okay. Now, did you ask Don to leave, also?
A. I never talked to Don.
Q. Never mentioned it to him?
A. No.
Q. Do you know whether or not Mr. Alamo did?
A. I think Tony had seen Don at the back door a few days before then. Don rushed up to the back door and said I’m sorry, Tony, I’ve taken all of her I can take, I just split her out good. And Tony stood there with his mouth open, wondering what in the world was going on. But I don’t—Don said that he was leaving, that he could not stay with her any longer and that he was leaving.
Q. Do you know, in talking about Don, do you know whether or not he was born of a wealthy family, or was his background pretty much the same as Kathy’s, or was he born of wealth?
A. Oh, I think that the father had some money. I don’t think anywhere to where it’s been made to be, from what I understand about it, that most of it was tied up in trust funds. I know that for—and then there was quite a litigation, some attorney beat him out of a fortune.

You’re guessing here, Susan.

A. Yes.
Q. Incidentally, did you all ever have any connection with Elvis Presley?
A. Yes.
Q. What kind of connection was that, please, ma’am?
A. Quite a lot down through the years.
Q. Business or personal or—
A. Both.
Q. Were you ever associated, Mrs. Alamo, with what is known as the Fleetwood Foundation?
A. No, there’s never been any Fleetwood Foundation, that I’m aware of.
Q. Do you have a member of your Foundation that owns the Sergeant Pepper chain in Nashville, Dorris?
A. Who?
Q. Dorris.

First name or last name?

Q. I don’t know. Do you know a Dorris or Doris of Nashville?
A. Oh, they’re not any member of our Foundation. We know some people in Nashville that used to have the Sergeant Pepper Stores, they went broke.
Q. Well, what was his name, Dorris what?
A. I don’t even remember, I don’t remember.
Q. Did he marry a girl in the Foundation?
A. Oh, no, heavens, no. He has a wife that he’s been married to, probably, for thirty-five years, grown children. When was this supposed to have happened?
Q. Don’t ask me.
A. You’ve got me curious now. My God, if Dorris left his hus—wife, that is incredible. Q. But you don’t know about it?
A. I don’t think she knows anything about it.

Well, it could have happened.

Q. Do you know a Jeannie Puckett?
A. Yes.
Q. Is she still in the Foundation?
A. Yes, she is.
Q. Where is she now?
A. The last time I saw her, she was at her house in Dyer.
Q. Okay. Will she be available for a deposition?
A. Oh, yes, she will.
Q. Are you telling me that all of the people out there that I want to depose, I can?
A. No, I’m not telling you any such thing.

That can be worked out with me, Charles. We’ll work it out, if you have somebody you want.

Well, I mean all I’ve got to do is serve a subpoena on them, but I—

Well, you don’t—just—you don’t even have to do that. You can just call me, we’ll work that out.

A. You know Jeannie Puckett lived in that upstairs room there with them, so that she would be there with their little girl at night. I think she would be a very, very good one, indeed, because she does know an awful lot.

Q. What’s her name?
A. Jeannie Puckett. And she’s one you’d want, for sure.
Q. Puckett, P-u-c-k-e-t-t?
A. Right, because she—whether she wanted to or not, was involved.

Q. You say she’s one that—one of the girls that slept at the foot of Don’s and Kathy’s bed?
A. No,
Q. Or slept in the room with them?
A. You do have a vivid imagination.
Q. No, I have a hearing problem.
A. I said that she occupied a room upstairs with a private that’s a beautiful outfit Soupy has on. And she she’d say I’ve had it in lay-a-way for months. She sure did. She laid it away yesterday and picked it up today, everything like that, continuously.
Q. Did you ever buy any clothes for Kathy and give her?
A. All the time, continuously, a fur coat at the Boston Store, the winter that she left.
Q. Incidentally, did Richard Hydell ever buy you a coat?
A. Did Richard Hydell ever buy me a coat? Not that I’m aware of.
Q. A mink?
A. Why would Richard Hydell buy me a coat?
Q. I just asked you the question, you can tell me yes or no.
A. Not that I’m aware of, Richard Hydell ever bought me any coat.
Q. Was there ever a mink coat bought for you through Richard Hydell’s account?
A. Richard Hydell’s account? This is most amazing.

