Willis Carto archive

Including information about his associates

Deposition of LaVonne and Lewis Furr — March 14, 2000

                                                                 1
 1         IN THE CHANCERY COURT OF GARLAND COUNTY, ARKANSAS

 2

 3   LEGION FOR THE SURVIVAL OF
     FREEDOM, INC.                                      PLAINTIFF
 4
     VS.                      NO. 97-221
 5
     LEWIS FURR AND LAVONNE FURR                        DEFENDANT
 6

 7

 8   _____________________________________________________________

 9
               ORAL DEPOSITION OF LAVONNE AND LEWIS FURR
10
     _____________________________________________________________
11

12
                             MARCH 14, 2000
13

14   APPEARANCES:

15   ON BEHALF OF THE PLAINTIFF:     ON BEHALF OF THE DEFENDANT:

16   MS. ROSALIND MOUSER             MR. MARC HONEY
     RAMSAY, BRIDGFORTH, HARRELSON   HONEY LAW FIRM
17    & STARLING                     1801 WEST CENTRAL AVENUE
     ELEVENTH FLOOR                  HOT SPRINGS, ARKANSAS 71901
18   SIMMONS BANK BUILDING
     PINE BLUFF, ARKANSAS 71601
19

20

21

22                     KELSO COURT REPORTING FIRM
                          NORTH JACKSON STREET
23                    LITTLE ROCK, ARKANSAS 72207
                             (501) 661-1515
24
         LITTLE ROCK * PINE BLUFF * HOT SPRINGS * RUSSELLVILLE
25
     _____________________________________________________________
			
			
                                                                 2



 1                             I N D E X

 2

 3   STYLE AND NUMBER. . . . . . . . . . . . . . . . . . . . . . 1

 4   APPEARANCES. . . . . . . . . . . . . . . . . . . . . . . . .1

 5   STIPULATION PAGE. . . . . . . . . . . . . . . . . . . . . . 3

 6   WITNESS:  LAVONNE AND LEWIS FURR

 7             Examination by Ms. Mouser. . . . . . . . . . . . .4

 8             Deposition Concluded. . . . . . . . . . . . . . 231

 9   COURT REPORTER’s CERTIFICATE. . . . . . . . . . . . . . . 232

10

11   EXHIBITS:                                             MARKED:

12   Exhibit No. 1 - Power of attorney. . . . . . . . . . . . .156

13   Exhibit No. 2 - Power of attorney. . . . . . . . . . . . .156

14   Exhibit No. 3 - Affidavit. . . . . . . . . . . . . . . . .159

15   Exhibit No. 4 - Letter of 10-25-93. . . . . . . . . . . . 164

16   Exhibit No. 5 - Confirmation of payment. . . . . . . . . .164

17   Exhibit No. 6 - Letter of 11-1-93. . . . . . . . . . . . .164

18   Exhibit No. 7 - Letter of 11-1-93. . . . . . . . . . . . .164

19   Exhibit No. 8 - Letter of 12-9-93. . . . . . . . . . . . .164

20   Exhibit No. 9 - Letter of 3-22-94. . . . . . . . . . . . .164

21   Exhibit No. 10 - Letter of 6-30-94. . . . . . . . . . . . 164

22   Exhibit No. 11 - Letter of 8-4-94. . . . . . . . . . . . .164

23   Exhibit No. 12 - Check No. 2004. . . . . . . . . . . . . .164

24   Exhibit No. 13 - Check No. 2006. . . . . . . . . . . . . .164

25   Exhibit No. 14 - Check No. 2046. . . . . . . . . . . . . .164



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                                                                 3



 1                    I N D E X  C O N T I N U E D

 2   Exhibit No. 15 - Checking account. . . . . . . . . . . . .189

 3   Exhibit No. 16 - Check No. 2442. . . . . . . . . . . . . .196

 4   Exhibit No. 17 - Check No. 27492. . . . . . . . . . . . . 196

 5   Exhibit No. 18 - Power of attorney. . . . . . . . . . . . 198

 6   Exhibit No. 19 - Resolution. . . . . . . . . . . . . . . .202

 7   Exhibit No. 20 - Letter of 9-16-93. . . . . . . . . . . . 208

 8   Exhibit No. 21 - Revocation of resignations. . . . . . . .208

 9   Exhibit No. 22 - Checks from Independence House. . . . . .211

10   Exhibit No. 23 - Court exhibit. . . . . . . . . . . . . . 218

11   Exhibit No. 24 - Letter of 4-16-96. . . . . . . . . . . . 225

12   Exhibit No. 25 - Letter of 3-24-94. . . . . . . . . . . . 225

13   Exhibit No. 26 - Letter of 10-6-95. . . . . . . . . . . . 226

14

15

16

17

18

19

20

21

22

23

24

25



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                                                                 4



 1                      LAVONNE AND LEWIS FURR,

 2

 3             PRODUCED, SWORN, AND EXAMINED at the office of

 4   Wood, Smith, Schnipper & Clay, 123 Market Street, Hot

 5   Springs, Arkansas, on March 14, 2000, beginning at 10:25

 6   a.m., the above-entitled cause now pending in the Chancery

 7   Court of Garland County, Arkansas, said deposition being

 8   taken at the instance of counsel for the plaintiff.

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                   5



 1   THEREUPON,

 2                      LAVONNE AND LEWIS FURR,

 3   having first been duly sworn by the undersigned Notary Public

 4   to tell the truth, the whole truth, and nothing but the

 5   truth, deposed as follows:

 6                        EXAMINATION

 7   BY MS. MOUSER:

 8   Q    Mr. and Mrs. Furr, as you know, my name is Rosalind

 9   Mouser, and I'm an attorney for the Legion for the Survival

10   of Freedom.  And you and I have seen one another several

11   times in the past.  And first of all, I appreciate your being

12   here today.  And my understanding, that all of the matters

13   between both of you and the legion have settled.  And as one

14   of the conditions of settlement, you graciously agreed to

15   appear, to put under oath, and to be deposed in regard to any

16   assets of the legion, where they may have been since your

17   disinvolvement from the corporation and if you have any

18   current knowledge.

19        As you know, the legion has agreed not to pursue either

20   of you or your assets with your agreement to be here today.

21   And first let me say I apologize.  I was late between the

22   18-wheeler that both Ms. Miller and I encountered and the

23   moving of a house.  We've never had that happen before, but

24   the house, hopefully, will get moved safely.

25        As I understand it, the purpose of a deposition is just



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                   6



 1   to try to find out information that may be within your

 2   knowledge, Mrs. Furr, and your knowledge, Mr. Furr, that our

 3   client, the legion, would not have.  Most of the time when we

 4   do a deposition, it’s for the purposes to maybe use it at a

 5   later trial date.  But, of course, that’s not really what

 6   we're doing here today.  This is more, as Mr. Honey has said,

 7   is a discovery deposition, just to glean information that may

 8   be used by the legion in other matters, particularly, for

 9   example, matters involving Willis Carto, W-i-l-l-i-s

10   C-a-r-t-o.  And we'll mention him later.

11        Ms. Miller is here to take down every word that is said.

12   If we nod our head up and down or side to side, she will try

13   to record that.  So if you are asked questions, I would ask

14   if you would try to verbalize your answer.  A huh-uh or an

15   uh-huh is hard to record, so if you'll try to say yes or no.

16            MS. MOUSER:  Mr. Furr, I'm aware of your hearing

17   challenge, and I'll try to speak very clearly and loudly.  If

18   I get to where I'm screaming, tell me.  It’s okay.

19            MR. HONEY:  All right.  Are you hearing all right

20   now?

21            MR. FURR:  Yeah.  I can hear her.

22            MR. HONEY:  Good.  Good.

23            MS. MOUSER:  Okay.  Okay.  No one has ever accused

24   me of speaking too softly, I'm afraid.  That’s not a problem

25   I have.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                   7



 1   Q    (By Ms. Mouser)  The other thing is, is I'm aware both

 2   of you are wiser in years, and to the extent that we need to

 3   take breaks, you just need to let me know.

 4        If I ask you something and you don't know the answer,

 5   you just need to tell me.  I don't know.  Sometimes we think

 6   when lawyers or anyone asks us a question, they think we know

 7   the answer.  That’s not true in depositions.  Sometimes we

 8   don't know if you know or not.  And if you don't know, just

 9   tell me you don't know.  It would be much better to do that

10   than to guess.

11        If I ask you something and you want to talk to Mr. Honey

12   before you answer, that is fine too.  That is not a problem.

13   We'll take a break.  You-all can step out in the hall or

14   Ms. Miller and I will step out.

15        If I ask you a question and you don't understand it, it

16   is very, very acceptable for you to say, Ms. Mouser, I don't

17   understand what you're asking me.  Would you ask it again?

18   If I ask you two questions at one time and try to confuse you

19   — maybe I don't mean to confuse you, but if it confuses you,

20   just say, Well, look.  Repeat the question or don't ask me

21   two things at one time.  Okay?

22        Now, Mrs. Furr, do you understand those are kind of our

23   guidelines today?

24   A    Yes, I do.

25   Q    All right.  Thank you, ma'am.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                   8



 1            MS. MOUSER:  And, Mr. Furr, do you understand?

 2            MR. FURR:  Yes.

 3   Q    (By Ms. Mouser)  Now, one other thing we're going to do

 4   today, primarily because we're not in an adversarial

 5   situation — I've never done this before, and I don't think

 6   Ms. Miller has either.

 7            MS. MOUSER:  Mr. Honey, have you ever done this

 8   before.

 9            MR. HONEY:  I think on one other occasion.

10            MS. MOUSER:  Okay.

11            MR. HONEY:  Yeah.

12   Q    (By Ms. Mouser)  What we're going to try to do is depose

13   both of you at the same time.  And Ms. Miller is going to use

14   a fancy word on us as to how she’s going to actually record

15   Mr. Furr’s testimony because it’s actually going to be, Mrs.

16   Furr, your deposition with Mr. Furr’s supplemental answers.

17        If we don't do it this way, I'll have to ask you all the

18   questions and then repeat them all with Mr. Furr.  That seems

19   to me to be a waste of everybody’s time, particularly both of

20   yours.  It just doesn't seem to be very efficient.  So I'm

21   going to have to be real careful not to speak over you, and

22   if you-all could try be careful and not speak over one

23   another.

24        But what I'd kind of like to do after we leave here

25   today is have a story where both of you probably can give me



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                   9



 1   information to complete the story, because obviously I'm on

 2   the outside.  You-all have knowledge; my client believes it

 3   has knowledge.  And what we're trying to do is just really

 4   get your side of the story today.

 5        Okay.  Mrs. Furr, do you understand?

 6   A    Yes, I do.

 7            MS. MOUSER:  Mr. Furr, do you understand?

 8            MR. FURR:  Yes.

 9   Q    (By Ms. Mouser)  Mrs. Furr, would you state your name

10   for the record, please, ma'am.

11   A    LaVonne Doden Furr.

12   Q    Is Doden, D-o-d-e-n?

13   A    Correct.

14   Q    And where do you currently reside?

15   A    Morphew Road, Hot Springs, Arkansas.

16            MS. MOUSER:  And, Mr. Furr, would you state your

17   name for the record, please, sir.

18            MR. FURR:  Lewis B. Furr.  That’s L-e-w-i-s.

19            MS. MOUSER:  And where do you currently reside?

20            MR. FURR:  260 Morphew Road.

21            MS. MOUSER:  And that’s here in Hot Springs, isn't

22   it.

23            MR. FURR:  Hot Springs.

24            MS. MOUSER:  Yes, sir.

25   Q    (By Ms. Mouser)  Mrs. Furr, how long have you and



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  10



 1   Mr. Furr resided in Hot Springs?

 2   A    December '91 we moved here, which is almost — what?

 3   Nine years?

 4   Q    Yes, ma'am.

 5        And why did you-all choose to locate in Hot Springs?

 6   A    My son bought this little house that we live in.  He

 7   wanted us to fix it up for a hunting camp.  And we've been

 8   fixing it up, but we're still there.

 9   Q    And do you intend to continue to reside there for the

10   next, say, year or so?

11   A    I believe so.  It depends on Mr. Furr’s health.  And

12   he'll be 80, and the yard is kind of big.  And, in fact, our

13   son is talking about, you know, maybe — we can't continue to

14   do what we're doing.

15   Q    Sure.  Sure.  Let me ask you, today, are you on any

16   medication that you feel would prevent you from hearing or

17   understanding questions that I would be asking you?

18   A    No.

19            MS. MOUSER:  Mr. Furr, are you currently taking any

20   medication which would prevent you from hearing or

21   understanding what I'm going to be asking you.

22            MR. FURR:  I'm taking some medication, but I don't

23   think --

24            MS. MOUSER:  You're not drowsy or anything like

25   that?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  11



 1            MR. FURR:  No.

 2            MS. MOUSER:  Okay.

 3   Q    (By Ms. Mouser)  Now, your son lives where?  The son

 4   that bought the home on Morphew Road here in Hot Springs,

 5   where does he live?

 6   A    Colorado.

 7   Q    And he basically bought that home to fix up and for a

 8   hunting camp sort of?

 9   A    Fishing.

10   Q    And has anyone been there fishing since you've been

11   there?

12   A    No.

13   Q    If you choose to move from Hot Springs, do you have any

14   idea where you might go?

15   A    No.

16   Q    Now, just for the record, Mrs. Furr, how old are you?

17   A    72.

18   Q    You volunteered Mr. Furr’s age, so I don't have to ask

19   Mr. Furr.

20        You-all have been married, I know, a long time.  How

21   long have you-all been married?

22   A    Be 53.

23   Q    All right.  And I believe you were born — were you born

24   in Texas?

25   A    No.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  12



 1   Q    Where were you born?

 2   A    Iowa.

 3   Q    And I know you lived in Texas for awhile.  When did you

 4   move to Texas?

 5   A    I was --

 6   Q    Were you a teenager, perhaps?

 7   A    Oh, no.

 8   Q    No?

 9   A    I was 36.

10   Q    Did you graduate from high school?

11   A    Yes, I did.

12   Q    And do you have any subsequent education to high school?

13   A    I have a year in college.

14   Q    And were those general studies?

15   A    General.

16   Q    What about your employment history after high school?  I

17   know you've had several jobs.  What basically have you done

18   as far as work is concerned?

19   A    Housewife.

20   Q    Did you ever work outside the home?

21   A    No.  Except when my husband was clerk of the court, I

22   would — he would bring typing home for me from the office.

23   Q    Yes, ma'am.

24   A    Because I was real sick.  And that was the main thing,

25   doing — I think I typed probates.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  13



 1   Q    Would that be help — more of assistance to him rather

 2   than a job actually you had?

 3   A    It was assistant.

 4   Q    You weren't separately compensated for that work by the

 5   Court, were you?

 6   A    No.

 7   Q    Not that you can recall?

 8   A    Not that I can recall.

 9   Q    How many children do you and Mr. Furr have?

10   A    Three.

11   Q    I know one son lives in Colorado.  Where do the other

12   two children live?

13   A    Louisiana.

14   Q    Both in Louisiana.

15        Now, I know at one time you began doing volunteer work,

16   perhaps, with what I know to be the Legion for the Survival

17   of Freedom — what I think I know to be the Legion for the

18   Survival of Freedom.  Is that correct?

19   A    Yes.

20   Q    And when I say volunteer work, you did not describe it

21   as a job, so would it be more, in your opinion, volunteer

22   work?

23   A    It was volunteer.

24   Q    Were you ever — in all the years that you worked for

25   the legion or any other entity that was related to the



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  14



 1   legion, were you ever compensated for your work?

 2   A    I was compensated for work with American Mercury

 3   Magazine.

 4   Q    And was that early on when you began your affiliation

 5   with what I know to be the legion or a similar group?

 6   A    Mr. Matthews bought the American Mercury in 1962.  So

 7   his wife had died.

 8   Q    Uh-huh.

 9   A    And so, therefore, I worked for the American Mercury,

10   which was under the legion.

11   Q    And was that Hoyt Matthews?

12   A    H-o-y-t.

13   Q    H-o-y-t, uh-huh.

14        And then was it actually the Legion for the Survival of

15   Freedom to begin with or was that a later name?

16   A    Mr. Matthews and Mrs. Matthews founded the Legion for

17   Survival, which was a daily or — I really don't know for

18   sure if it was daily or just something like Paul Harvey.

19   Q    Uh-huh.  Uh-huh.

20   A    He founded it in 1952.

21   Q    Now, I'm not going to try to figure out how old you were

22   in '52, but were you associated with them when they founded

23   it?

24   A    I never met them until 1963.

25   Q    And is that when you began your volunteer work with



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  15



 1   them?

 2   A    Right.

 3   Q    How did you begin that volunteer work with them?  Were

 4   they in Texas?

 5   A    Yes.

 6   Q    And were you also residing in Texas?

 7   A    No.  My parents — just let me tell — I'll tell you how

 8   it’s done.

 9   Q    Yes.  If you don't mind, yes, ma'am.

10   A    My parents moved from Louisiana to McAllen, Texas.  The

11   radio broadcast only was beamed in Texas.

12   Q    This is the legion’s radio broadcast?

13   A    The legion’s radio broadcast.  And my father heard it,

14   and in '63 he got acquainted with Mr. Matthews.  And having

15   three children in school, the only time I could visit my

16   parents in McAllen, Texas, was the day after school was out,

17   I went to McAllen, Texas.  They were real little.  And he had

18   a swimming pool.  And a week before I got there, his wife had

19   died.

20   Q    Now, would that be your mom?

21   A    No.  His wife.  Mrs. Matthews died.

22   Q    Oh, I'm sorry.  Excuse me.  Her name was Marsha, I

23   believe.

24   A    Right.  Her daughter was also Marsha.

25   Q    Okay.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  16



 1   A    He asked Mr. Matthews, Can I bring my grandchildren out

 2   to go swimming?

 3   Q    Sure.

 4   A    So I went too.  And he excused himself, and my daddy

 5   said, He’s got some condolences to answer.

 6   Q    Sure.

 7   A    There was other volunteer girls, and she wasn't there.

 8   LaVonne, can't you go and address --

 9   Q    Help.

10   A    — some of them and help.  That’s how it all got

11   started.

12   Q    And at that time, it was the Legion for the Survival of

13   Freedom?

14   A    Right.

15   Q    At that time, when you first began doing volunteer work,

16   Mrs. Furr, what was your understanding of what the purpose of

17   that entity was?  What was the goal?

18   A    At the time I started, it was just cleaning up the place

19   and money was sent in, and I helped with the bank deposit and

20   just --

21            MR. HONEY:  She’s not asking you about what you did.

22   She’s asking a larger question as to the general purpose of

23   the organization.

24            MS. MOUSER:  But that’s okay.  Yeah.  That’s okay.

25   Q    (By Ms. Mouser)  I was wondering if you had — when you



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  17



 1   began, did you have a feel for what they were trying to do,

 2   what the legion was trying to accomplish?  Not on a

 3   day-to-day basis, but overall, were they — you know,

 4   churches, obviously, are trying to convert people to

 5   Christianity, that kind of thing.  What was the legion trying

 6   to do, as you understood it, early on?

 7   A    To promote freedom for the United States of America.

 8   Q    All right.  Now, this was in '63?  Did you say '63 or

 9   '66?

10   A    Well, it started with their theme.

11   Q    Way back?

12   A    In '52.

13   Q    Right.  But when you began doing some volunteer work?

14   A    That’s what I considered it.

15   Q    Was that in the '60s?

16   A    '63, '62.

17   Q    Right.  Now, here we go.  I'm going to test my history.

18   We were not in Vietnam yet, full-fledged, so was this

19   something you think that carried over from the Korean War?

20   What was Mr. Matthews — what seemed to be — I know you

21   never met Mrs. Matthews.  What seemed to be Mr. Matthews'

22   motivating force, if you ever had an understanding of that?

23   A    Against communism.

24   Q    That was the big threat then.

25   A    Yeah.  That was it.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  18



 1   Q    Of course, Russia — I think we were all — was a big

 2   threat then.  May still be today, but we won't get into that.

 3   But I'm assuming communism and Russia, eastern Europe, those

 4   were Mr. Matthews' major concerns, as you understood it.

 5   A    And also, they would talk about different bills that

 6   were in the House, what — who it would help and who it would

 7   not help, things like that.

 8   Q    Was Mr. Matthews also concerned about socialism,

 9   perhaps?

10   A    Not that I'm aware of.

11   Q    And this is a very difficult question to answer,

12   perhaps, but let me go ask it.  Over the course of the years

13   that you did volunteer work for the legion, do you feel that

14   whoever acted as if they were in charge of the legion affairs

15   — do you feel that the goal of the legion, the focus of the

16   legion changed?

17   A    I think it took on a broader aspect.

18   Q    And when did you see that occurring?

19   A    I don't know any particular time because the magazine --

20   well, see, the radio broadcast ceased the minute she died.

21   Q    Now, why would that — the minute Mrs. Matthews died,

22   why would that have been?

23   A    He wrote the script, and she was the voice.

24   Q    How about that?  Okay.

25   A    And he was already in his --



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  19



 1            MS. MOUSER:  Off the record.

 2              (AN OFF-THE-RECORD DISCUSSION WAS HELD.)

 3   Q    (By Ms. Mouser)  I'm sorry.  Go ahead.  I'm sorry.

 4   A    Then he had the magazine.

 5   Q    And what magazine?  What was the name?

 6   A    The American Mercury Magazine.

 7   Q    And did you say how often that was published?

 8   A    When it first started by H. L. Mencken in 1924, I think

 9   it was a monthly.

10   Q    And how do you spell Mencken, if you recall?

11   A    M-u-c- — I don't --

12   Q    Okay.

13            MR. HONEY:  You don't know?

14            MS. MOUSER:  Yeah.

15            MR. FURR:  M-e-n-c- --

16            MS. MOUSER:  — -c-k-e-n-, maybe?

17            MR. FURR:  — -c-k-e-n-, I think.

18            MS. MOUSER:  Okay.

19   Q    (By Ms. Mouser)  But anyway, when it first began, it was

20   how frequently?

21   A    I do not know.

22   Q    When you began volunteering, other than just, you know,

23   doing the bank records, et cetera, how often was it

24   published?

25   A    It was quarterly.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  20



 1   Q    And other than the radio which ceased when Mrs. Matthews

 2   died, the American Mercury, were there any other publications

 3   that were regular in frequency?

 4   A    Not from McAllen, Texas.  After Marchita made Willis

 5   Carto and I incorporators, he merged the Washington Observer.

 6   Q    When you say he merged it, he merged it into the

 7   American Mercury?

 8   A    Into the legion.

 9   Q    Oh.  Into the legion.

10        And was it published still separately from the American

11   Mercury?

12   A    Correct.

13   Q    And if you know, how frequently was that published, do

14   you think?

15   A    The months that the Mercury was not published, the

16   Washington Observer came out twice a month.

17   Q    Now, let’s go back.  Marchita, M-a-r-c-h-i-t-a, was that

18   the Matthews' daughter?

19   A    That’s correct.

20   Q    And maybe her given name was Marsha like her mother's

21   and you-all called her Marchita --

22   A    Marchita.

23   Q    — maybe to distinguish between the two?

24   A    (The witness nods head up and down.)

25   Q    Now, other than the radio which ceased when



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  21



 1   Mrs. Matthews died, the American Mercury, and the Observer,

 2   were there any other — I've seen the Noontime Press name.

 3   What was that?

 4   A    That was Americana, history books.

 5   Q    Oh, it was just a publication company.  It wasn't a

 6   separate publication of itself?  There wasn't a newspaper

 7   quarterly or something that came out called Noontime Press?

 8   A    It was books.

 9   Q    And was that owned — that publishing company, was it

10   owned by the legion?

11   A    It merged into the legion.

12   Q    Who owned it before it merged?  Do you know?

13   A    No.  I don't know who owned it.  I can't remember.

14   Q    I've also seen the name Institute for Historical Review.

15   Is that a publication or something — IHR, is that a

16   publication?

17   A    They did put out — that’s — I left in 1979.  And that

18   happened after I left, so --

19   Q    You may not know about that.

20   A    I know that it existed.

21   Q    Uh-huh.

22   A    But I don't know --

23   Q    I think actually what I've seen is like Institute for

24   Historical Review, which would imply to me that it wasn't a

25   publication necessarily.  That institute might have published



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  22



 1   things, but that would never have been the name necessarily

 2   of a publication.

 3   A    No.

 4   Q    Yeah.  Now, other than the summers when you went to

 5   Texas, did you in the fall or late summer, did you go back to

 6   Louisiana with the children?

 7   A    Yes.  For school.

 8   Q    Yes, ma'am.  And did you continue to do any volunteer

 9   work from the State of Louisiana?

10   A    No.

11   Q    Do you think you went every summer for a course of

12   years?

13   A    No.

14   Q    How many — let’s see.  I think you had mentioned in '63

15   was when you maybe first took the children down there and

16   Mrs. Matthews had just died.  And then you left in '79.

17   That’s about 13 years.  Of those 13 years, do you think you

18   went every other summer or how frequently do you think you

19   went to Texas?

20   A    The first time it was only four weeks because Mr. Furr

21   came and got me and helped me back to Louisiana.  The --

22   maybe the following fall, Mr. Matthews had a speaking

23   engagement, and I went down and stayed with my parents and

24   went out to the house to pick up the mail and take messages.

25   Q    Uh-huh.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  23



 1   A    That was only like two or three weeks while he was gone

 2   and making speeches.

 3   Q    Uh-huh.

 4   A    Then in '65, I --

 5   Q    And if you don't recall, Mrs. Furr, that is fine.

 6   A    — is when Marchita came down to sell their house, her

 7   parents' house.

 8   Q    Had Mr. Matthews died?

 9   A    No.  Not --

10   Q    No?

11   A    Well, yes, he had.  He died in --

12   Q    In '65?

13   A    He died in November of '64.  So she came down in

14   February of '65.

15   Q    Uh-huh.

16   A    And she was going through a divorce, and she says, I

17   cannot take on the responsibilities of the legion and the

18   American Mercury.

19   Q    Uh-huh.

20   A    And so she said, Who would you get to help you, you

21   know, with this?  Because I knew nothing about the publishing

22   business.

23   Q    Sure.

24   A    And I had heard Mr. Matthews talk about Mr. Carto, and

25   Mr. Carto had — which I hadn't read or didn't even know at



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  24



 1   the time — Liberty Lobby.

 2   Q    And when you say he had it, was that like a separate

 3   entity he was in charge of, Mr. Carto?

 4   A    Right.  He had nothing to do at all with the legion or

 5   the American Mercury at that time.

 6   Q    Yes, ma'am.

 7   A    And so I guess either she called him or I called him and

 8   wanted to know if he would be interested in helping.

 9   Q    Uh-huh.

10   A    And we met at the lawyer’s office in Houston, Texas.

11   Q    Uh-huh.

12   A    And that’s when she assigned that Willis and I would be

13   substitute incorporators.

14   Q    Now, up until the time in '65 when Mr. Matthews died,

15   what I would call all the corporate records — now, I've

16   understood from the very beginning that the legion is

17   actually a Texas corporation.  Is that your understanding?

18   A    A nonprofit corporation.

19   Q    Right.  A nonprofit Texas corporation.

20        Up until the time that Mr. Matthews died and the times

21   that you visited him and your parents and then did the

22   volunteer work, did he always work out of his home?

23   A    Correct.

24   Q    Was there ever a separate office for him?

25   A    No.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  25



 1   Q    And when you did the volunteer work, did you happen to

 2   see what I would call records of the corporation?  I mean,

 3   correspondence, checking account statements.  Were all those

 4   records kept in his home?

 5   A    Correct.

 6   Q    And then in '65 after he died, do you know what Marchita

 7   did with those records?

 8   A    Just left them in the house.  They were — it was a

 9   mess.  I mean --

10   Q    The house was?

11   A    Yes.  I mean, there was no record, really, keeping.  It

12   was — we found a little bit here and a little bit there, and

13   she knew more about it than I did.  And literally there was

14   boxes and boxes, and she assembled them as much as she could.

15   Q    And do you know what she did with those boxes?

16   A    She left them in with me until Mr. Carto — until we got

17   all the papers signed.

18   Q    Okay.

19   A    And see, then, in '6- --

20   Q    Let me back up.  Did you leave the boxes in

21   Mr. Matthews' home or did you move them to your parents'

22   home or what did you do with them?

23   A    We moved the whole office to Houston, Texas.

24   Q    And to a — to where in Houston?  I'm sorry.

25   A    To a house.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  26



 1   Q    Do you remember what that address would be?

 2   A    The only thing I can think of is Woodland.

 3   Q    And who owned that home at the time?

 4   A    It was rented.  I don't remember the person’s name.

 5   Q    And was that rented by the legion?

 6   A    It was rented — well, we always just said the American

 7   Mercury because that’s who paid — I never — you know, I

 8   paid all the checks by — the rent by American Mercury.

 9   Q    Was the American Mercury, to your knowledge, a separate

10   corporation?

11   A    It was under the legion.

12   Q    Sure.  It was the name of the publication.  And then was

13   it also kind of just used synonymously with legion or not?

14   A    I don't understand how you mean that.

15   Q    Well, like, if I was going to make a donation or when

16   people made their donations, would they usually make their

17   check payable to the legion or the American Mercury?  Do you

18   remember?

19   A    I think it came in both ways.

20   Q    So the home was actually probably rented, to the best of

21   your knowledge and memory, in the name of the American

22   Mercury.  All the boxes were moved there?

23   A    The back issues of the American Mercury.

24   Q    Sure.

25   A    And they were — from 1994 there was bound volumes that



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  27



 1   looked like these law books because they were bound because

 2   all those — there’s a lot of libraries throughout the United

 3   States were on the subscription list.

 4   Q    Yes.

 5   A    Because anybody who wrote for the American Mercury at

 6   the time when H. L. Mencken had it, you were a writer.  There

 7   was no — it wasn't romance or anything else.  It was --

 8   Q    Right.  Solely nonfiction?

 9   A    Almost like Shakespeare and things like that.

10   Q    Oh, okay.

11   A    We were very recognized.

12   Q    Yes.

13   A    And --

14   Q    But it was nonfiction, wasn't it?  It wasn't — like you

15   say, it wasn't romance and historical novels, that kind of

16   thing?

17   A    No.

18   Q    Right.

19   A    It — well, it changed hands, hands, and hands, and

20   finally — don't ask me why or how — but a religious

21   organization in Oklahoma City — and that’s who he bought it

22   from.

23   Q    I'm sorry, now.  Who is he?

24   A    Mr. Matthews.

25   Q    I see.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  28



 1   A    He bought the American Mercury.

 2   Q    I see.  This was at the beginning.

 3   A    Uh-huh.

 4   Q    Now, so we're in Houston.  And do you remember what the

 5   lawyer’s name was that was handling the substitute

 6   incorporator matter?

 7   A    Kenneth Graham.

 8   Q    Kenneth Graham.  And is he related, to the best of your

 9   knowledge, in any way to a Jack Graham?

10   A    I would not know.

11   Q    At that time were the initial incorporators, to the best

12   of your knowledge, Mr. and Mrs. Matthews?

13   A    And a lady — I had a little clipping out of a paper.

14   Frances --

15   Q    Was it Kerr, K-e-r-r?  No?

16   A    Frances Clark.

17   Q    Clark.  Okay.

18   A    I think.  Because I think I remember that I got a

19   souvenir piece of stationery.

20   Q    Uh-huh.  Yeah.

21   A    And I think that’s — I remember her name.

22   Q    And then once, of course, Mrs. Matthews died, did

23   Marchita come on?

24   A    Mr. Matthews appointed her to take her mother’s place.

25   Q    Right.  And then Mr. Matthews died, and then it became



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  29



 1   — did Marchita continue on or did she just say, I can't;

 2   don't have time?

 3   A    Well, for several months until we got — until she got

 4   organized and got, you know, over the grieving period, until

 5   she got into looking at things --

 6   Q    Sure.

 7   A    — and — because she lived in Florida.  So that’s when

 8   she — we sat down and talked, and that’s what she decided to

 9   do, that she just couldn't, you know — so she turned it

10   over, and I didn't know anybody else.

11   Q    Right.  And so at that point, it would be you and

12   Mr. Carto.  Was there anyone else as substitute incorporator?

13   A    There was only two.

14   Q    Do you know if Marchita is still living?

15   A    I do not think so.  I wrote a letter probably in the

16   '70s or — yeah.  In the '70s.  And it came back “deceased."

17   Q    What about how long, if you recall, were the records at

18   the house on Woodland in Houston, if you recall?

19   A    As long as I was there, about a year and a half.

20   Q    And did Mr. Furr and the kids move to Houston with you?

21   A    No, they did not.  I communicated back and forth.

22   Q    Bless your heart.  And how often do you think — were

23   you in Houston on a weekly basis?

24   A    I'd go a week at a time and then go home.

25   Q    And how old were your kids about this time?  Were they



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  30



 1   teenagers or --

 2   A    One was in high school.  And David was — last year of

 3   grammar school, I guess.  And we moved to California.

 4   Q    And if you need — you're looking at Mr. Furr, and since

 5   we're doing it together, if you need to ask him something,

 6   Mr. Furr can respond.

 7            MRS. FURR:  Do you --

 8            MR. FURR:  '67.

 9   A     '67.

10   Q    (By Ms. Mouser)  Now, when you-all — as a family you

11   moved to California?

12            MR. FURR:  That’s when the Mercury was — that's

13   when American Mercury and the office for the legion moved to

14   California.

15            MS. MOUSER:  Both American Mercury and the legion

16   were moved.

17            MR. FURR:  Yes.

18   Q    (By Ms. Mouser)  Now, before those businesses moved and

19   before you-all moved as a family, were the records always

20   kept at the house on Woodland in Houston?

21   A    I believe so.

22   Q    I'm sorry.  On the street named Woodland in Houston, not

23   on Houston.  I'm sorry.  In Houston.

24        And you were there maybe in that one-year period every

25   other week maybe?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  31



 1   A    I believe so.  Maybe two weeks when the children had

 2   Thanksgiving off and they'd come to visit.

 3   Q    Did you ever feel during the course of that year that

 4   people — anybody that was authorized or unauthorized was

 5   removing records from that building?

 6   A    No, ma'am.

 7   Q    Everything was pretty secure there, and that’s your

 8   recollection?

 9   A    Right.

10   Q    Yes, ma'am.  Now, in '67 why, do you believe, did the

11   Mercury and the legion move to California?

12   A    We moved to Houston because there was — McAllen, Texas,

13   if you know the state, is way down.

14   Q    I don't know.

15   A    It was way down the point.  And Mr. Matthews was mailing

16   and printing the American Mercury in Oklahoma City, because

17   that’s where all the facilities were.  There was none in

18   McAllen, Texas, whatsoever.  Well, we moved to Houston

19   thinking that we could have better control over the printing

20   and not the expense of going to Oklahoma City for

21   proofreading.

22   Q    Sure.

23   A    That’s what — you know.  So we, Marchita and I,

24   decided, Well, we'll move it to Houston.  We didn't find any

25   of the facilities there at all, and we continued from



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  32



 1   Oklahoma City.  And so I don't know how — my husband lost

 2   the election, and Mr. Carto presented, you know, moving to

 3   California.  The children, Disneyland.

 4   Q    Uh-huh.

 5   A    They all were excited to move.  So I said yes, that

 6   would be all right, because that’s where he — his office was

 7   and that’s where he lived.  And he could help me better than

 8   making a stop in Washington, D.C., to Houston to California.

 9   And my parents were not at Tallulah, Louisiana, any more, and

10   there was no ties there since he lost the election.  He was

11   without a job.  And everybody was agreed to --

12   Q    Move to California?

13   A    Thought it was an adventure.

14   Q    It was an adventure, wasn't it?  That was about '67.

15   Right?

16   A    Uh-huh.

17   Q    Let me go now to Mr. Furr, if I may, and ask Mr. Furr

18   about --

19            MS. MOUSER:  I think I know that you graduated from

20   Louisiana Tech.

21            MR. FURR:  Right.

22            MS. MOUSER:  I work with a bunch of guys from

23   Louisiana Tech, believe it or not.  And I think your degree

24   was in agriculture.

25            MR. FURR:  Correct.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  33



 1            MS. MOUSER:  And I think I know that you were what

 2   we would call a circuit clerk, but in Louisiana explain to me

 3   what exactly that you did.

 4            MR. FURR:  In Louisiana it’s called clerk of court.

 5            MS. MOUSER:  Yes, sir.

 6            MR. FURR:  We handle civil and criminal court

 7   records and probate and recorded — filed and recorded all

 8   deeds and mortgages.

 9            MS. MOUSER:  Uh-huh.  And you-all — that would be

10   of the parish, instead of a county.

11            MR. FURR:  Right.

12            MS. MOUSER:  In Louisiana I think they are parishes,

13   aren't they?

14            MR. FURR:  Correct.

15            MS. MOUSER:  Now, I didn't know until Mrs. Furr that

16   you actually had to run for that position.

17            MR. FURR:  Right.  It’s elected.

18            MS. MOUSER:  Now, how many years did you serve in

19   that capacity?

20            MR. FURR:  12 years.

21            MS. MOUSER:  And what were your terms?  How many

22   times did you have to run for office?

23            MR. FURR:  Every four years, 1948 to 1960.

24            MS. MOUSER:  Before that, Mr. Furr, how were you

25   employed?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  34



 1            MR. FURR:  I was — immediate employment, I was a

 2   driver’s license examiner.

 3            MS. MOUSER:  And before that what did you do?

 4            MR. FURR:  I was in the service.

 5            MS. MOUSER:  In the Army, as I recall.

 6            MR. FURR:  Yes.

 7            MS. MOUSER:  And did you serve actively?  And, if

 8   so, where?

 9            MR. FURR:  In Europe.

10            MS. MOUSER:  Thank you.

11            MR. FURR:  Very actively.

12            MS. MOUSER:  Now, you have heard the questions I've

13   asked of Mrs. Furr about Mr. and Mrs. Matthews.  Now, she

14   never met Mrs. Matthews — we're talking about Mrs. Hoyt

15   Matthews or Mrs. Marsha Matthews.  Did you ever meet her?

16            MR. FURR:  No.

17            MS. MOUSER:  Did you ever meet Mr. Matthews?

18            MR. FURR:  Yes.

19            MS. MOUSER:  Did you ever do any volunteer work

20   while the legion was located at McAllen?

21            MRS. FURR:  McAllen.

22            MS. MOUSER:  McAllen.

23            MR. FURR:  Very little, if any.  I'd occasionally go

24   down there while they were there for a few days, but — you

25   might say no.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  35



 1            MS. MOUSER:  Yes, sir.  And what about when the

 2   office moved to Houston?  Do you recall that you did any

 3   volunteer work at that time?

 4            MR. FURR:  No, I didn't.

 5            MS. MOUSER:  I would assume then most of the

 6   questions that I've just asked Mrs. Furr, to the extent that

 7   they involve her volunteer working for the legion, you would

 8   not have any personal knowledge of those facts.

 9            MR. FURR:  No.

10   Q    (By Ms. Mouser)  Now, the whole family moved — back to

11   you, Mrs. Furr.  The whole family moved to California in

12   about '67.  And at that time, did you continue the volunteer

13   work for the legion and the American Mercury?