Answer, if you know.

Q. Yes or no?
A. What kind of an account?
Q. Bank account.

She says she doesn’t know. Mr. Garner. Richard Hydell was taken out of all purchasing in California, because we caught Richard Hydell stealing money from the Foundation.

Q. Well, I repeat my question. Did Richard Hydell ever buy you a mink coat?
A. No, Richard Hydell never bought me any mink coat. Richard Hydell probably during the time that he was working on the purchasing very possibly picked up and shipped several coats, and expensive coats, to the Nashville Store. There would have been no reason why Richard Hydell would have been buying anything for me. He might have picked up a coat and shipped it, I don’t know about that. But Richard Hydell never bought me anything in his life.
Q. And no mink coat was ever bought for you through his—one of his bank accounts?
A. Well, I wish I knew he had a bank account.
Q. Well, I—
A. If he has a bank account, it’s Foundation money. Did Mr. Richard Hydell have a bank account?
Q. I take it, then, that your answer is no that he did not.
A. My answer is a question, does he—

Well, we’ll get to that when we take his deposition.

Q. Did you—was there ever a mink coat bought for you through Richard Hydell’s account, to your knowledge?
A. Richard Hydell never had any bank account, to my knowledge.
Q. So, therefore, no mink could have been bought through his account for you, right?
A. Did Richard Hydell ever have any bank account that you—

Not to my knowledge.

Just answer it as best you can, of course.

Q. Who are Don and Kathy Hanks?
A. Oh, they’re some people that have been in and out and around Fort Smith for any number of years.
Q. Are they—were they once employed by the Foundation?
A. A very short time.
Q. In what capacity?
A. Music.
Q. Who—him or her or both?
A. Both of them.
Q. And who employed them?
A. Tony.
Q. And in what capacity?
A. Music director.
Q. Music director for the Foundation, down there?
A. Choir.
Q. And how long were he, or they, at the foundation?
A. A very short time, a very short time.
Q. Do you know how much they were paid?
A. I think $1200 a month.
Q. And when you say a very short time, are we talking about the term of one month or one year, or— A, Oh, not a year, not at all. Don Hanks went over and opened up some kind of a little shop here on—

Just ans—how long were they employed?

A. I don’t know, Roy, a short time.
Q. Do you know where they are now?
A. Yes, they’re in Tulsa with Don and Kathy.

Q. Do they live with Don and Kathy or—
A. They’re all there together. Don Hanks owes us quite a bit of money. If you happen to run onto him, ask him to pay his bill.
Q. What does he owe it to you for?
A. Labor, for our boys.
Q. For what?
A. A whole crew of our boys, on a big construction job that he never paid a dime of.
Q. Only one or two more, what banks did you do business -, through in California?
A. I don’t do any business in a bank, my husband does all the banking.
Q. And you still don’t?
A. Still don’t.
Q. Are your weekly television talks, Mrs. Alamo, taped?
A. Yes.
Q. Are they taped ahead or—
A. Yes.
Q. How far ahead?
A. I—really, it would be optional. It would be optional to how often we are taping.
Q. Well, what I see live on Sunday is not live, I mean—
A. No.
Q. —it’s taped ahead, video taped?
A. Uh-huh (yes).
Q. Who has those tapes?
A. We do.
Q. Does the–do you do your own taping or does some studio do the taping?
A. Oh, we have taped everywhere from Hollywood to Nashville, to Virginia Beach, Charlotte, North Carolina, remote control units, that would be optional, again.
Q. Where are those tapes located?
A. Where are the located?
Q. Yes, ma’am.
A. The Ed Mick thing.
Q. How was she taken off?
A. She was just taken off the papers.
Q. And you two are the only two, now?
A. No, no, we’re not.
Q. Who are the other members of the Foundation?
A. I don’t know.
Q. I mean—well, are you an officer, still?
A. Yes.
Q. Well, do you have meetings?
A. Yes.
Q. Who all was present down at the last meeting?
A. There are three of us.
Q. Who is the other one?
A. Larry LaRoche.
Q. Larry Laroche. And where is he, please, ma’am?
A. At the office.
Q. At what office?
A. Our Dyer office.
Q. Dyer office?
A. Uh-huh (yes).
Q. And how long has he been on your board or—
A. Since Kathy was taken off.