14   A    No.  I started finally drawing a salary.

15   Q    Good.  Kind of making up for all that hard work you had

16   done.

17        At that time what exactly did you have — other than

18   substitute incorporator, did you have another title that you

19   recall?

20   A    Yes.  I had lots of titles.  I was a janitor.  I did the

21   mailing.  I did the banking.  I had a secretary that would

22   come and type three times a week for several hours for the

23   billing of the subscriptions to the American Mercury.

24   Q    Uh-huh.

25            MR. FURR:  She was managing editor of the Mercury.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  36



 1   A    Managing editor.

 2   Q    (By Ms. Mouser)  You were basically — from what I can

 3   tell, from what you've said today and from what I think I've

 4   read, you were basically the legion?

 5   A    Well, I always call it the American Mercury.

 6   Q    The American Mercury.  I'm sorry.

 7   A    Under the legion.

 8   Q    Right.  There might have been other people who you

 9   sought advice from, but basically, day to day, you were the

10   one that made sure everything got done?

11   A    Uh-huh.

12   Q    How did the actual records and books get from Houston to

13   California?  Do you recall?

14   A    They hired a truck to move them.

15   Q    When they got to California, were you in charge of the

16   unpacking?

17   A    No.

18   Q    When things finally did get unpacked, did you feel that

19   everything made the move from Houston to California?

20   A    As far as I could tell, it did.

21   Q    And then how long did you work for the American Mercury

22   in California?

23   A    Until November the 11th, 1979.

24   Q    And did any of your duties substantially change from '67

25   to November of '79?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  37



 1   A    They increased in hours.  The same duties but the same

 2   — longer hours and sometimes seven days a week.

 3   Q    Yeah.  Do you recall, just ballpark figures, when you

 4   were in McAllen, how much — and I know you weren't there

 5   every month.  But did you ever see any numbers that would

 6   give you a feel for the number of subscribers while the

 7   American Mercury was in McAllen?

 8   A    You're going to be surprised.  There was a mailing list

 9   of 24,000 or 30,000.

10   Q    In McAllen.

11   A    In McAllen.  They did not even bill anybody.  People

12   just donated money.  He borrowed money.  Mr. Matthews and

13   Mrs. Matthews sold their jewelry to get that magazine out,

14   and also at that time to support the radio broadcast.

15   Q    Had Mr. Matthews served in the Armed Forces?

16   A    He was — he traveled all over the world.

17   Q    But he was never pat of our military?  Do you recall?

18            MR. FURR:  I don't think so.

19   Q    (By Ms. Mouser)  This was just a burning desire he had

20   in his heart?

21   A    From traveling and seeing communism taking over from one

22   country to China.  And he was a pilot.  He trained Amelia

23   Earhart.

24   Q    Did he have a profession?  By training what was his

25   profession?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  38



 1   A    He knew everything.  He wrote music.  He wrote --

 2   Q    But as a job, how did he first start out making a

 3   living?  Was he a lawyer?  Was he a banker?

 4   A    He was 87 years old.  I don't know way back then at all.

 5   He was 87 years old or 89 when he died, so, I mean, all I

 6   knew, that he wrote music; he wrote poetry.

 7   Q    Uh-huh.

 8   A    He was just a --

 9   Q    A brilliant person.

10   A    Very much.  He was a photographer in Europe.

11   Q    So the 24 to 30,000 on the subscription list, about the

12   time you-all were in McAllen.  Right?  Now, in Houston would

13   you have any recollection of the number on the subscription

14   list?

15   A    No.  I don't remember that because we started billing.

16   And, of course, a lot of — he had the American Mercury on

17   all the airplanes, and it was all donated, I guess.  I mean,

18   it was a mess.  They never — and, finally, I had the long --

19   make a copy on 3 by 5s of all — and the expiration dates.

20   And there was no expiration date.  So I had a girl come in,

21   and we started billing.  And, of course, some people said,

22   I've never subscribed, you know, like that.

23   Q    Right.

24   A    And I think finally — so we put all those names in what

25   we call the inactive file.  And then I think we were even



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  39



 1   down to maybe like finally — maybe 5,000 paid subscribers.

 2   Q    And that’s in Houston?

 3   A    That was in Houston.  And the magazine really, before

 4   Mr. Carto helped me with it, it was horrible.  It was just a

 5   few pages put together just to keep up with the post office

 6   regulations --

 7   Q    Yes, ma'am.

 8   A    — that I remember.  And then with Mr. Carto’s

 9   supervision, it started increasing.

10   Q    Now, was that while it was still in Houston?

11   A    No.  Oh, he might have sent some articles.  I don't — I

12   don't remember exactly when.  But finally when we got

13   everything to California, it started to improve.

14   Q    Uh-huh.  And we're talking now — you're talking now by

15   way of not only content of the American Mercury but also

16   subscriptions?

17   A    But also — correct.

18   Q    When you left in '79, do you happen to remember the

19   approximate subscriptions?

20   A    No, I don't.

21   Q    And obviously, when you were first trying to set that

22   up, there was no computers.  There wasn't anything, was

23   there?

24   A    A typewriter.

25   Q    Yeah.  And no one had kept any of the records.  Like you



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  40



 1   say, Mr. Matthews had not done a real good job at that.

 2   A    No, he did not.

 3   Q    Yeah.  Tell me when you first remember meeting

 4   Mr. Carto.

 5   A    I was helping — Mr. Matthews was writing an article on

 6   airplanes, and he asked me to go along.  He was crippled.  He

 7   was shot down in a plane.  And he always had a cane.  He had

 8   a real bad walk.

 9   Q    Would that have been during military service that he was

10   shot down?

11   A    No.  It was one of his flights — he laid the first

12   airline from Capetown, Africa, to London, England.

13   Q    Okay.

14   A    And I guess going over a desert or something and he

15   crashed.  He was by himself.  And so anyway, he was writing

16   an article.  And I would go and check out the books that he

17   wrote down to check out.  You only could check out in the

18   Library of Congress three or four at a time.

19   Q    And you-all were in Washington?

20   A    And he and I were in Washington.

21   Q    Yes, ma'am.

22   A    And he was sitting there, and says, Oh, I have a friend

23   here in Washington, D.C.  So he went to telephone.  And

24   Mr. Carto came, and we stood outside the Library of Congress

25   for about 10 minutes.  That’s the first time I ever --



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  41



 1   Q    Was Mr. Carto about the same age as Mr. Matthews or

 2   younger?

 3   A    Mr. Carto is a couple years older than I am.

 4   Q    So he was much younger then Mr. Matthews?

 5   A    Right.

 6   Q    And at that time, did you understand what Mr. Carto did

 7   for a living?

 8   A    I had no idea.

 9   Q    Did you later come to have any understanding about what

10   his training was?  And when I'm talking about training, like

11   I went to law school, but I may not be a lawyer today.  I'm

12   kind of talking about — when I ask about Mr. Matthews'

13   training and Mr. Carto’s training, what did they study?  What

14   did they start off?  What was their background?  Do you have

15   any feeling today for what Mr. Carto — did he go to college?

16   A    I heard that he went to college.  I mean --

17   Q    But you don't know, of course?

18   A    I don't know.

19   Q    Do you know — did he profess to be any particular

20   professional, like a lawyer, an accountant, a banker?

21   A    He didn't — no.  He was just — to me he was just a

22   publisher and a writer.  That’s all I can remember.

23   Q    Now, he was pretty — or he is.  I assume he’s still

24   alive today.  I don't know.  But I'm assuming Mr. Carto is

25   pretty intelligent as well, wrote well.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  42



 1   A    I figured --

 2   Q    Knew a lot about a lot of different things.

 3   A    I would think so.

 4   Q    The articles that you say he may have sent for the

 5   American Mercury, were you not impressed by his writing

 6   ability?

 7   A    I don't remember.  I had three children.  I mean, there

 8   was all that book work.  And all what I had to do, I don't

 9   remember that at all.

10   Q    Do you remember the, like, dollar amounts?  Like do you

11   have any recollection like in McAllen in any one summer, we

12   might have taken in $10,000?  $5,000?

13   A    I wish that was so.

14   Q    That would have been a lot of money back then.

15   A    He had to borrow money even --

16   Q    You're talking about Mr. Matthews now, aren't you?

17   A    Right.  And my father gave him money.

18   Q    Yeah.

19   A    And Mother and Daddy would cook for him.  And if he

20   didn't get some money donated to him, that was it.  We maybe

21   got $100 hardly a week.

22   Q    What about in Houston?  Did the money increase in

23   Houston?

24   A    It did increase.  We had enough to pay the rent, which I

25   don't remember what it was, and I think I made $4 an hour.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  43



 1   Q    So you were on a salary in Houston?

 2   A    When we finally got — I had to.

 3   Q    Sure.

 4   A    He was without work, and it just couldn't keep going

 5   like that.

 6   Q    Right.  And I think you did say that once you-all got to

 7   California and got everything going, you were able to be on

 8   salary out there as well.

 9   A    Right.

10   Q    Did Mr. Carto, when the legion and the American Mercury

11   moved to California, did Mr. Carto reside in California?

12   A    Yes.  Not completely.  He had, which he still does

13   today, Washington, D.C. and California.

14   Q    Do you — and, of course, before — that was before he

15   was associated — before '67 when he got involved, did you

16   ever — did you know at the time or have you come to know

17   where he got enough money to have a residence in Washington,

18   D.C. and California?

19   A    I do not know.

20   Q    He’s never disclosed or talked about his personal

21   finances with you?

22   A    No.

23            MR. FURR:  Let me answer.

24            MS. MOUSER:  Sure, Mr. Furr.  Go ahead.

25            MR. FURR:  He did not have a residence in



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  44



 1   Washington, D.C.  He lived in the Liberty Lobby Building.

 2   Q    (By Ms. Mouser)  Okay.  Now, this is like in '67 when

 3   you first became a substitute incorporator?

 4   A    In the basement of the building.

 5   Q    Liberty Lobby owned a building, to the best of your

 6   knowledge, in D.C.?

 7            MR. FURR:  Correct.

 8   A    Well, I think they bought it later.

 9   Q    (By Ms. Mouser)  And he lived in the basement.

10        Now, was he married to Miss Elisabeth when you first met

11   him?

12            MR. FURR:  Correct.

13   A    Correct.

14   Q    (By Ms. Mouser)  And do you know, did she work outside

15   the home?

16   A    No.  I don't know that she did.  I don't think so.

17   Q    Did you ever get the feeling when you first met

18   Mr. Carto that Mrs. Elisabeth Carto worked for Liberty Lobby?

19   A    I think she was like I did.  She helped him.

20   Q    And do you recall, did they have children?

21   A    They did not have children.

22   Q    And was Mrs. Carto approximately the same age as

23   Mr. Carto?

24   A    She’s a little bit younger.

25   Q    Now, after that first meeting with Mr. Carto outside the



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  45



 1   Library of Congress in D. C., I think you mentioned that

 2   after Mr. Matthews died that you and Marchita were trying to

 3   think of someone who could come in and help.  And someone

 4   called Mr. Carto.  It doesn't matter who.  And then the next

 5   time you saw him, was it at the lawyer’s office when the --

 6   A    It was at the lawyer’s office.

 7   Q    Was that lawyer someone Mr. Carto chose or did you and

 8   Marchita choose him?  Mr. Graham, I think you mentioned, was

 9   his name.

10   A    Mr. Platzer --

11   Q    Now, if you'd spell that for Ms. Miller, please.

12   A    P-l-a-t-z-e-r.

13   Q    Thank you, ma'am.

14   A    Living in Houston, he could hear the radio program.

15   Q    Yes, ma'am.

16   A    He gave a lot of money, donated a lot of money, and

17   visited Mrs. Matthews and Mr. Matthews, I guess, quite

18   regularly.  And Mr. Graham was a lawyer, but also Mr. Platzer

19   went to school with Mr. Graham.  But Mr. Graham was older

20   than Mr. Platzer.  Mr. Platzer said that he ran around with

21   Mr. Graham’s younger brother.  And so since the Platzers were

22   good friends of the Matthews and he came to the funeral --

23   Q    That’s how he got connected with Mr. Graham?

24   A    Because I didn't know Mr. Graham.

25   Q    Sure.  And Mr. Carto certainly wasn't involved in that



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  46



 1   either?

 2   A    He wasn't even at the funeral.  I don't even know that

 3   he knew when he died.

 4   Q    Did you know — now, Mr. Matthews said that Mr. Carto

 5   was a friend.  Did you ever know how they had become friends?

 6   Because, obviously, he didn't hear the radio station unless

 7   he was in Texas.

 8   A    Because --

 9   Q    Not the radio station.  The radio program.  Excuse me.

10   A    I think — now, this could be very wrong, but I can't

11   remember.  Mrs. Matthews belonged to some organization that

12   was nothing but women.  She was being — Congress for Freedom

13   or something, you know.  She was all — they were very

14   wealthy at one time.

15   Q    The Matthews were?

16   A    The Matthews were.  Well, not Mr. Matthews.  Mrs.

17   Matthews.

18   Q    I see.

19   A    And she was — she knew McArthur, Chiang Kai-shek.  And

20   they would just travel the world.  I mean, she was a very

21   brilliant woman.  And somehow, I think, Mr. Carto and

22   Mrs. Matthews met at one of these Congress for Freedom

23   meetings, and I think that’s how it started.  From there on,

24   I don't know.

25   Q    And so Mr. Carto came to the meeting at Mr. Graham's



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  47



 1   office in Houston.  And he became a substitute incorporator

 2   as well, along with you?

 3   A    Correct.

 4            MS. MOUSER:  Mr. Furr, did you become a substitute

 5   incorporator at that time?

 6            MR. FURR:  No.  There’s never been but two.

 7   Q    (By Ms. Mouser)  Now, Mr. Carto, during the time from

 8   '67 to '79, how often would he come to the office in — first

 9   of all, where did the American Mercury move to in California?

10   A    Torrance, California.

11   Q    Is that a town, Torrance?

12   A    Torrance.

13   Q    T-o-r-r-a-n-c-e?

14   A    Correct.

15   Q    You don't happen to remember the address, do you?

16   A    When we first moved there, we didn't have the money to

17   get our furniture out of the --

18   Q    Storage facility?

19   A    — storage.  And Mr. Carto did not pay any moving

20   expenses.  So we had to wait.  We were in an apartment, a

21   furnished apartment.

22   Q    And you're talking about we; you're talking about the

23   American Mercury?

24   A    I'm talking — no.  My family.

25        And there was a storage place where the material went in



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  48



 1   Los Angeles which was on Labrea Street.

 2   Q    I'm not very familiar.  Is Torrance just like next door

 3   to Los Angeles or --

 4            MR. FURR:  About 25 miles south of --

 5   A    There’s five towns in between Torrance.

 6   Q    (By Ms. Mouser)  Yeah.

 7   A    You know, I can't tell whether you're from --

 8   Q    Why would the American Mercury materials have gone to

 9   Los Angeles?  Was that just the closest place you could find

10   a storage facility?

11   A    I guess it was.  He knew — I mean, he had an office.

12   Q    Mr. Carto did?

13   A    Yes.  On Labrea Street.

14   Q    And that’s where the storage facility was?

15   A    That’s correct.  And my dining room table was my desk --

16   Q    Uh-huh.  Uh-huh.

17   A    — in the apartments.

18   Q    Yes, ma'am.

19   A    And finally, we found a house that we could rent on Ward

20   Street.

21   Q    And when you — you mean your personal family or we, the

22   American Mercury?

23   A    Again, the --

24   Q    Your family?

25   A    Right.  And I would go to the office in Los Angeles



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  49



 1   maybe once a week to get materials or find things, you know,

 2   that I needed.  My 3-by-5s were on my dining room table, and

 3   at night --

 4   Q    Now, were the records of the American Mercury and the

 5   legion — were they in the storage facility or were they in

 6   an office building that Mr. Carto had on Labrea?

 7   A    They were — most of them were, except my current, you

 8   know --

 9   Q    Sure.  That you were working on were at your home.

10   A    Right.

11   Q    But I mean the other things.

12   A    But extra copies of the American Mercury.

13   Q    Right.

14   A    And there wasn't really any more records.  And then the

15   — there was no bankbooks or anything.  I had all --

16   Q    You would have had all that?

17   A    I had — I had all of that.

18   Q    Sure.  So the boxes were mostly just the books that you

19   had mentioned?

20   A    Right.  There was no furniture.

21   Q    Right.  When were those boxes finally taken out of

22   storage and unloaded, if you recall?

23   A    I don't remember.

24   Q    Where were they unloaded when they finally came out of

25   storage?  Do you recall?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  50



 1   A    We found a small office right near where we used to --

 2   where we lived on Ward Street.

 3   Q    And that’s in Torrance again?

 4   A    That was in Torrance.   And when we found this house on

 5   Ladean Street, the valuable bound volumes from way back in

 6   1924 and all the-- then everything came to my — to that

 7   house.  And the back copies of the American Mercury were in

 8   storage.  People would write in, Do you have a back copy, you

 9   know.

10   Q    Right.  Right.

11   A    Because we just — I didn't have room.

12   Q    And on Ladean, that was your personal residence?

13   A    Personal residence.

14   Q    Which you continued basically to work out of your

15   personal residence?

16   A    Right.

17   Q    At any time after that, before you left in '79, was

18   there actually a separate office location for the American

19   Mercury or the legion?

20   A    When I packed up to leave, the legion had gotten an

21   office someplace else.

22   Q    Did you ever go to that office?

23   A    While they were moving the things, I did.

24   Q    And who is they?  Who moved the things?

25   A    We had hired Tom Marcellus.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  51



 1   Q    And that’s M-a-r-c-e-l-l-u-s, Tom Marcellus?

 2   A    Right.

 3   Q    Now, to help you move the things or just --

 4   A    We hired him to take my place.

 5   Q    And was he in challenge of moving all the materials and

 6   the records?

 7   A    Oh, I helped.

 8   Q    Sure.

 9   A    You know, because --

10   Q    They were in your home?

11   A    — to separate my things from — you know.

12   Q    Sure.

13   A    And the American Mercury, the bound volumes and

14   everything that belonged to the American Mercury, not the

15   legion, was moved to Shreveport, Louisiana.

16   Q    So Tom Marcellus took your place basically as an

17   employee of the legion?

18   A    Correct.

19   Q    And all those legion items were moved to this office

20   that you actually helped maybe move into, but you never

21   worked out of?

22   A    I never worked out of there.

23   Q    Was that in Torrance as well?

24   A    I can take you there, but I don't --

25   Q    Okay.  That’s okay.  But it was in California?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  52



 1   A    Yes.

 2   Q    Was it Costa Mesa, by any chance?

 3   A    No.  It wasn't Costa Mesa.

 4   Q    Now, the American Mercury things went to Shreveport.

 5   Now, why is that?

 6   A    Because Mr. Touchstone bought the American Mercury.

 7   Q    Do you recall, was that in '79 about the time you left,

 8   or was that before you left?

 9   A    I left November the 11th, 1979, and some of the American

10   Mercury supplies were shipped by me to Shreveport.  And what

11   was left, it went on the truck with my furniture.

12   Q    So when, basically, your home, which you also operate as

13   your office — when you left that home, you felt that

14   everything that was the legion’s had gone to the new legion

15   office; Tom Marcellus had taken your place.

16   A    Correct.

17   Q    The American Mercury stuff had gone to Mr. Touchstone?

18   A    In Shreveport, Louisiana.

19   Q    Right.  Just out of curiosity, does he still own the

20   American Mercury?  Do you know?

21   A    He died two years after he bought it.

22   Q    Has anyone carried that on or --

23   A    No.  It folded up.  I had to quit because he wasn't

24   paying me.

25   Q    Oh, did you continue to work for him?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  53



 1   A    I continued to work for him.

 2   Q    Yeah.  Well, were there any other records?  Did you keep

 3   copies of any records from either American Mercury — other

 4   than like the books, which would have been yours.  I'm

 5   talking about just maybe copies of bank statements or minutes

 6   or anything like that.

 7   A    Everything was left.

 8   Q    You mean it was — either went to the legion office or

 9   went to Mr. Touchstone?

10   A    Right.  I didn't carry any of the legion.  That was all

11   left under the supervision of Mr. Carto.

12   Q    Why did you leave in November of '79?  Do you want

13   Mr. Furr to answer the question?  That would be fine.  I mean

14   --

15   A    He did not like California.

16   Q    Mr. Furr did not?

17   A    He left in '76.

18   Q    Mr. Furr and I probably would get along very well.

19   Yeah.

20   A    He just couldn't stand the pace, and the traffic was

21   getting — and he was from Louisiana and two girls back

22   there.  And he wanted to go back home and --

23   Q    So the girls who wanted to go to Disneyland, they

24   decided to go back to Louisiana, huh?

25   A    They went to Louisiana Tech to college and found



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  54



 1   husbands at college.

 2   Q    Sure.  Yeah.

 3   A    And my son lived with my mother in Colorado.  He didn't

 4   like California.

 5   Q    You liked California though, didn't you?

 6   A    I did, and I didn't.  It was exciting.

 7   Q    It is a rapid pace, isn't it?  I would think even back

 8   then.

 9   A    It’s worse now.  Well, I haven't been back there in

10   years.  It was fun.  We didn't have no money, but there’s a

11   lot of free things we could take the children to.

12   Q    Sure.

13   A    Like the beach, which I can't stand to this day.  Didn't

14   go that often.

15   Q    Yeah.

16   A    But Mr. Furr’s — he was in a computer — Hawthorne with

17   Filon.  He said, I've gone as far as I can here, and he says,

18   I — so he just left and went and lived with our son for a

19   year and came back and forth to visit me.

20   Q    Right.  Right.

21   A    And my mother and daddy lived in Colorado at that time.

22   And so it took four years before we could find somebody to

23   buy the American Mercury.

24   Q    Right.

25            MS. MOUSER:  Now, Mr. Furr, where did you work in



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  55



 1   California?  This would have been in about '67 when you-all

 2   moved out there.  Did you work at the same place all those

 3   years or --

 4            MR. FURR:  No.

 5            MS. MOUSER:  Where did you work?

 6            MR. FURR:  I worked for Title Insurance Company

 7   downtown Los Angeles for awhile, and I worked for an outfit

 8   called — some chemical company that made specialty paints.

 9   Like they'd make 55-gallon drums of eyeball white paint for

10   Matel to paint their doll eyeballs with.  And it was my job

11   to convert from the laboratory the ingredients to mix it

12   right.  And then I got a job as a — an outfit that made

13   fiberglass reinforced panels as a computer operator

14   programmer.

15            MS. MOUSER:  Now, that would have been early on when

16   people in Arkansas probably didn't know what computers were.

17            MR. FURR:  They are — compared to what they are

18   now, they were kind of primitive.

19            MS. MOUSER:  And then in '76, did you move to

20   Colorado approximately around then, you think?

21            MR. FURR:  It was earlier than that.

22            MS. MOUSER:  Did you have a job in Colorado?

23            MR. FURR:  No, I didn't.  I lived with David up

24   there.

25            MS. MOUSER:  That’s your son.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  56



 1            MR. FURR:  Yeah.

 2   Q    (By Ms. Mouser)  Yeah.  And then in '79, you-all moved

 3   to where?

 4   A    Shreveport, Louisiana.

 5   Q    And why did you go back to Shreveport?

 6   A    In — whenever Mr. Furr started working with the bakery

 7   in Shreveport.

 8            MR. FURR:  I got a job there.

 9            MS. MOUSER:   Good.  Good.  And then how long were

10   you-all in Shreveport?

11            MR. FURR:  Well, actually in Shreveport and Bossier

12   City to 1991, until we moved up here.

13   Q    (By Ms. Mouser)  Now, from approximately '79 to '91,

14   Mrs. Furr, did you have any — did you do any volunteer work

15   for Mr. Touchstone, other than you mentioned you did some,

16   but then you finally had to say, No.  I can't do it anymore

17   because he wasn't paying?

18   A    It wasn't considered — I thought I'd be — was being

19   paid all the time.

20   Q    Yeah.  Yeah.

21   A    And I ended up on — September 1980, left a note on his

22   desk he owed me 5,000, and finally his wife got it down — he

23   died owing me 2,000.

24   Q    Yeah.

25   A    I did some typing.  I did some baby-sitting, but that



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   was the only occupation --

 2   Q    But, I mean, for the American Mercury.  Other than what

 3   you've mentioned, did you do anything else for the American

 4   Mercury, whether it was intentionally volunteer or ended up

 5   being volunteer work?

 6   A    That was my only — well, from December to September, I

 7   worked for the American Mercury.

 8   Q    What about for the legion from '79 to '91?  Did you do

 9   any volunteer work or paid work for the legion?

10   A    I was supposed to be paid $100 a month to help Tom and

11   continue on some public relations for the legion.

12   Q    And that’s Tom Marcellus?

13   A    Tom Marcellus.

14   Q    Yes, ma'am.

15   A    For awhile they would send checks.  I'd sign checks, and

16   Tom Marcellus was supposed to cosign them.  But finally I

17   told Mr. Carto — I said, This is ridiculous.  I get blank

18   checks.  I don't know what he’s writing them for.  And I

19   says, And it was taking up time.  And then in '85, my mother

20   had stomach cancer, and I stayed with her until — five

21   months until she died.

22   Q    Uh-huh.

23            MS. MOUSER:  And, Mr. Furr, during — from '79 until

24   '91, while you-all were in Louisiana, did you do any

25   volunteer work or paid work for the American Mercury?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  58



 1            MR. FURR:  I never did any paid work for them.

 2            MS. MOUSER:  Did you do any volunteer work during

 3   that period of time from '79 to '91?

 4            MR. FURR:  I'd say no.

 5            MS. MOUSER:  What about for the legion --

 6            MR. FURR:  No.

 7            MS. MOUSER:  — from '79 to '91?

 8            MR. FURR:  (Shakes head.)

 9            MS. MOUSER:  Okay.

10   Q    (By Ms. Mouser)  Then in '91 you moved to Hot Springs.

11   Did you do — I'm assuming you were through with the American

12   Mercury at that time, Mrs. Furr.

13   A    Correct.

14   Q    Did you do any volunteer work or paid work for the

15   legion from '91 until today, let’s say?

16   A    The legion is a nonprofit organization, and to be on the

17   board, you do not get paid.  It’s a — you do not pay — I

18   wasn't — neither one of us were paid.  Nobody was paid to

19   work for the legion.

20   Q    Yes, ma'am.  When did you --

21   A    You couldn't do that by the laws.

22   Q    Right.  When did you go on the board — and are you --

23   I'm assuming you're still one of the incorporators.

24   A    Right.

25   Q    Now, when did you go on the board of the legion?  Do you



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  59



 1   recall when that was?

 2   A    Mr. Matthews — I can't remember if I was a voting

 3   member, but he asked me to join the legion.

 4   Q    The board of the legion?

 5   A    The board of the legion.

 6   Q    Yes, ma'am.  Do you remember approximately when that

 7   was?

 8   A    It was July of 1964.

 9   Q    And from that time forward — are you still on the board

10   today?

11   A    Well, we — that’s the case that was in Houston.

12   Q    When you say that case, you mean the litigation?

13   A    The litigation to prove that Willis and I were

14   incorporators.

15   Q    Do you think that incorporator is synonymous with board

16   member or do you view those to be two different roles?

17   A    They're two different roles.

18   Q    Great.  I do too.  So do you feel sitting here today

19   that you are still a board member?

20   A    I resigned.

21   Q    When did you resign?

22   A    September the 16th, 19- --

23   Q    '93 maybe?

24   A    '93.

25   Q    And did you ever revoke that resignation?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  60



 1   A    I revoked it.

 2   Q    When did you do that, if you recall?

 3   A    Probably a few weeks later.

 4   Q    And so sitting here today, have you resigned again as a

 5   board member or do you feel you're still a board member?

 6   A    They didn't acknowledge the revoke, so --

 7   Q    When you say --

 8   A    Judge told us to not acknowledge that I --

 9   Q    The revocation.  Okay.  So do you feel that you're still

10   — no.  So you still feel that your resignation is effective,

11   according to that decision?

12   A    I have to — according to that decision.

13            MS. MOUSER:  Now, Mr. Furr, when — now, you've

14   never been an incorporator.  Right?  Of the legion?

15            MR. FURR:  Correct.

16            MS. MOUSER:  When did you become a board member of

17   the legion?

18            MR. FURR:  I don't remember.

19            MS. MOUSER:  And did you also feel that you resigned

20   at the same time of Mrs. Furr, on September 16 of '93?

21            MR. FURR:  Yes.

22            MS. MOUSER:  And then did you also feel a few weeks

23   later that you had revoked --

24            MR. FURR:  Correct.

25            MS. MOUSER:  — that resignation?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  61



 1            MR. FURR:  Right.  Correct.

 2   Q    (By Ms. Mouser)  Mrs. Furr, why did you resign?

 3   A    I resigned because of the threats that Tom Marcellus and

 4   all who was working for him kept writing letters that I was

 5   responsible for Mr. Carto’s actions.

 6   Q    Why was Tom Marcellus doing that?  I mean, to the best

 7   of your knowledge.  Obviously, you can't get in his mind, but

 8   why was he doing that?

 9   A    He wanted to take over the legion.

10   Q    Now, at that time, was he still basically — I would

11   have called you at the time, when you had described all the

12   things you did from like '67 forward — you were basically a

13   manager.

14   A    It was a manager.

15   Q    You might have been an incorporator; you might have been

16   a director.  But you also kind of managed the day-to-day

17   business?  Did Tom have a title?

18   A    I didn't manage the day-to-day business.  I wasn't there

19   to manage the day-to-day business.

20   Q    From '67 to '79, you weren't?  I'm sorry.  I thought you

21   kind of were the nuts and bolts.

22   A    Oh, then.

23   Q    Yes, ma'am.

24   A    But Tom wasn't working at that time.

25   Q    Right.  Right.  So that’s why I'm saying, if he took



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  62



 1   over your position and then when you starting getting these

 2   letters, which caused your resignation in '93, was he still

 3   doing the same thing or had he taken on another position?  I

 4   mean, what gave him the authority, on behalf of the legion,

 5   to write these letters to you, is my question.

 6   A    Mr. Carto made him office manager or — I think Tom took

 7   the title CEO.  I mean, I didn't do it.

 8   Q    So you think Mr. Carto --

 9   A    He was in charge.  He could hire and fire.

10   Q    Tom was?

11   A    Tom was.

12   Q    Well, what was his relationship — what was Mr. Carto to

13   Tom?

14   A    He took — he was --

15   Q    Could Mr. Carto fire Tom?  He hired him.  Could he fire

16   him, do you think?

17   A    No.  Mr. Carto and I both hired.  I interviewed him and

18   he interviewed him, and we agreed to hire Tom Marcellus.

19   Q    But you were gone — when Mr. Marcellus started writing

20   you these letters, you were gone.  Could Mr. Carto — I'm

21   just trying to figure out the chain of command there.  Who

22   was — of course, you and Mr. Furr were on the board.  Who

23   else was on the board at the time when you-all resigned?  Was

24   Elisabeth Carto a board member?

25   A    I don't remember.  She — sometimes — because she would



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  63



 1   go out of the country.  I don't remember if she was on at

 2   that time.

 3   Q    Was he, was Mr. Carto?

 4   A    He wasn't on the board at that time, but I had given him

 5   a power of attorney to supervise or direct the office help.

 6   You know, someone had to oversee Tom and all the books that

 7   they did and all that.

 8   Q    Sure.  So do you feel that Mr. Carto could have, with

 9   that power of attorney, fired Tom?

10   A    I have no opinion on that.

11   Q    Did you complain to Mr. Carto about the letters that

12   Mr. Marcellus was writing you?

13   A    No, I did not.

14   Q    Do you know, sitting here today, did Mr. Carto ever know

15   about those letters?

16   A    He does now.

17   Q    How does he know about them now?

18   A    They were in the court proceedings December the 30th or

19   31st of '93 in the poll list case.

20   Q    Is that the California case or the Texas case?

21   A    California.

22   Q    And has Mr. Carto ever discussed those letters from

23   Mr. Marcellus to — now, were the letters to you or to you

24   and Mr. Furr?

25   A    Some were just to me and some were to both of us.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  64



 1   Q    Have you ever discussed those letters with Mr. Carto?

 2   A    I don't think I have.  He’s read them.

 3   Q    So he’s never expressed his apologies or anything like

 4   that to you for those letters?

 5   A    I don't know why he would apologize.  He did write them.

 6            MS. MOUSER:  What about you, Mr. Furr?  Have you

 7   ever talked to Mr. Carto about the letters from Mr. Marcellus

 8   that were addressed to you?

 9            MR. FURR:  After the fact, yes.  And after he found

10   out about it, he was — as I recall, he was under the

11   impression that he could have fired him.

12            MS. MOUSER:  Yeah.  Fired Mr. Marcellus.

13            MR. FURR:  Yeah.

14            MS. MOUSER:  But he didn't know about the letters at

15   the time they were — at least to the best of your knowledge,

16   Mr. Carto was not aware Mr. Marcellus was writing these

17   letters.

18            MR. FURR:  No.  No.

19   Q    (By Ms. Mouser)  Well, for either of you, do you have

20   any feel — and I guess we'll just start with you, Mrs. Furr

21   — why was Tom Marcellus doing this?  I mean, you were gone;

22   you were long gone, since '79.  This was like in '93 — well,

23   when did the letters start?  Did they start in '93?

24   A    August of '93.

25   Q    I mean, you had been gone — well, that’s — is that six



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  65



 1   years?  16 years, actually.

 2   A    I had made Mr. Carto power — gave him a power of

 3   attorney, and that was one of the things that Tom said that I

 4   had no business.  I would be responsible for any actions that

 5   Mr. Carto would be taking or had taken.

 6   Q    So maybe Tom and Mr. Carto had differences of opinion?

 7   Is that maybe one thing we could gather from that?

 8   A    I'm not surprised.  I had different opinions of

 9   Mr. Carto.

10   Q    Well, you know, we have differences of opinion with

11   everyone, but it seems to me like maybe — it seems like --

12   it’s just unusual that after 16 years you had been gone and

13   all of a sudden you start getting these letters from

14   Mr. Marcellus.

15   A    It hurt.  I trusted Tom.

16   Q    Sure.

17   A    I like him to this day.  I mean, you know --

18   Q    It just doesn't somehow — I'm trying to figure out why

19   on earth after 16 years would he just up — do you recall

20   when you gave Mr. Carto the power of attorney?  Was that

21   somewhere in '93 or close to '93?

22   A    No.  It was in '85 when Jean Farrell left some money to

23   Mr. Carto.

24   Q    Was it about the time that Mr. Marcellus thought maybe

25   some of the money from the estate should have gone to the



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  66



 1   legion?  Is that about the time you started getting these

 2   letters?  That he thought maybe Mr. Carto had done something

 3   with the money.  Is that the seedling for the harsh letters?

 4   A    I think that’s what it was.

 5   Q    So it may have been to — do anything with you

 6   personally.

 7   A    It wasn't me.

 8            MS. MOUSER:  What do you think, Mr. Furr?  Do you

 9   think maybe the timing — it just seems unusual after 16

10   years, all of a sudden, for Tom Marcellus to start writing

11   harsh letters.  Do you think it maybe had something to do

12   with the Farrell estate and where Tom thought the --

13            MR. FURR:  I'm sure it did.

14            MS. MOUSER:  Why do you say you're sure?

15            MR. FURR:  He was trying to get us to resign from

16   the board of directors so he could get some directors

17   appointed with the idea of perhaps getting some of that money

18   from the Jean Farrell estate.

19            MS. MOUSER:  Now, when you say he, you mean Tom?

20            MR. FURR:  Yes.  Tom and the people who were working

21   for him.

22   Q    (By Ms. Mouser)  Now, who all — do you recall,

23   Mrs. Furr, any of the names of the people who were working

24   for Tom at that time?

25   A    They were on the letters.  I never met them.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  67



 1   Q    So if I've seen a letter where there were five people,

 2   those people were all the people involved at the time?

 3   A    That’s right.

 4            MS. MOUSER:  Is that your recollection, Mr. Furr?

 5            MR. FURR:  Right.

 6            MS. MOUSER:  I think I've seen some of those

 7   letters.

 8        And, basically, is that why you resigned, Mr. Furr,

 9   because, basically, those letters?

10            MR. FURR:  Right.  He was threatening us with

11   possible criminal action.

12            MS. MOUSER:  Uh-huh.  I have seen those letters.

13   And so why then did you, Mr. Furr, revoke your resignation?

14            MR. FURR:  We found out that we were misled about

15   what he — what they could do.

16            MS. MOUSER:  And who informed you of that, that you

17   had been misled?

18            MR. FURR:  I don't recall.

19   Q    (By Ms. Mouser)  Mrs. Furr, why did you revoke your

20   resignation?

21   A    Just — well, like Mr. Furr said, we found out that --

22   in the letters Tom would mention that I had no authority to

23   give power of attorney to anybody under the California law.

24   And we both resigned.  My father had just died.  We had

25   family problems.  And I almost had a nervous breakdown.  And



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  68



 1   then the bankruptcy that we had to take.

 2   Q    Sure.

 3   A    And then the $2,000.  And I thought, Here’s another

 4   friend — I just went all to pieces.

 5   Q    Sure.

 6   A    And I just — in fact, the day we sent it in, we went to

 7   my daughter’s house --

 8   Q    Is this the resignation or the revocation?

 9   A    This is when we resigned.  I said, I just want to get

10   out of town.  And from that time on, Mr. Furr has suffered

11   seizures.  He had five that night.  It just — and we found

12   out it was the stress.

13   Q    Did Mr. Marcellus ever call — now, you were residing,

14   of course, in Hot Springs at the time.  Did Mr. Marcellus

15   ever call your home?

16   A    Constantly.  Twice a day.

17   Q    And was it kind of the same stuff that was in the

18   letters?

19   A    Sort of.  And still trying to butter me up and still

20   saying, you know, whatever.  And I know one time I was

21   cooking, and I says I can't talk to him anymore.  And Lewis

22   said, Well, we took bankruptcy, and you can't get blood out

23   of a turnip.  And finally I changed my telephone number.

24   Q    Now, I don't recall — and I may have missed it — but I

25   don't recall any of those letters ever alleging that you or



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  69



 1   Mr. Furr got any of the money from the Farrell --

 2   A    We did not.

 3   Q    I think it’s F-a-r-r-e-l-l, I believe.  Isn't it?

 4   Something like that.

 5            MR. FURR:  F-a-r-r-e-l-l.

 6            MS. MOUSER:  Yeah.

 7   Q    (By Ms. Mouser)  But I don't ever recall him alleging

 8   that you or Mr. Furr got any of the money from the estate.

 9   A    No, he did not.  He did allege that.  But he just

10   alleged that we were — I was responsible for his actions.

11   Q    Mr. Carto’s actions?

12   A    Mr. Carto’s actions.

13            MS. MOUSER:  Do you recall, Mr. Furr?  I don't

14   recall Mr. Marcellus, or any of those other people on those

15   letters, alleging that you or Mrs. Furr had gotten any of the

16   estate money.  Do you recall that?