You’re calling him a member of the Foundation.

Yeah, member of the Foundation.

I’m not sure about that.

Well, I’m not either. If I’ve used the wrong denominator, descriptio per sonar, you know…

Q. You say since Kathy—when did Kathy leave the Foundation?
A. Oh, I have records, but I don’t know, I couldn’t tell you just offhand.
Q. What kind of records do you have about her leaving?
A. Well, the date that she left and letters that she had written back, stacks of them, and all sorts of things.
Q. Who has possession of those letters?
A. I do.
Q. Pardon?
A. I do.
Q. Would you make copies of them available to Mr. Gean, in order that he may furnish them to me?
A. I’ll give them to Mr. Gean and Mr. Gean can do what Mr. Gean wants to do with them.

Roy, will you see that I get Zero: copies of them?

Doesn’t your client have copies of them?

Of course, you don’t make copies when you write personal letters, Roy. MR. GEAN:
Well, I don’t know if they’re personal letters or business letters.

Well, either way, I’m requesting—

A. They had a letter-writing campaign that they were writing, too—

I’m requesting for the purpose of the record that Mr. Gean and his client furnish me with copies of each and every piece of correspondence, which they have, which they allege that my client wrote or signed or caused to be written. Will you do that, Mr. Gean?


All right.

I’ll get them and then I’ll get in touch with you about it.

Q. Incidentally, did you ever borrow any money from Elvis Presley?

What difference does that make? Charlie, who they borrowed money from and so forth, I just don’t think that that’s material.

Well, it’s in the Foundation.

Well, what difference does that make, insofar as holding Kathy Wylie as a prisoner, false imprisonment? We’re going to object.

It goes to the financial status of the thing, Roy.

Well, I’m going to object.

You know, we’re entitled to show financial worth in cases of this sort.

I don’t know whether you are or not.

Well, the Arkansas Supreme Court says you are—

Well, we’re not to that far.

MR. ALAMO: I’m not worried about any financial situation—

-I know—

I hope they do. Okay, that’s fine.

A. Let me say this to you, Kathy Wylie would not know if we did or if we didn’t.

Q. Well, Mrs. Alamo, to ease your mind a little, please rest assured that I’ve talked to more people and got more stuff than Kathy Wylie, and what I was going to ask you about Elvis Presley—

The question that we’re talking about, Charles, is whether they borrowed money from Elvis Presley, and I don’t think it’s material, and as your attorney, I’m telling you not to answer it.

I think she’s already explained that I do all the business, anyway, so how can –

Well, whoever told me what they told me was very nice, they said you paid him back, there was no derogatory— I don’t know where you’re getting everything is derogatory, the information—

Nobody says it’s derogatory, it’s not relative.

I thought it was very nice. I mean whoever told me whatever it was was very complimentary, said that you borrowed $700 from Elvis Presley and that you paid him back.
A. That’s not so.
Q. Well, I don’t know whether it was or not.
A, Absolutely not.

Don’t answer any more questions about borrowing money.
A. I know that Kathy told Don that she went out to Elvis Presley’s house with us, too, but it is not so. As a matter of fact, some of the people are still alive that were there, that could tell you it is not so.

Who are those people?
A. Well, Red Webster was.
Q. Red who?
A. Red Webster. Kathy was never at Elvis Presley’s house.
Q. With you?
A. Ever, I don’t think she was ever there, period.

Well, you don’t know.
A. Now, she told Don, I know, because Don asked us about it one time. I said well, Don, Kathy wasn’t—she doesn’t know anything about that.

Q. Mrs. Alamo, when you were down in Mexico, getting married, did you also get a divorce?

How, when are you talking about, what date?

Q. 8-20—after 8-20-1966.
A. Well, now, we’ve gone all through that, Mr. Gean.

You don’t need to answer that. That’s before the Foundation was organized, hasn’t got anything to do with this lawsuit.

Okay. I think that’ll be all.


In: Legal & Court Documents, Tony Alamo's Secrets Exposed

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