17            MR. FURR:  No.

18   Q    (By Ms. Mouser)  Have those calls stopped?

19   A    I changed my telephone number.

20   Q    And absent that, they haven't.

21        What about letters?  Did the letters stop?

22   A    We've had letters anonymous and some mailed from Little

23   Rock.

24   Q    When do you think you got the last letter?

25   A    Tom even wrote me.  I think it’s in a memo in which you



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  70



 1   asked for.

 2   Q    Uh-huh.

 3   A    Off the top of my hat, I'm going to say 1995.  I didn't

 4   even read it last night.  I saw that and I just — I don't

 5   even remember what it said.

 6   Q    So maybe since '95.  Is that the last time you've

 7   heard --

 8   A    From Tom.

 9   Q    Where it’s been identified?

10   A    Right.

11   Q    Any idea who these people are that are sending you

12   stuff?

13   A    I knew it was Tom — Weber.  He always wrote 206.

14   Q    Is that Mark?

15   A    No.

16            MR. FURR:  Yeah.

17   A    Yeah.

18   Q    (By Ms. Mouser)  Now, who is he?  I've seen his name.

19   Is he someone who works for the legion?

20   A    Oh, he worked for Tom.

21   Q    And what’s this 206 thing, now?  Is that your address?

22   A    No, it’s not.  But that’s the way, with his handwriting,

23   that we recognized it.  And he even had Ohio addresses.

24   Q    You mean Mr. Weber used --

25   A    Yes.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  71



 1   Q    Oh, I see.

 2   A    He used 206.  So I knew his handwriting by some of the

 3   letters and --

 4   Q    But they would come from different places in the

 5   country.

 6   A    — places.

 7            MR. FURR:  Yeah.

 8   Q    (By Ms. Mouser)  And what were, basically, the content

 9   of those letters?  The same stuff like with Marcellus?

10   A    I don't remember.

11   Q    Now, did those stop about in '95 too, the 206 Weber

12   letters?

13   A    No.  I think Weber stopped before that.

14   Q    Anybody else that you can identify that you think has

15   been sending you correspondence or anything since '95?

16   A    I don't think so.

17            MS. MOUSER:  What about you, Mr. Furr?  Can you

18   think of anything that you have gotten in writing since '95

19   from anybody that you think is affiliated with the legion?

20            MR. FURR:  We got a telephone call, one telephone

21   call, after we had the number changed.  And I think it was

22   this attorney in California that kind of made a joke out of

23   it.  You thought I couldn't get your telephone number because

24   it was unlisted.

25            MS. MOUSER:  And that wasn't one of your lawyers?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  72



 1   That was --

 2            MR. FURR:  No.  No.  It was one of their lawyers.

 3            MS. MOUSER:  And did he say anything else?

 4            MR. FURR:  He was — he hung up on me.  But I don't

 5   know --

 6   A    There’s been calls where people have hung up, but you

 7   never know.

 8   Q    (By Ms. Mouser)  Sure.  They may have my number too.  I

 9   get that too.  It’s very aggravating, kind of unsettling.

10   A    Well, right during that time, the last two years, no.

11   But I'm talking about — I'm talking of the period of that --

12   Q    In the '93, '94, '95 --

13   A    Like that.

14   Q    So other than the deposition that we're doing today, do

15   you feel that you're pretty much free of phone calls and

16   letters?

17   A    I feel that.

18            MS. MOUSER:  What about you, Mr. Furr?

19            MR. FURR:  Yes.  I hope so.

20            MS. MOUSER:  Can we go on a little bit more?

21            MRS. FURR:  A little bit.

22            MS. MOUSER:  Okay.  And then we'll take a break for

23   lunch, if that’s okay.

24   Q    (By Ms. Mouser)  One of the things I recall that you-all

25   also agreed to do, in light of the settlement, was to dismiss



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  73



 1   some of the lawsuits that are pending.  And, obviously, I am

 2   not involved in those.  I don't even know the lawyers.  I may

 3   recognize their names.

 4        But I know there was some Texas — some litigation in

 5   Texas, and I think it’s called the Incorporators of the

 6   Legion for Survival, et cetera, versus Andrew Allen

 7   Friedrich, F-r-i-e-d-r-i-c-h, Burg and John Curry.  Do you

 8   know, Mrs. Furr, what the current status of that case is?

 9   A    I have written --

10   Q    And if you want to confer with Mr. Honey and if you've

11   got something in writing, you're welcome to look at it.

12   A    I wrote Mr. Izen, who was supposed to handle the appeal,

13   and he has --

14   Q    Is he your lawyer?  I'm sorry.

15   A    He’s Mr. Carto’s, our lawyer representing the appeal.

16   Q    So did you and Mr. Furr and Mr. Carto — were you-all

17   all three plaintiffs?

18   A    Mr. Furr was not in the --

19            MR. FURR:  I wasn't.  I was not involved.

20            MS. MOUSER:  Okay.

21   A    He was not the incorporator.  It was just Mr. Carto and

22   myself.

23   Q    (By Ms. Mouser)  Now, when — oh, that’s right.  Back in

24   '67 was when Mr. Carto became the incorporator with you.

25   That’s right.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  74



 1   A    Right.

 2   Q    And how do you spell Izen?

 3            MR. FURR:  I-z-e-n.

 4            MS. MOUSER:  Okay.

 5   Q    (By Ms. Mouser)  And you wrote him — do you recall

 6   approximately when?  Or Mr. Honey may have a document to help

 7   you.

 8   A    I faxed a copy.  I don't know whether he has it with him

 9   or not.

10            MR. HONEY:  Well, the only thing I'm looking at

11   right now is just this Exhibit C that we attached to the

12   agreed order in the bankruptcy case.

13            MS. MOUSER:  Yes, sir.

14            MR. HONEY:  Yeah.  That lists some 29 cases that

15   were dismissed with prejudice.

16            MS. MOUSER:  And was that faxed to Mr. Izen?  Do you

17   know?

18            MR. HONEY:  I don't know.

19   Q    (By Ms. Mouser)  Did you think that had been faxed, Mrs.

20   Furr, to Mr. Izen?

21   A    I don't know, but I hadn't heard from him.  And I called

22   his office four or five days ago, and his assistant said that

23   their lawyer had already dismissed.

24   Q    The appeal?

25   A    The appeal.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  75



 1   Q    When you say their lawyer, you mean --

 2            MR. FURR:  ABC.  Allen, Burg, and Curry.

 3   Q    (By Ms. Mouser)  Now, see, you and Mr. Carto filed the

 4   appeal.

 5   A    Right.

 6   Q    Are you saying the Court already dismissed your appeal?

 7   A    That’s my --

 8   Q    That’s your understanding?

 9   A    That’s my understanding.  It’s been dismissed, yeah.

10   Q    Well, that should be done then.  Right?  That should be

11   over.

12   A    I have no configuration.  I'm just telling you what I

13   was told, that it’s been dismissed.

14   Q    Sure.

15            MR. FURR:  They had already gotten a summary

16   judgment anyway.

17            MS. MOUSER:  Yes, sir.  The defendants had.

18            MR. FURR:  Right.

19            MS. MOUSER:  Yes, sir.

20   Q    (By Ms. Mouser)  And it was from that summary judgment,

21   I believe, that, Mrs. Furr, you and Mr. Carto appealed?

22   A    Right.

23   Q    And it’s your understanding — and, obviously, we'd have

24   to see the order.  And I've not seen it, but, hopefully,

25   someone in Texas has.  Your understanding is that the appeal



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  76



 1   has been dismissed, and for all practical purposes, as far as

 2   you're concerned, that case is over?

 3   A    That case is over, as far as I'm concerned.

 4   Q    What about the — well, let me go back and ask.  How was

 5   Mr. Izen paid in that Texas proceeding?

 6   A    I don't think he was.

 7   Q    Did Mr. Carto find Mr. Izen or did you?

 8   A    I guess he did or maybe Howard Singleton who --

 9   Q    Now, who — I'm sorry.  Who is Howard Singleton?

10   A    Howard Singleton handled the case of Mr. Carto and I.

11   Q    In Texas?

12   A    In Texas.

13   Q    And then Mr. Izen was going to do the appeal?

14   A    Right.

15   Q    I see.

16   A    And I don't know how that name came up or whether

17   Mr. Singleton suggested him.

18   Q    Sure.  Who hired Mr. Singleton?

19   A    Mr. Carto and I.

20   Q    Did you personally speak with Mr. Singleton?

21   A    Many times.  Been in his office many times.

22   Q    And do you have any understanding — was Mr. Singleton

23   ever paid any money?

24   A    Yes, he was.

25   Q    And do you know the source of that money?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  77



 1   A    Mr. Carto paid it.  Lewis and I don't have any money.

 2   Q    Yes, ma'am.  And do you know approximately how much

 3   Mr. Carto may have paid Mr. Singleton?

 4   A    I do not.

 5   Q    Now, what about the lawsuit in California?  I believe

 6   that had to do with the fact that you and Mr. Furr were

 7   served here maybe not with the right documents and were a

 8   member of the registration of the judgment and all that

 9   stuff.  But that, as I recall, was the actual judgment out

10   there.

11   A    Correct.

12   Q    That maybe the lawyers didn't file a timely answer.

13   A    That’s correct.

14   Q    And it was a default judgment, as I recall.

15   A    That’s correct.

16   Q    Yes, ma'am.  Now, I believe that you and Mr. Furr, as I

17   recall, are parties in that lawsuit; is that correct?

18   A    Correct.

19            MS. MOUSER:  Is that your recollection, Mr. Furr?

20            MR. FURR:  That’s correct.  That’s the one that's

21   under appeal in California.

22            MS. MOUSER:  Right.

23   Q    (By Ms. Mouser)  Now, what is your understanding — if

24   we could start with Mrs. Furr — of the status of that case?

25   A    It’s under appeal.  I've never seen papers or documents



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  78



 1   or anything.

 2            MS. MOUSER:  Is that your understanding, Mr. Furr?

 3            MR. FURR:  Correct.

 4   Q    (By Ms. Mouser)  Are Ware and Urtnowski, are those your

 5   attorneys?

 6   A    That’s our attorneys.

 7            MR. FURR:  No.  Not anymore.  Ware is not in it.

 8   A    Ware is not in it anymore.  Ryan Urtnowski.

 9            MR. FURR:  Urtnowski.

10   Q    (By Ms. Mouser)  And he’s the one — well, let me

11   rephrase.  The firm that he was with — may still be with --

12   they're the ones that failed to file the answer on time?

13   A    Lawyer Ware.

14   Q    Ware failed to file the answer on time?

15   A    Yes.

16   Q    So is Urtnowski — he is handling the appeal now?

17            MR. FURR:  Correct.

18            MS. MOUSER:  And is he being paid?

19            MR. FURR:  I don't know.

20   A    I imagine so.

21   Q    (By Ms. Mouser)  Did they also default as to — was

22   Mr. Carto a defendant?  I can't remember.  Do you-all

23   remember if Mr. Carto was a --

24            MR. FURR:  Yes.  That’s the judgment in

25   California --



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  79



 1            MS. MOUSER:  Yes.

 2            MR. FURR:  — where they got that --

 3            MS. MOUSER:  And did they default as to Mr. Carto

 4   too?

 5            MR. FURR:  Oh, yes.

 6            MS. MOUSER:  Okay.  Now, I didn't remember that.

 7   See, that may have been something I would --

 8            MRS. FURR:  I don't remember that either.

 9            MR. FURR:  That was against all of us.

10            MS. MOUSER:  As I recall, they started by naming

11   them John Does, remember?

12            MR. FURR:  That was --

13            MS. MOUSER:  They maybe did not know who all to

14   name, and they named like John Doe one through something.

15            MR. FURR:  They said 50 John Does.

16            MS. MOUSER:  Yeah.

17            MR. FURR:  And that was when they had filed

18   something that brought us into it.

19            MS. MOUSER:  An amendment probably.

20            MR. FURR:  We weren't listed in the initial

21   complaint.

22            MRS. FURR:  We weren't listed in the initial.

23            MS. MOUSER:  Right, see.  And then they would have

24   amended to name you.

25        And you believe that Ware and Urtnowski also represented



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  80



 1   the Cartos initially?

 2            MR. FURR:  Initially.

 3   Q    (By Ms. Mouser)  If Mr. Urtnowski is getting paid, who

 4   do you think is paying him to handle the appeal on your

 5   behalf, Mrs. Furr?

 6   A    I would imagine Mr. Carto.

 7            MR. HONEY:  I mean, don't say it unless you know.

 8            MRS. FURR:  Well, I --

 9            MR. HONEY:  I mean, you can say — you know you

10   haven't paid and --

11   A    I haven't paid them, so I don't know the source.

12   Q    (By Ms. Mouser)  Okay.

13            MS. MOUSER:  And, Mr. Furr, have you paid

14   Mr. Urtnowski — I guess.

15            MR. FURR:  No.

16            MS. MOUSER:  Is that how you say it? — any money.

17            MR. FURR:  No.

18   Q    (By Ms. Mouser)  Now, I've also seen some documents — a

19   bank versus Hereford, H-e-r-e-f-o-r-d, Corporation or maybe

20   H-e-r-f-o-r-d.  Do you know anything about that litigation?

21   A    I don't know anything about that.

22            MS. MOUSER:  Do you know anything about that

23   litigation?

24            MR. FURR:  No.

25   Q    (By Ms. Mouser)  Have you ever heard of a Hereford or



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  81



 1   Herford Corporation before?

 2   A    No.

 3   Q    Then I also think that Mrs. Carto and a fellow named Tom

 4   K-e-r-r — now, Mrs. Furr, do you know a Tom Kerr or know of

 5   a Tom Kerr?

 6   A    I met him once.

 7   Q    What do you know about him?

 8   A    He — I think he was on the board one time.

 9   Q    The board of the legion?

10   A    He’s dead.

11   Q    I guess he’s not on the board of the legion anymore, is

12   he?

13            MR. FURR:  No way.

14   Q    (By Ms. Mouser)  Did you ever meet him personally?

15   A    I met him personally.

16   Q    Was he also employed by the legion or just on the board?

17   A    No.  He was — what I understood, that Tom Marcellus

18   hired him to translate a book from German that they wanted to

19   print in English.

20   Q    And that was Tom Kerr?

21   A    Tom Kerr.  And also Tom Marcellus told Tom Kerr that

22   there was nobody by the name of LaVonne D. Furr.  And so

23   Willis called me and said, Would you mind talking to Tom

24   Kerr.  I will give you his number.  I will not give you her

25   — her number.  And so I called him, and he said, Well, Tom



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  82



 1   told me that you didn't exist, that Mr. Carto just made it

 2   up.  And he said, I wanted to hear your voice.  So then I --

 3   he knew of Mr. Matthews.

 4   Q    Yeah.

 5   A    So I had a back copy with my name in it as managing

 6   editor, and I mailed it to him.  I got a thank-you note from

 7   him.  That was it.

 8   Q    Do you know where Tom Marcellus is today?

 9   A    I have no idea.  I haven't known where he’s been at for

10   a long time.

11            MS. MOUSER:  What about you, Mr. Furr?

12            MR. FURR:  No.

13            MS. MOUSER:  Do you know where he is today?

14   A    I don't know where any of them are at.

15   Q    (By Ms. Mouser)  In fact, I think that I don't have any

16   information which leads me to believe that Mr. Marcellus has

17   any connection to the legion any more.  Do you know?

18   A    No.  I think there was a letter --

19            MR. FURR:  We got a letter from him — I don't

20   remember the date — that said he’s resigned all affiliation

21   with the legion.

22            MS. MOUSER:  That’s interesting.

23   A    It was always --

24   Q    (By Mr. Mouser)  That would have been sometime '95 or

25   before.  Right?  Because you say the last letter you think



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  83



 1   you got from Mr. Marcellus was in '95, so that would have

 2   been --

 3   A    And I think he started it out and said, As you know, I

 4   am no longer affiliated.

 5   Q    But no idea where he might be today?

 6   A    I have no idea.

 7   Q    Do you-all — Mrs. Furr, I'm going to start with you.

 8   Now, it seems like Elisabeth Carto and Mr. Kerr sued the

 9   legion.  Do you know anything about that lawsuit?  It’s out

10   in California.

11   A    I do not know.

12   Q    Did you ever go testify in that case?

13   A    I've never testified in California.

14   Q    You've never testified in any litigation in California?

15   A    I have never testified.

16   Q    You're sure about that?

17   A    Yes.

18   Q    All right.

19   A    I attended.

20   Q    Were you there to observe?

21   A    I was there to observe.

22   Q    Okay.  Maybe that’s --

23   A    Yeah.  I was there in 1993.

24   Q    Was that in your case or another case?  Do you remember?

25   A    Their case.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  84



 1   Q    Well, maybe Mrs. Carto and Mr. Kerr’s case?

 2            MR. FURR:  Yeah.  That was it.

 3            MS. MOUSER:  Would that have been it, Mr. Furr?

 4            MR. FURR:  That’s it.  Yes.

 5            MS. MOUSER:  Were you there as well?

 6            MR. FURR:  Yes.

 7            MS. MOUSER:  But just to observe.

 8            MR. FURR:  Right.

 9   A    Tom Kerr never got on the witness stand.  That’s when I

10   met him.

11   Q    (By Ms. Mouser)  But you never got on the witness stand,

12   Mrs. Furr?

13   A    Right.

14            MS. MOUSER:  And, Mr. Furr, you did not get on the

15   witness stand?

16            MR. FURR:  No.

17   Q    (By Ms. Mouser)  Did someone take your deposition in

18   that case, Mrs. Furr, either here or in California?  Do you

19   remember you gave a deposition in that case?

20   A    Yes.  Here in Hot Springs.

21   Q    Do you remember what — what was that all about?  Do you

22   remember?

23   A    About the same questions you're asking.

24   Q    About the corporation?

25   A    Corporation.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  85



 1   Q    Incorporators and all that kind of stuff?

 2   A    And the history of American Mercury.

 3            MS. MOUSER:  Mr. Furr, were you deposed either here

 4   or in California or anywhere else in that Elisabeth Carto and

 5   Tom Kerr matter?

 6            MR. FURR:  I don't remember.  I don't think I was.

 7            MS. MOUSER:  Do you know the status of that case,

 8   Mr. Furr, as we sit here today?  Now, you were not a party.

 9            MR. FURR:  No.

10   Q    (By Ms. Mouser)  Do you, Mrs. Furr, know what happened?

11   A    I don't think what we were deposed over was anything

12   about — I think it was about the judgment.  No.  I don't

13   think it was Tom Kerr at all.  His name was never mentioned.

14   Q    Did he die unexpectedly?

15   A    No.  Shortly after all this happened, he had one tumor,

16   brain tumor, after — I mean, it was a year and a half, and

17   he died.  It wasn't just suddenly.  It was illness, prolonged

18   illness.

19            MR. FURR:  I have a letter from Tom Marcellus dated

20   October 6, 1995, saying he resigned all my position with the

21   legion.

22            MRS. FURR:  That’s in her — what she requested.

23            MS. MOUSER:  Uh-huh.  Okay.

24            MR. FURR:  In March.  It said in March he would

25   resign.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  86



 1   Q    (By Ms. Mouser)  No reason why stated in that letter

 2   that you can tell?  I may or may not have that letter.  I

 3   don't remember seeing a letter, but I've looked at a lot of

 4   things.

 5        And Howard Singleton was just the attorney who handled

 6   the initial litigation in Texas by the incorporators.

 7   Right?

 8   A    Correct.

 9   Q    To go back a ways, Mrs. Furr, from '67 to '79, how often

10   do you think you spoke with Willis Carto?  Every day, I

11   imagine.

12   A    He would be in California two or three weeks or five

13   weeks.  And probably every other day.  The longest he didn't

14   call was when we had an earthquake and didn't have a

15   telephone for 14 days.

16   Q    That may be another reason why Mr. Furr didn't like

17   California.

18            MR. FURR:  That’s right.

19            MS. MOUSER:  I'm with you.  I'll take a tornado any

20   day over the earthquake.

21            MRS. FURR:  No.  He was working downtown doing the

22   title research.

23            MR. FURR:  Title insurance.

24            MRS. FURR:  And he thought he was having a dizzy

25   spell and somebody hollered earthquake.  And, of course,



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  87



 1   everybody said no elevator.

 2            MS. MOUSER:  But anyway --

 3            MR. FURR:  I was up on about the 11th floor of the

 4   building.

 5            MS. MOUSER:  Uh-huh.  Uh-huh.

 6   Q    (By Ms. Mouser)  But Mr. Carto, during those years, you

 7   probably spoke with him quite frequently.

 8   A    Certainly.

 9   Q    Did you grow to have an opinion, as opposed to whatever

10   opinion you have today, which may be the same?  But during

11   those years from the time you first met him outside the

12   Library of Congress, you saw him in Mr. Graham’s office when

13   he became a substitute incorporator.  Those very initial

14   times for the time '67 until '79, did you come to develop an

15   opinion about Mr. Carto as to his veracity, his truthfulness?

16   And, if so, what opinion did you hold back then?

17   A    I always thought he was a hard worker.  He thought

18   everybody should work seven days a week.  We had difference

19   of opinion on religion.

20   Q    And I don't care to know your opinion, but I would like

21   to know what was his opinion about religion?

22   A    He just didn't have one.

23   Q    Was he a professed atheist that you recall?

24   A    I'm not going to say that.

25   Q    Did Liberty Lobby, from what you could tell, was its



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  88



 1   main goal like the legion, to combat communism all over the

 2   world?

 3   A    The legion was more, when it started, was fighting

 4   communism.  And to me Liberty Lobby is getting — that's

 5   where the name come from, is lobby; that they would have

 6   people lobby and listen to legislation.

 7   Q    Yes, ma'am.  That was more of a lobbying organization?

 8   A    Right.  That’s how the name arrived.  I don't know how

 9   the name arrived, but that’s what I just have, you know,

10   assumed.

11   Q    What about your opinion during those years about

12   Mr. Carto’s truthfulness?  He was a hard worker?

13   A    He was always truthful to me.

14   Q    Did he have much day-to-day contact with the money of

15   the legion?

16   A    He had none whatsoever.

17   Q    Other than you, who did?

18   A    No one.  I was audited by the IRS.

19   Q    You mean you personally or the legion was?

20   A    I.

21   Q    Let’s let Mr. Furr say something.

22            MR. FURR:  The legion had no money whatever.  Bank

23   account was in the name of American Mercury.

24   Q    (By Ms. Mouser)  Let me rephrase about the name I'm

25   using then.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  89



 1   A    The answer under American Mercury because the legion

 2   never had a bank account.

 3   Q    As far as Mr. Carto ever having anything to do with the

 4   American Mercury’s money?

 5   A    He did not.  He signed a bank card, and when my first

 6   granddaughter was born, he might have used it because I was

 7   gone for two weeks.

 8   Q    Sure.

 9   A    But he never — I mean, he would look at it and, How are

10   we doing, or things like that.  But I was the only one who

11   wrote checks or made deposits.

12   Q    And during those two weeks, you did not feel he misused

13   the accounts?

14   A    No.  The check never came through if he did.  I don't

15   remember, but just in — I say --

16   Q    From the time of '79 until the time of your resignation

17   or when it was revoked in '93, did you have any dealings with

18   Mr. Carto during that period of time?

19   A    We talked about the progress of the legion and what Tom

20   Marcellus was doing and who he hired.

21   Q    How much did you speak over the telephone with Mr. Carto

22   during that period of time, if you could generalize it?

23   A    Sometimes we would go two weeks.  And during that time,

24   five months with my mother, I didn't during that time.

25   Q    Did he call you most of the time or you call him?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  90



 1   A    He called most of the time.

 2   Q    And wanted to visit about what was going on?

 3   A    And keep me informed and whatever.

 4   Q    Did you have any feel for where Liberty Lobby was

 5   getting its money?

 6   A    No.

 7   Q    Now, since 1993 have you had occasion to visit with

 8   Mr. Carto over the telephone?

 9   A    Certainly.

10   Q    And when was the last time you think you spoke with

11   Mr. Carto?

12   A    Probably last week.

13   Q    And what seemed to be the necessities for your

14   continuing to communicate with him?

15   A    Oh, I know.  I asked him had he had any information from

16   Mr. Izen as to anything in writing, and he did not.

17   Q    This was about the appeal being dismissed?

18   A    Right.

19   Q    Yes, ma'am.

20   A    So I said — from your letter, I said, I haven't gotten

21   anything in writing yet, and he says, No.  I haven't either.

22   He said, I'll call Mr. Izen.  And I think that was the last

23   time.

24   Q    Other than that call, when was the last time you had

25   spoken with Mr. Carto?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  91



 1   A    Probably a couple of weeks before that.

 2   Q    And what was the nature of that call?

 3   A    I don't remember.  Sometime he'd just call, How are you

 4   doing, and things like that.

 5   Q    Is Ms. Elisabeth Carto still living?

 6   A    Yes.

 7   Q    Are they still married?

 8   A    Yes.

 9   Q    And do you ever have occasion to visit with her?

10   A    Once in awhile when I can't get ahold of Willis when I

11   wanted to ask — you know, to find some papers for me that I

12   don't have or, you know, what was going on.

13   Q    Now, what kind of papers would you be asking Mr. Carto

14   about at this time?

15   A    The — whether the — what was going on with the appeal

16   or Mr. Izen.

17   Q    Uh-huh.  Other than the litigation in Texas and

18   California, have you discussed any other matters with Mr.

19   Carto since '93, since your resignation, I believe, in — you

20   told me — since September of '93?

21   A    I don't know what we discussed.

22            MS. MOUSER:  What about you, Mr. Furr?  Since '93,

23   have you had any discussions with Mr. Carto?

24            MR. FURR:  Occasionally.  I don't remember how

25   often.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  92



 1            MS. MOUSER:  What have those conversations been

 2   about?

 3            MR. FURR:  It varied.  Some of it was about the

 4   litigation, and some of it was he wanted us to come out there

 5   and visit him.

 6            MS. MOUSER:  Have you-all been out there to visit

 7   him?

 8            MR. FURR:  Not lately.  We were out there one time.

 9            MS. MOUSER:  When was that?

10            MR. FURR:  In 1993.

11            MRS. FURR:  '3.

12            MR. FURR:  That’s when I --

13            MS. MOUSER:  Why don't we take a lunch break and

14   come back about 1:15.  Is that okay, Mark?

15            MR. HONEY:  Yeah.  That’s fine.

16            MS. MOUSER:  I'd really like to try to finish up

17   this afternoon, so we don't have to come back tomorrow.

18        Off the record.

19              (AN OFF-THE-RECORD DISCUSSION WAS HELD.)

20

21                (A LUNCH RECESS WAS TAKEN.)

22   Q    (By Ms. Mouser)  Well, we'll go back on the record now.

23   And let me just do a few follow-up questions from this

24   morning, Mrs. Furr, and we'll maybe move into a new area.

25        I believe at one time in the past you have said in a



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                  93



 1   deposition that you have never financially invested in the

 2   legion.  And I would mean by that, or I would have thought

 3   what the question meant — it wasn't explained in the

 4   deposition — have you ever given large amounts of money to

 5   the legion as opposed to your time, which obviously was a

 6   huge investment?

 7   A    No, ma'am.  When you live on less than $1,000 — I mean,

 8   $2,000, I don't know what — with three kids and two in

 9   college, where would it come from?

10   Q    And I was talking about back in the years like '67 to

11   '79?

12   A    No.

13   Q    Your investment was your time?

14   A    My time.

15   Q    And your energy.

16   A    My father gave money.

17   Q    Yes.

18   A    Not a big amount.

19   Q    But not you personally?

20   A    But I personally did not.

21            MS. MOUSER:  Mr. Furr, would that be true of you as

22   well?

23            MR. FURR:  Yes, ma'am.

24   Q    (By Ms. Mouser)  Now, I know you served a long time on

25   the board.  I don't think I asked this morning — I know you



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 1   are an incorporator, but when did you actually go on the

 2   board?  Was it in '67?

 3   A    '65 when — but I don't remember if that was a voting --

 4   see --

 5   Q    That’s right.  You mentioned that this morning.

 6   A    In '65.

 7   Q    In '65?

 8   A    No.  Excuse me.  '64.  Because he died in '64.

 9            MS. MOUSER:  And, Mr. Furr, do you remember when you

10   went on the board?

11            MR. FURR:  No.  It was after that.

12            MS. MOUSER:  But it was after '64, wasn't it?

13            MR. FURR:  Oh, yeah.

14   Q    (By Ms. Mouser)  Do you remember, Mrs. Furr, were you

15   elected by the other board members?  And, if so, who were

16   those board members?

17   A    Marchita Matthews and — that was the only one left.

18   Q    And Mrs. Matthews.  That’s right.  Okay.

19   A    Yes.  I don't remember if — that would be it.

20   Q    That would be the only ones.  That’s right.

21            MS. MOUSER:  And then, Mr. Furr, do you recall who

22   was on the board when you were elected a board member?

23            MR. FURR:  I don't remember.

24   Q    (By Ms. Mouser)  Do you remember, Mrs. Furr, who was on

25   the board when --



                          AMY MILLER, CCR-RPR
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 1   A    Well, I was.

 2   Q    Right.  And, of course, Marchita was gone basically --

 3   A    Oh, she was gone.

 4   Q    — after her dad died in '67?

 5   A    Yeah. '66.  Yeah.  When Willis and I took over, late '65

 6   or whenever that ever happened.  I can't remember the date.

 7   Q    Would it have been after Mr. Carto came on as an

 8   incorporator?

 9   A    Oh, way after.

10   Q    Way after that.  Okay.

11        From '67 to '79, do you think the legion had an annual

12   meeting?  A lot of non-profits and for-profits have like an

13   annual meeting just to say — a lot of them have them just to

14   say they had one.

15   A    Yeah.  We had an annual meeting.

16   Q    Did you-all have any other regularly scheduled meetings?

17   Like was there a certain time every month?

18   A    March was --

19   Q    The annual meeting?

20   A    That was --

21   Q    Were there any monthly meetings?  Some boards, like,

22   meet once a month.  Did the board of the legion from '67 to

23   '79, while you were in California --

24   A    No.  Because Willis and I communicated all the time.

25   Q    Sure.



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 1   A    And there was no need to have a weekly or a monthly.  It

 2   was just --

 3   Q    Right.  What about '79 to '93 when you attempted to

 4   resign and then attempted to revoke?

 5   A    We still had — yes.

 6   Q    Still annual meetings, but, once again, no regular

 7   monthly or other meetings?

 8   A    No.

 9   Q    Now, have you ever seen, from the beginning days when

10   you volunteered with Mr. Matthews to today — have you ever

11   seen a corporate book, a corporate minute book?

12   A    Yes.

13   Q    And do you know where that is, as we speak?

14   A    I probably looked at it once.  Mr. Carto has always had

15   it.

16   Q    And when you say he’s always had it, since the move to

17   California he has had it?

18   A    I don't remember.  It was either in my office, but when

19   — that was all left, like I told you this morning.

20   Q    Right.  And that would have been left with

21   Mr. Marcellus, wouldn't it?

22   A    No.

23   Q    No?  The corporate minute book would not have been in

24   the documents that you turned over to Mr. Marcellus that

25   were --



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 1   A    I didn't have the documents to turn over.

 2   Q    Mr. Carto did?

 3   A    Mr. Carto had — he was — I left everything.  All the

 4   minutes, everything that — the seal that was there, which

 5   had McAllen on it.  Everything was there because I had no

 6   need for it.

 7   Q    And I guess I had thought from this morning that

 8   Mr. Marcellus came and — of course, your office was in your

 9   home.  So when you were moving your home, that Mr. Marcellus

10   moved some of that stuff out and then the others went down to

11   Mr. Touchstone.

12   A    All the corporate minutes --

13   Q    The corporate records?

14   A    — all went with Mr. Carto.  That was always in my hands

15   or his hands.

16   Q    I know he had a home, you said, in California.  Did he

17   have a — and I know he had the business location in D.C.

18   Did he have a business location in California that you knew

19   of at that time, like '67 to '79?

20   A    Liberty Lobby.

21   Q    Oh, he had a building in California as well?

22   A    No — yes.

23   Q    Well, that’s what I was --

24   A    Oh, just a small office.

25   Q    Yes, ma'am.  And was that in Torrance as well?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    No.  That was on Labrea Street.

 2   Q    Okay.  Now, one more time.

 3   A    Labrea.

 4   Q    Labrea Street?

 5   A    Uh-huh.

 6   Q    And we don't --

 7   A    Los Angeles.

 8   Q    Oh.  That was in Los Angeles.  Okay?

 9            MR. FURR:  That’s L-a-b-r-e-a.

10            MS. MOUSER:  That’s the Labrea Street.  Okay.

11   Q    (By Ms. Mouser)  Do you recall in the communications

12   with Tom Marcellus, did he ever allege that he had any of the

13   corporate records?

14   A    No.  He asked for them.

15   Q    And I don't think I ever recall him alleging he had the

16   corporate seal either.

17   A    No, he did not.

18            MS. MOUSER:  Mr. Furr, in the conversations that you

19   had with Mr. Marcellus or from his letters, do you ever

20   recall him saying that he had any of the corporate records?

21            MR. FURR:  No.

22            MS. MOUSER:  Or the corporate seal?

23            MR. FURR:  No.

24            MS. MOUSER:  Do you know, Mr. Furr — did you see

25   the corporate records or the corporate seal being delivered



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 1   to Mr. Carto?  Do you have any personal knowledge of that?

 2            MR. FURR:  No.

 3   Q    (By Ms. Mouser)  Have you had any discussions since '79,

 4   Mrs. Furr, with Mr. Carto about where those corporate records

 5   would be?

 6   A    No.

 7   Q    What about the corporate seal?  Have you asked him about

 8   where that might be?

 9   A    I always knew he had them.

10   Q    Would he have them in California or D. C.?

11   A    No.  That would stay in California.

12   Q    When you say you always knew he had them, did you ever

13   see them in his possession after '79 or you just assumed that

14   that’s where they would be?

15   A    I assumed that’s where they would be.

16   Q    You've never actually seen them in his possession?

17   A    No.

18            MS. MOUSER:  What about you, Mr. Furr?  Have you

19   ever seen, since 1979, Mr. Carto in possession of corporate

20   records or the corporate seal?

21            MR. FURR:  No.

22   Q    (By Ms. Mouser)  Did Mr. Carto, Mrs. Furr, ever indicate

23   that he would have trusted anyone else enough to let them

24   take possession — not ownership, but possession — of those

25   documents or the seal?



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 1   A    Knowing him, he would not; and knowing me, I would not.

 2   Q    Sure.  That’s kind of my impression as well.

 3        Do you know if any of the documents — let me rephrase.

 4   Did you ever have any copies of some of the documents that I

 5   would call corporate records, like meeting minutes or

 6   letters, et cetera?

 7   A    From the '80s I got some of the minutes, which you have,

 8   but none of the corporate.  I never had any in my possession.

 9   Q    And when you say you have, I think you have brought some

10   things today with you.

11   A    I think your requested minutes and --

12   Q    Yes, ma'am.

13            MR. HONEY:  She brought some documents in response

14   to your request.

15            MS. MOUSER:  Yeah.  We'll look at those in a minute.

16   Sure.  Yeah.

17   Q    (By Ms. Mouser)  Did you ever deliver any copies or

18   original documents to Mr. Singleton in Texas?

19   A    Yes.

20   Q    Do you recall just generally what you delivered to

21   Mr. Singleton?

22   A    I mailed everything I had, which is right there.

23   Q    And so are these copies of what you mailed to him?

24   A    I don't know what he sent me back, whether they were --

25   I never had the originals.  Because we would do up the



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 1   minutes, and at one time, we had the board members sign; I'd

 2   seen send it to somebody, and they would forward it on and

 3   then forward it on to Mr. Carto.

 4   Q    Yes, ma'am.

 5   A    So I always have copies.  I got some copies with no

 6   signatures on it at all.

 7   Q    Right.  And some with all signatures because maybe you

 8   just got a copy when it was all signed.  But ultimately, the

 9   original was intended to be with Mr. Carto?

10   A    Right.

11   Q    The documents you sent to Mr. Singleton, has he sent you

12   most or all those back, to your knowledge?

13   A    As to my knowledge.  Then he — I know he probably made

14   copies because his — the judgment or summary judgment, I see

15   he’s got some.  So they would have to be.

16   Q    I think I read somewhere that at one time after you were

17   gone, the office or offices of the legion were burned.

18   A    Correct.

19   Q    What do you — I mean, obviously, you weren't there, but

20   what have you heard and what do you understand happened?

21   A    Somehow a fire broke out.  And I don't know how much was

22   destroyed or whatever.

23   Q    Was it your understanding — were the offices in a home

24   or was it an office building?

25   A    The office was in a complex.  Just — well, somebody had



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 1   a furniture store here; somebody had a rug thing.

 2   Q    Kind of like a street mall, street fronts?

 3   A    Street mall with different things.

 4   Q    Was Tom Marcellus still kind of the day-to-day manager

 5   guy at that time?

 6   A    That was in '85 so he was in charge.

 7   Q    Because he didn't leave — I think we found that letter

 8   — Mr. Furr did.  He resigned totally in '95 from all his

 9   responsibilities.  Is that what you recall from this morning?

10   A    Right.

11   Q    Did you ever hear anyone talk about whether there was

12   any insurance on the contents?

13   A    There was — I remember Willis saying that there was not

14   enough insurance for all the books that got burned.

15   Q    Sure.  Do you recall whether Mr. Carto or anyone else

16   ever indicated if the corporate records were destroyed in the

17   fire?

18   A    No.

19   Q    Just don't recall?

20   A    I don't.

21   Q    Now, if we could talk a little bit about — I'm going to

22   call her Jean Farrell.  I think she actually had a hyphenated

23   last name.  Eddison.  Jean Eddison-Farrell.  Did you ever

24   meet a woman named Jean Eddison-Farrell?

25   A    Never knew her.



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 1            MS. MOUSER:  Did you ever meet Jean Eddison-Farrell,

 2   Mr. Furr?

 3            MR. FURR:  No.

 4   Q    (By Ms. Mouser)  When did you first hear of her name,

 5   Mrs. Furr?

 6   A    When she died.

 7   Q    And who, first of all, mentioned her name to you?

 8   A    That was — she died the day before my mother.

 9   Q    How about that.

10   A    And I didn't even know that she had died.  And when I

11   called — after the funeral, when I called Mr. Carto, he knew

12   it, but he didn't tell me then.  And it was probably a week

13   — I don't know — later.

14   Q    Had you known of her before they --

15   A    Never heard her name.

16   Q    And so when he called you after your mom’s death and he

17   called you to tell you Jean Farrell had died, what did he say

18   about her?  Why would he have brought her name up?

19   A    That she had left some money to Mr. Carto.  He said me.

20   And he says, I'm going to go over there and see what I can do

21   about it.

22   Q    So Mr. Carto indicated that the money from Ms. Farrell

23   was left to him personally?

24   A    For him to do as he wished.

25   Q    Did you ever see a will that said that?



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 1   A    No, ma'am.

 2   Q    And do you know if Mr. Carto actually went — and when

 3   you say over there, I think it was in Switzerland, was it

 4   not?

 5   A    Yes.

 6   Q    And do you recall if he ever went over there?

 7   A    Yes.  He went several times.

 8   Q    And did you ever accompany him on any of those trips?

 9   A    No.

10   Q    And do you know what, if anything, happened to the

11   estate in any bequest that Ms. Farrell gave to Mr. Carto?

12   A    He said she was never married.  I do remember that.  He

13   did say that some of it went to a couple of nieces or

14   nephews.  I don't remember all of that.

15   Q    Do you recall any explanation of why she would have left

16   any money to Mr. Carto?

17   A    He said that they were friends.

18   Q    Uh-huh.

19   A    And she was a great friend, I guess.  Well, I don't

20   know.  But she liked Liberty Lobby, from what I've been told.

21   I don't know if she did or not.

22   Q    Was she an American citizen?  Do you know anything about

23   her personally?

24   A    I do not know that, no.

25   Q    Did you ever give Mr. Carto your power of attorney on



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   behalf of the legion to do anything for the legion in regard

 2   to Ms. Farrell’s estate?

 3   A    I gave him power of attorney.

 4   Q    And why would you have done that if the bequest was to

 5   Mr. Carto individually?

 6   A    He asked me to, to see — I don't know why he asked me

 7   to, really.

 8   Q    Why did you sign such a power of attorney if your

 9   understanding was that the bequest was to him individually?

10   A    I don't know that it was individually, but that was my

11   understanding.  I didn't see anything to know whether it was

12   to Liberty Lobby.  And all I can remember him saying is to do

13   what I wanted to do, and I know that he wanted to help the

14   legion as well as Liberty Lobby.

15   Q    So you basically signed the power of attorney to allow

16   Mr. Carto to handle whatever portion of that estate he wanted

17   to give to the legion; is that right?

18   A    Whatever he wanted to do.

19   Q    What amount — did you ever have any understanding as to

20   the amount of the estate of Jean Farrell?

21   A    Not the total amount.  I never have known.

22   Q    Did you ever have any understanding or information,

23   rumor or otherwise, in regard to where Ms. Farrell came upon

24   such a great deal of wealth?

25   A    She was related to Eddison, a granddaughter or a



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   great-granddaughter.  And I understand she had some holdings

 2   in South America, but that’s all — you know, where else, I

 3   don't know.

 4   Q    And my question was more as to the source of the funds.

 5   A    I don't know.

 6   Q    Do you know enough to know that the estate was millions

 7   of dollars?

 8   A    Yes.

 9   Q    And who indicated that to you?

10   A    Mr. Carto.

11   Q    And did he ever mention how many millions of dollars?

12   A    He didn't mention it, but I read in the Spotlight I

13   think he mentioned around 6 million.

14   Q    And the Spotlight is what, now?

15   A    His newspaper.

16   Q    From Liberty Lobby?

17   A    From Liberty Lobby.

18            MS. MOUSER:  What about you, Mr. Furr?  Did you ever

19   have any discussions with anyone about Ms. Farrell’s estate?

20            MR. FURR:  No.

21            MS. MOUSER:  You never talked to Willis Carto about

22   that?

23            MR. FURR:  No.

24   Q    (By Ms. Mouser)  What about NECA Corporation?  Mr. Carto

25   mentions the corporation NECA, N-E-C-A.  Do you know anything



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   about that corporation?

 2   A    I think that was the corporation that was left to her

 3   nieces.  And I can't remember if it was nieces and nephews or

 4   just what.

 5   Q    Do you know or did Mr. Carto ever indicate, or anyone

 6   else ever indicate, what that corporation’s assets were?

 7   A    No.  I don't remember.

 8   Q    Do you remember if it was a United States corporation?

 9   A    I don't know.

10            MS. MOUSER:  What about you, Mr. Furr?  Does the

11   company named NECA Corporation mean anything to you?

12            MR. FURR:  I've heard of it.

13            MS. MOUSER:  Who did you hear discussing it or

14   mentioning it?

15            MR. FURR:  I'm going to disagree with her.  I think

16   that was a corporation set up by Jean Farrell to — funneling

17   money to Mr. Carto.

18            MS. MOUSER:  Did you say you were in agreement with

19   Mrs. Furr or disagreement?

20            MR. FURR:  Disagreement with what she said.

21            MS. MOUSER:  Okay.  And --

22            MR. FURR:  I may be wrong too.

23            MS. MOUSER:  Well, I'm just asking what you know,

24   either rumor or hearsay.  What did you think it was, now.

25            MR. FURR:  That was a corporation set up to transfer



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 1   some of the estate to Mr. Carto.

 2            MS. MOUSER:  And do you think Ms. Farrell

 3   established that corporation before she died?

 4            MR. FURR:  Yeah.  That’s my impression.  Now, I have

 5   no --

 6            MS. MOUSER:  Did you get the impression that there

 7   was something wrong with that?

 8            MR. FURR:  No.

 9   Q    (By Ms. Mouser)  What about Joan Althaus?  Did she have

10   a daughter named Joan Althaus?

11   A    She had no children.

12   Q    No children.  So if there was a Joan — and I think it's

13   spelled A-l-t-h-a-u-s — if there was a woman named Joan

14   Althaus who was making a claim on the estate, did you ever

15   hear about her?

16   A    All I'm telling you is what I --

17   Q    Sure.

18   A    I mean, I don't know.

19   Q    You weren't in Switzerland, did not know this woman.

20   I'm just asking what you've heard.

21   A    I think I remember hearing that she was a companion.

22   Q    A friend, not a family member?

23   A    That’s right.

24            MS. MOUSER:  What about you, Mr. Furr?  Did you ever

25   hear anyone talk about Ms. Althaus?



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 1            MR. FURR:  That’s the way I understood it.  She was

 2   a friend or housekeeper or something.

 3   Q    (By Ms. Mouser)  Do you recall — did anyone ever say

 4   that she was trying to make claim to the estate in opposition

 5   to Mr. Carto and anyone he would choose to give the money to?

 6   Did you ever hear that, Mrs. Furr?

 7   A    I think he said that he had to go over there and explain

 8   to her what Ms. Farrell wanted and mention that — I don't

 9   know if there was any conflict or anything.

10   Q    Now, some of the things I have read seem to indicate

11   that the bequest was actually to the legion, and because the

12   legion did not have sufficient finances to protect itself, to

13   get its bequest, that basically that’s why you gave power of

14   attorney to Mr. Carto to go over there and basically protect

15   the interest of the legion.  But sitting here today, you

16   disagree with that theory, that story?

17   A    I didn't understand it.

18   Q    Why would Mr. Carto — did he say or do you have any

19   opinion as to why he would have given any of the money to the

20   legion in lieu of Liberty Lobby?

21   A    Because he believed in the IHR and the books.  He wanted

22   to promote the books that they were selling.

23   Q    Now, let’s talk about IHR.  You mentioned that this

24   morning.

25   A    Institute for Historical Review.



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 1   Q    Historical Review.  Now, what exactly is that, in your

 2   opinion?

 3   A    I don't even know what books they published.  British

 4   history.

 5   Q    Was it a publishing entity, to the best of your

 6   knowledge?

 7   A    Right.

 8            MS. MOUSER:  Do you have any separate knowledge of

 9   IHR, Mr. Furr?

10            MR. FURR:  That’s correct, what she says.

11   Q    (By Ms. Mouser)  Now, obviously I don't want to get into

12   revisionism.  But did you feel that the legion way, way back

13   there with Mr. Matthews, was it a revisionist movement?

14   A    I don't understand revisionist movement, so I can't

15   answer that.

16   Q    So you certainly didn't think it was, since you don't

17   know what that is, really.  Mr. Matthews never talked about

18   it that way?

19   A    No.

20   Q    Did Mr. Carto ever talk about Liberty Lobby or the

21   American Mercury or the legion or — I know IHR may be.  But

22   any of those other organizations, did he ever use the phrase

23   “revisionist history” or “revisionism"?  Did he ever use

24   those terms?

25   A    Not that he wanted the American Mercury to be



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 1   revisionist.

 2   Q    Right.  What about the legion?

 3   A    I don't think so, but he was very interested in

 4   revisionist history.

 5   Q    Right.  Now, the IHR, though, is a revisionist movement

 6   or publishing entity?

 7   A    I would say that, yes.

 8   Q    And do you know, are they still in the publishing

 9   business?

10   A    I do not know.

11            MS. MOUSER:  Do you know, Mr. Furr, if they're still

12   publishing?

13            MR. FURR:  I don't know.  I don't know.

14   Q    (By Ms. Mouser)  Now, was IHR a division or underneath

15   Liberty Lobby?

16   A    No.

17   Q    Who ran IHR, if you know?

18   A    It was founded by Willis Carto and then Tom Marcellus.

19   Q    Oh, okay.  Was it headquartered in --

20   A    Torrance — well, no.  Now, it’s in Costa Mesa, or it

21   was at that time.

22   Q    Was it basically out of the same office as American

23   Mercury until it was sold?

24   A    Not until I left, yeah.  Afterwards.

25   Q    So after you left, IHR kind of --



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    Forms.

 2   Q    — formed?

 3        Do you know if it’s a separate corporation?

 4   A    I don't think so.  I still think it’s under the legion.

 5   Q    (By Ms. Mouser)  Do they have like conferences or

 6   meetings or something?

 7   A    I have nothing at all to do with that.

 8   Q    To do with that.

 9            MS. MOUSER:  Do you know — just, Mr. Furr.  Do you

10   know?

11            MR. FURR:  They used to put out a publication

12   periodically.  I'm not sure how often.

13   Q    (By Ms. Mouser)  Have I asked about Noontime Press?  I

14   don't recall.  I know we talked about the American Mercury.

15   We talked about Mr. Furr’s Washington Observer.  But I saw --

16   Noontime Press, I think, was actually — was it a book?

17   A    It was books.

18   Q    Books?

19   A    It was books.

20            MR. FURR:  Book publishing branch of the legion.

21   Q    (By Ms. Mouser)  Of the legion.  So we had the legion,

22   and then we have American Mercury, which was the quarterly,

23   and then Washington Observer merged with it.  And then we

24   also have Noontime Press that did books.

25   A    That did merge with that.  Washington Observer



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   deceased --

 2   Q    That was really Liberty Lobby’s publication, wasn't it?

 3   I think you said this morning.

 4   A    No.  We had — I had — we had writers, because Lewis

 5   and I proofread it.  And it was printed in Torrance.  And it

 6   was a supplement, you might say, when — as I told you this

 7   morning, when the American Mercury — the months that it

 8   wasn't --

 9   Q    Uh-huh.  Yes.

10   A    So I was — pasted it up myself.

11   Q    You know, Mrs. Furr, you are a very well-educated woman.

12   I mean, to edit these types of articles.  You know — I mean,

13   you really are, aren't you?  I mean, I know you may not have

14   any — a lot of formal education, but you are a very educated

15   woman to be able to do all of this.  Don't you think?

16   A    No, ma'am.  I had a good proofreader that worked for

17   free.

18   Q    Oh, I see.  And you're pointing to Mr. Furr?

19   A    Right.

20   Q    Well, but you were the editor and — so, I mean, you had

21   a lot of responsibility and carried it forward for many

22   years.

23   A    I had, but I don't consider myself an editor at all.  To

24   me it was — I had no — I was interested in keeping the

25   American Mercury alive.  I was interested in public



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   education.  We had a religious article; we had a health

 2   article; some history article.  And I know what Mr. and Mrs.

 3   Matthews went through.  He even ate cat food.  I know he sold

 4   their jewelry because he was dedicated to the legion, as well

 5   as to the American Mercury.  And I could see what these

 6   people did.  And I know the money that my daddy put in to

 7   help and all that he went through.  And then I really got

 8   interested in the PTA and how corrupt it is.

 9   Q    Parent-Teacher Association?

10   A    Right.  And national education.  So that was one of my

11   first articles that I really helped --

12   Q    Right.

13   A    A man named Roy Friday from Michigan wrote it, and I

14   gave him some material.  And it was through — because I had

15   children in school, and I was interested in better education

16   way back.

17   Q    Right.

18   A    So that was — I know what these people went through.

19   Q    Uh-huh.  Uh-huh.  Are you involved in any other — have

20   you ever been involved, other than with the legion, in any

21   other cause as much and as strongly as you were with the

22   legion?

23   A    Brownies.

24   Q    Brownies.

25   A    No.  That’s it.  I mean --



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Q    Yeah.  I mean, it really was your life for many, many

 2   years?

 3   A    It was, with my kids.  And I have grandchildren, and I

 4   have two great-grandchildren.

 5   Q    Are in any of your children involved in the legion?

 6   A    Not in the least bit.

 7   Q    They might have been a little jealous of the legion

 8   maybe at one time.

 9   A    I think at some times Mother may have spent too much

10   time.

11   Q    Yeah.

12   A    And that’s why I don't do anything but, Mom, I need you.

13   Q    All moms — Ms. Miller and I were talking about that at

14   lunch.  All moms who work outside the home get that

15   sometimes.

16        Let me show you a document here — and, obviously, it is

17   a copy — and ask if you can identify that document,

18   Mrs. Furr.  Let me take that Post-it note off.  Mr. Honey

19   might want to look at it first.

20   A    Oh, yes.

21   Q    What do you recognize that document to be?

22   A    A report that he got back from Switzerland.

23   Q    When he — you mean --

24   A    Mr. Carto.

25   Q    And basically, what was he telling you?  You don't have



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   to read it, but just kind of summarize it.

 2   A    That she had left some money, and he was going to try --

 3   he said it’s worth our endeavor.  The legion had no money for

 4   him to go over there, and he said, We haven't got too much to

 5   lose.  And --

 6   Q    Was there any agreement on the front end that he was

 7   going to give a certain portion of his bequest to the legion,

 8   like 30 percent or some percentage or something?

 9   A    That was never discussed.  See, this was — he went two

10   weeks after my mother died.

11   Q    Yes, ma'am.

12   A    And I wasn't with it.

13   Q    Sure.

14   A    And I really didn't think too much — I don't even

15   remember what I thought.  That was during that time.

16   Q    That was a real traumatic period in your life.

17   A    I said — it was Jean Farrell, he told me.  And I just

18   don't remember.

19   Q    Do you know how long it took him to work through the

20   estate and get the money that --

21   A    It was several, several years.

22   Q    And as you — as time passed from the death of your

23   mother, did you have any discussions with him about paying --

24   the legion paying his expenses or, you know, Willis, what

25   type of return can we expect from this, or any discussions



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   along those lines?

 2   A    I left all that up to him.  I mean, that was his cup of

 3   tea.  Let me — it won't take too long.  I had a man write me

 4   from Long Beach, California, and says, I want to leave you

 5   some money.  And I says, Well --

 6   Q    Now, when was this?  I'm sorry.

 7   A    This was in probably 1978.

 8   Q    Yes, ma'am.

 9   A    Thomas Kennedy in Long Beach.  And he says, Can I see

10   you on Sunday?

11   Q    And he’s talking about you personally?

12   A    Personally.

13   Q    LaVonne D. Furr?

14   A    Right.  And so I — he lived in a little house,

15   apartment with a pay telephone.  He said, Call me at such and

16   such time.  Then when I talked to him, he said, I want to

17   leave some money.  I said, I'll have to get some papers.  I

18   don't think we had at that time anybody leaving the legion

19   any money --

20   Q    Right.

21   A    — except maybe where he had solicited $10 or a $15

22   check.  But nothing — you know, I didn't know what.  So, I

23   don't want your husband — I don't want no one to know.  And

24   so I went down on the Sunday afternoon scared to death.

25   Q    Sure.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    And here’s this man sitting on the bench, one kind of

 2   shoe on and one of another kind, you know.  And he says, I

 3   want to leave you $75,000.  And I says — well, I don't even

 4   think we had a lawyer at that time.  I says, I'll have to go

 5   get some papers.  He said no.  I'm not leaving it to no one.

 6   He says, When I die, I know that you're underpaid.  You can

 7   leave it to anybody.  You might not like the legion when I

 8   die.  So the next day, I went down — and I didn't tell Lewis

 9   or Willis for a long time.  And even after we moved to

10   Louisiana, he said that they changed the front key and he

11   sent me a new key.

12   Q    Now, who changed the front key to what?

13   A    His apartment.  The manager.  I mean, it was a hole in

14   the wall.

15   Q    You're talking about this gentleman who was going to

16   leave you the money?

17   A    Yes.  $75,000.

18   Q    Uh-huh.

19   A    Well, I never did hear from him.  And all of a sudden, a

20   paper that I signed and he signed in front of a notary --

21   said you might be interested in this.  And I already had a

22   copy, and I thought, well, I guess somebody found a copy.

23   And later on, years later — I mean, 10 years later --

24   Q    Were you in Louisiana?

25   A    No.  I was — when I told Lewis and told Mr. Carto, he



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   said, That man died and he was dying of cancer and left it

 2   all to the Catholic church.  But that’s how I feel that

 3   Mr. Carto — how anybody would find out — Tom Marcellus --

 4   that I got $75,000 and I was working for the legion.  But

 5   this was what this man said, and it was on there, to LaVonne

 6   D. Furr, $75,000.  Well, I thought that’s all — and he was a

 7   railroad retired man.

 8   Q    Sure.

 9   A    Knowing nobody.

10   Q    Sure.

11   A    So I can feel — to me, if I had to go through that and

12   he says, Well, he just said that you're just saying that --

13   so this is how I feel that this was.  I mean, you know, that

14   was him.  Because I didn't even know.  I didn't know anything

15   about her.

16   Q    About Ms. Farrell?

17   A    Yeah.  Never ever heard her name.

18   Q    And have you ever seen a copy of her will or do you know

19   if she had a will?

20   A    No.  I didn't even know that she had one.

21   Q    And Mr. Carto never discussed that with you, whether she

22   had a will or not?

23   A    No.  I never asked.

24   Q    Do you recall if, on behalf of the legion, you ever

25   authorized any settlement — let me back up.  Do you recall



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   if there was ever any litigation in Switzerland regarding the

 2   bequest in Ms. Farrell’s will?

 3   A    I never did see a will.  I don't know.

 4   Q    Or her estate.  Are you aware of any litigation?

 5   A    No.

 6   Q    Did you ever sign any documents approving a settlement

 7   from her estate?

 8   A    Not that I remember.

 9            MS. MOUSER:  What about you, Mr. Furr?  Do you

10   recall any discussion regarding litigation over Ms. Farrell's

11   estate?

12            MR. FURR:  I don't recall any.

13            MS. MOUSER:  Do you recall signing any documents in

14   regard to her estate settlement or otherwise?

15            MR. FURR:  I don't recall any.  I think Mr. Carto

16   said at one time that he was talking about what it was going

17   to cost to hire lawyers, that he would have to have over

18   there to get through with everything.

19            MS. MOUSER:  Right.

20            MR. FURR:  And I don't know what that was --

21            MS. MOUSER:  Whether it was litigation or not?

22            MR. FURR:  Yeah.

23            MS. MOUSER:  And what were basically — I mean, do

24   you know, did he ever hire any lawyers?

25            MR. FURR:  It’s my understanding he did.



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1            MS. MOUSER:  Now, why would he have been having

 2   those discussions with you?  Were you a director at the time?

 3            MR. FURR:  I was a director, but, I mean, this was

 4   not a conversation, really.  Not as a business session.

 5            MS. MOUSER:  Yes, sir.

 6   Q    (By Ms. Mouser)  Now, what do you know, Mrs. Furr, about

 7   the International Legion for the Survival of Freedom?

 8   A    That was what he, Mr. Carto, set up for the legion.  He

 9   had to give it some kind of a name.

10   Q    And what is your understanding of what the purpose of

11   that corporation was?

12   A    That, I guess, some of the money would go to — you

13   know, to the legion.

14   Q    To the international legion or to the legion?

15   A    To the legion.  But it was — had to be set up.  I don't

16   understand all of that.  I just know, you know --

17   Q    You just know what Mr. Carto told you?

18   A    That’s right.

19   Q    So what did he tell you about that?

20   A    I don't remember.

21            MS. MOUSER:  Do you remember anything about the

22   international legion, Mr. Furr?

23            MR. FURR:  No.  I have heard of it, but I don't know

24   anything about their purposes or anything else.

25   Q    (By Ms. Mouser)  Do you know anything, Mrs. Furr, about



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   a corporation called VIBET, V-I-B-E-T, Incorporated?

 2   A    That was part — I understood was part of the

 3   international.

 4   Q    And what did you understand that corporation was

 5   supposed to do?

 6   A    I don't even know what that was.

 7            MS. MOUSER:  What about you, Mr. Furr?  Do you know

 8   anything about VIBET, V-I-B-E-T, Incorporated?

 9            MR. FURR:  I've heard of it, but I don't know

10   anything about it.

11   Q    (By Ms. Mouser)  Is it accurate to say, Mrs. Furr, that

12   basically Mr. Carto handled all of the matters and issues

13   regarding the Farrell estate?

14   A    That’s correct.

15   Q    And if he set up corporations, those were his decisions?

16   A    Correct.

17            MS. MOUSER:  Is that your understanding, Mr. Furr?

18            MR. FURR:  Correct.

19   Q    (By Ms. Mouser)  In regard to where any, any, a penny of

20   the estate of Ms. Farrell went, do you know today where any

21   of that money went?

22   A    No.  The only thing I remember is part of my back pay, I

23   got a $5,000 check out of the Swiss bank.

24   Q    Now, would that have been from the legion or would that

25   have been --



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 1   A    It was — I don't know.  It was just a — it was just a

 2   check.

 3   Q    Well, I know the guy — Mr. Touchstone left you owing

 4   money.  Who — was it — I mean, obviously, it would have

 5   been legion or American Mercury because you hadn't worked for

 6   any of these other corporations.  Right?

 7   A    The back pay, when I left --

 8   Q    The legion?

 9   A    The legion.

10        — on December the 1st — or the first of every month, I

11   was to get $100 to help pay for the expenses for --

12   Q    Oh, that’s right.

13   A    So, I mean, that’s where --

14   Q    That’s right.  '79 to '93?

15   A    They had not paid anything.  And they still owe me money

16   because the $5,000 didn't cover it.

17   Q    Yeah.  That $100 was like from November of '79 to '93.

18   Right?

19   A    But it didn't cover it all.

20   Q    Yes, ma'am.

21   A    That’s the only thing that I know that where any money

22   went.

23   Q    You never signed any other checks?

24   A    I never signed — I've never signed --

25   Q    You never endorsed any of the checks?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    Never endorsed nothing.  I haven't seen anything out

 2   there.

 3            MS. MOUSER:  What about you, Mr. Furr?  Other than

 4   the $5,000 to Mrs. Furr, do you know where any of the other

 5   money went?

 6            MR. FURR:  No.  Don't have no idea, except what I

 7   read in the Spotlight something about it.

 8            MS. MOUSER:  What have you read in the Spotlight?

 9            MR. FURR:  That the IHR outfit got $750,000.

10            MS. MOUSER:  Now, let’s see.  IHR is a part of the

11   legion, and the Spotlight is --

12            MR. FURR:  Part of Liberty Lobby.

13            MS. MOUSER:  And so Liberty Lobby has alleged that

14   IHR got 750.

15            MR. FURR:  Yeah.

16            MS. MOUSER:  But you don't know that, do you?

17            MR. FURR:  No.  Not to my knowledge.  I don't know.

18   And I think in — I read in somebody’s deposition — I don't

19   remember even who.  There’s been so much of that.

20            MS. MOUSER:  Yeah.  There’s been a lot.

21   Q    (By Ms. Mouser)  Today looking back, since Ms. Farrell

22   died — I think we said she died in '85?

23   A    '85.

24   Q    Close to when your mom died.

25        Looking back and putting together your years with



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Mr. Carto, do you feel that Mr. Carto handled the money the

 2   way he said he was going to, Mrs. Furr?

 3   A    I feel like he has.

 4   Q    And what do you base that on, since you don't know what

 5   happened to the money?

 6   A    I just — Mr. Carto has always said, not only just to

 7   me, but he does what he’s going to say — you know, what he

 8   says he’s going to do.  And everybody — I mean, there’s a

 9   lot of people that — you know, that think a lot of him.

10   Q    And if your understanding is correct, that it was left

11   to him individually anyway, it was kind of up to him

12   regardless of what anybody else felt, huh?

13   A    That’s how I feel.

14   Q    Yeah.

15   A    I told you my story, and that’s exactly, you know, I

16   feel like what he’s going through.

17            MS. MOUSER:  Mr. Furr, do you have any reason to

18   doubt that Mr. Carto handled the money, whatever amount it

19   was — handled it honestly from the Farrell estate?

20            MR. FURR:  I believe it did.

21   Q    (By Ms. Mouser)  Do you recall, Mrs. Furr, there ever

22   being any discussions regarding raw gems in the estate?

23   A    Yes.

24   Q    What discussions do you recall about that?

25   A    From Mrs. Carto, they — she said it was not really



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   gems.  There was eight gold coins and some jewelry.  She

 2   didn't call them gems.  And it’s in the — because I don't

 3   know whether you've seen it or not, but it was in the Hot

 4   Springs paper, our headlines, Local couple in --

 5              MRS. FURR:  What was the title, Lewis?

 6   A    It’s ridiculous.

 7   Q    (By Ms. Mouser)  Now, I hadn't seen that.

 8   A    It’s sometime --

 9   Q    This has been related to the jewelry?

10   A    Yes.

11            MR. FURR:  They said we — we were involved with a

12   California case in which thousands of dollars, millions of

13   dollars worth of gems and jewelry and diamonds were missing.

14            MS. MOUSER:  This must have been when the judgment

15   was recorded.

16            MR. FURR:  Before that.

17            MS. MOUSER:  Yeah.

18            MRS. FURR:  It was before that.

19            MS. MOUSER:  I'm sorry about that.

20   Q    (By Ms. Mouser)  Well, regardless of what the newspaper

21   said --

22   A    And — well, anyway --

23   Q    — you were going to tell me what Mrs. Carto said.

24   A    Mrs. Carto and I, when I told her about the paper and

25   clipped it, she says, It’s in the judge’s mail.  He knows



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 127



 1   exactly that the lawyer wanted more money and he — it’s in

 2   his case that the lawyer, instead of money, got the — got

 3   it.

 4   Q    Okay.  Let me back up.  In the California matter in

 5   which Judge Maino, M-a-i-n-o, presided, there was a finding

 6   that one of the Swiss lawyers got the jewelry?

 7   A    I don't know whether it was a Swiss lawyer.  A lawyer.

 8   Q    Or some lawyer involved in the estate --

 9   A    Right.

10   Q    — proceeding?  Not someone here in --

11   A    He wanted more money, and Mr. Carto — I guess

12   Mrs. Carto saw them.  I do not know that.  And when I told

13   her what happened, she says, It’s — she said, It’s already

14   been — it’s in his court proceedings that the lawyer over

15   there got them.

16   Q    Have you ever visited in Mr. Carto’s home in California?

17   A    Yes.

18   Q    How would you describe that home?

19   A    It’s a California house with a view.  You have to go

20   through the kitchen — I mean, the dining room to get to the

21   other part of the house.  It’s just — well, my daughter

22   lives in a better house than it.  I mean, it’s just a

23   two-bedroom.

24   Q    It’s a smaller home?

25   A    It’s a small home.  It’s — you know, to me it’s not



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   even fancy like everybody's.  It’s not an estate.  It’s just

 2   a house.

 3   Q    What about any other home that they may own that you

 4   know of?

 5   A    I don't know that they own anything.

 6            MS. MOUSER:  Mr. Furr, have you ever been in any

 7   home of the Cartos other than the one in California?

 8            MR. FURR:  As far as I know, that’s the only one

 9   they have.  It used to have an avocado grove around it, but

10   all their trees died.

11   A    It has a pretty view, but I mean, it’s just a — you

12   know, like California, it’s spread — spread out.

13   Q    (By Ms. Mouser)  Yes, ma'am.  Sort of a spread-out home.

14   A    And the dining room was just big enough for the table,

15   and you walk — it’s like a hallway; you walk into the living

16   room.  And two bedrooms down the hall.

17   Q    So what you could tell of the way Elisabeth and Willis

18   Carto lived, they did not have a lavish lifestyle?

19   A    No, ma'am.

20            MR. FURR:  He’s tight as bark on a tree.

21   A    He still has an orange or an apple crate with an old,

22   old typewriter on it.

23   Q    (By Ms. Mouser)  What about Miss Elisabeth and

24   traveling?  Does she travel a lot?

25   A    No.  She’s traveling a little bit more now.



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Q    So if she vacationed with Ms. Farrell in Europe, that

 2   was an unusual event?

 3   A    Mrs. Carto’s mother lived in Germany, and about every

 4   three years — and I understand that Elizabeth’s mother would

 5   send her some money to come over.  Because Mr. Carto didn't

 6   want her to go no place.  She was a good cook and she’s a

 7   good housekeeper.  She’s very clean and dresses very, very

 8   modestly.

 9            MS. MOUSER:  What about you, Mr. Furr?  Would you

10   have that same opinion about the Cartos' lifestyle?  Are they

11   lavish people?

12            MR. FURR:  No way.

13   A    They don't go to shows.  They don't go to any — having

14   no children — where we like basketball, baseball, and music

15   lessons --

16   Q    (By Ms. Mouser)  They didn't do any of all that, did

17   they?

18   A    Once in awhile — we was living in California.  We

19   finally talked them into going to the Hollywood parade, the

20   Rose Bowl parade.  They never had been.  And they just didn't

21   go.

22   Q    Did you ever get the feeling that Mr. Carto did a lot

23   lobbying or were — did he hire other people to do the

24   lobbying?

25   A    I think the staff.  There were people on his staff there



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   that did that.

 2   Q    Did you ever get a feel for how many people were on his

 3   staff --

 4   A    No.

 5   Q    — or the staff of the Liberty Lobby?

 6   A    No.

 7   Q    Were you ever in the offices of Liberty Lobby in D. C.?

 8   A    I was there twice, once for a convention.  In 1976 they

 9   had a convention, and I stayed at the hotel.

10   Q    When you say they, you mean Liberty Lobby did?

11   A    Liberty Lobby had a --

12   Q    Any feel for how many people were working in that office

13   then?

14   A    No.  I never --

15   Q    Was there another time you were in the office other than

16   '76?

17   A    Just briefly.

18   Q    And any feel for the number of people working in the

19   office?

20   A    No.

21   Q    Did you see anybody working in the office?

22   A    Oh, yes.

23   Q    Maybe less than a dozen?

24   A    There was three floors.

25   Q    The whole building is three floors?



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    Uh-huh.  It’s old.  It’s a rat trap.  It’s real old.

 2   Q    Down D. C. maybe?

 3   A    It’s just a little way from the Capitol.

 4            MR. FURR:  Across the street from the Library of

 5   Congress there.

 6   Q    (By Ms. Mouser)  Did you ever learn how Mr. Carto got in

 7   the lobby business?

 8   A    No.

 9            MS. MOUSER:  What about you, Mr. Furr?  Did he ever

10   share that with you?

11            MR. FURR:  No.

12   Q    (By Ms. Mouser)  Do you know anything about his

13   educational background, Mrs. Furr?

14   A    No.  I think he started out to be a lawyer.

15   Q    Then got wise.

16        Now — and, obviously, we think sitting here today, the

17   appeal is dismissed.  But at one time, you and Mr. Carto had

18   sued Andrew Allen, Friedrick Burg, and John Curry.  What --

19   just briefly and generally speaking, what had those three men

20   done, in your opinion, to harm — I'm assuming you did it

21   because they harmed the legion and maybe you individually as

22   well.  But let’s start with the legion.  Did you feel they

23   harmed the legion?

24   A    They were just the ones who took over the directorship.

25   Q    How practically did that happen?  I mean, it was out in



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   California?

 2   A    Yeah.

 3   Q    And Tom Marcellus, when you left, was basically going to

 4   run it, you know, with the board of directors?

 5   A    He disappointed these people.

 6   Q    Mr. Marcellus did?

 7   A    Yes.  I don't know how he did it.  He just plain took

 8   over.

 9   Q    And what did Mr. Carto say about that?

10   A    Naturally, he was upset.

11   Q    Well, more than being upset, I mean, did he do anything

12   about it?  Because Marcellus didn't leave until '95.

13   A    They locked him out at gunpoint.

14   Q    They locked Mr. Carto out at gunpoint?

15   A    Right.  They pulled a gun on --

16   Q    These three guys?  Allen, Burg, and Curry or maybe

17   just --

18   A    No.  Just --

19            MR. FURR:  Marcellus and Greg Raven.

20   A    — Marcellus, Greg Raven.  Our former lawyer stood right

21   there --

22   Q    (By Ms. Mouser)  Now, who would that be?  Not

23   Mr. Singleton?

24   A    Hulsey.

25            MR. FURR:  William Hulsey.



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Q    (By Ms. Mouser)  H-u-l-s-e-y?

 2   A    Right.

 3   Q    Now, when you say our former lawyer, you mean the

 4   legion’s former lawyer?

 5   A    They had a case — he had handled a case.

 6   Q    For the legion?

 7   A    For the legion.  So he had a conflict of interest.

 8   Q    So Raven, Hulsey.  And who --

 9   A    Greg Raven, Tom Marcellus --

10   Q     Marcellus?

11   A    — and Hulsey.

12            MR. FURR:  Yeah.  And Marcellus.

13   Q    (By Ms. Mouser)  And so was Mr. Allen, was he ever out

14   in California?

15   A    He was a lawyer in San Francisco, as far as I know.

16   I've never met him.

17   Q    And what about Mr. Burg?  Was he ever employed or --

18   A    No, no.

19   Q    And what about Mr. Curry?

20   A    Never.

21   Q    They were just — alleged they were directors?

22   A    Right.

23   Q    And did Marcellus and Hulsey and Raven put them into

24   those positions or how did you understand that happened?

25   A    I understand that Mr. Carto went to the office and they



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   locked him out.  And I guess Mr. Carto and Elisabeth were

 2   trying to get in, and they beat up Mr. Carto real bad.  I

 3   mean, they had — they both dropped criminal charges, Mr. and

 4   Mrs. Carto and also Hulsey and Greg Raven.

 5   Q    What do you know about Greg Raven’s background,

 6   educational or otherwise?

 7   A    Nothing.  I never met him.

 8   Q    And did I already ask you if you know anything about Tom

 9   Marcellus' educational background?

10   A    I did not know --

11   Q    Now, you interviewed him.

12   A    Yes.

13   Q    Do you recall when you interviewed him what he said his

14   educational background was or work experience?

15   A    No, I don't.

16   Q    But initially, you were comfortable with him, whatever

17   he told you?

18   A    Yes.

19   Q    Yeah.

20   A    I'm easy to get along with.

21   Q    Well, yeah.  I mean, anybody could be fooled.

22   A    He had a good personality to meet the public.

23   Q    Was he college educated?  Do you remember?

24   A    I don't remember that.

25   Q    Had he had experience in publishing?



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    I do not know that.

 2   Q    Did you feel at the time that Allen, Burg, or Curry, or

 3   any combination of those three, had harmed you personally?

 4   A    No.

 5            MS. MOUSER:  And I don't think, Mr. Furr — I don't

 6   think you were a party.  That was just the incorporators.

 7            MR. FURR:  Incorporators.

 8            MS. MOUSER:  Yes, sir.

 9   Q    (By Ms. Mouser)  I think I asked you this, this morning,

10   but I have forgotten.  And I apologize.  Why did you revoke

11   your resignation as a board member?

12   A    Because of the letters, the threatening letters that Tom

13   — and the telephone calls that Tom Marcellus and Weber --

14   Q    I understand that’s why you resigned.

15   A    I couldn't take it.  I was --

16   Q    Why did you revoke that resignation?

17   A    Like that — Willis — we found out that all what Tom

18   Marcellus was saying was not true.

19   Q    Oh, that’s right.  You told me that.

20            MS. MOUSER:  And would that be — the same be true

21   of you, Mr. Furr?

22            MR. FURR:  Yes.

23   Q    (By Ms. Mouser)  Now, since, Mrs. Furr, you revoked your

24   resignation, have you taken any action as a director since

25   that time?



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    We had some meetings and Kenneth Graham with Howard

 2   Singleton because the Texas suit had not been — well, I

 3   hadn't even given a deposition yet.  He said we had to

 4   proceed under the Texas law --

 5   Q    Yes, ma'am.

 6   A    — and have a corporate meeting until things further --

 7   to keep up the status, whatever is required of a nonprofit

 8   organization.  I don't understand all that either.

 9   Q    Sure.

10   A    But I --

11   Q    Other than those meetings, did you — have you done

12   anything else --

13   A    No.

14   Q    — in your opinion, as a director?

15   A    No.

16   Q    And this would be since sometime right after September

17   of '93.  And I think you revoked, you said, a few weeks after

18   September 16th.

19   A    Right.  And I think that meeting in Mr. Graham’s office

20   with Mr. Singleton, under their advice, Lewis had just got

21   his — he had broken his ankle, and it was August.  It was

22   the first time down there.  Everybody was in a suit.  Lewis

23   was in his tennis shoes because — and so it was around

24   August the 4th or 5th.

25   Q    He thought he still lived in California, see?



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    Yeah.

 2            MR. FURR:  Uh-huh.

 3            MS. MOUSER:  Mr. Furr, did you — since the

 4   revocation of your resignation and that meeting in

 5   Mr. Graham’s office — or Mr. Singleton’s office, have you

 6   taken any other actions, in your opinion, as a director of

 7   the legion?

 8            MR. FURR:  Not that I recall.

 9            MS. MOUSER:  Do you feel sitting here today,

10   Mr. Furr, that you continue to be a director of the legion?

11            MR. FURR:  I'm really not sure.

12            MS. MOUSER:  Okay.  What do you feel --

13            MR. FURR:  This thing is so involved, I'm not sure.

14   Q    (By Ms. Mouser)  What do you feel, Mrs. Furr?

15   A    I don't know.  Until, I guess, it’s settled, I feel like

16   I'm not and maybe — I don't know.

17   Q    Do you still subscribe to the legion’s publications?

18   A    No.  I never have.  I don't even read the Spotlight.

19   I'm interested in something else.  I don't — there’s too

20   much bad news without reading all that garbage stuff from

21   Washington, D.C.  You can only take so much, and I've got

22   high blood pressure.  And there’s no sense in --

23   Q    Have you ever been an incorporator of any other

24   corporation that you can recall?

25   A    No.



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Q    Have you ever been a director of any other corporation

 2   other than the legion?

 3   A    No.

 4   Q    Or American Mercury?

 5   A    I was — I was president of the garden club one time,

 6   but that was it.

 7   Q    That was probably a lot more pleasant experience, I

 8   hope.

 9   A    But that’s not a — that’s just a local.

10   Q    Yes, ma'am.

11   A    I don't know what you mean by --

12   Q    Just any other corporation?

13   A    No.

14            MS. MOUSER:  What about you, Mr. Furr?  Have you

15   ever been an incorporator of any corporation?

16            MR. FURR:  No.

17            MS. MOUSER:  And have you ever been a member on any

18   board of a corporation, other than the legion?

19            MR. FURR:  No.

20   Q    (By Ms. Mouser)  Do you recall, Mrs. Furr, either when

21   you were volunteering or when you were partially paid, I'm

22   going to say, because I don't know that you ever got paid

23   enough for your work — did you ever see any financial

24   statements that the legion had prepared or were prepared by

25   someone internally at the legion?



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    They had a bookkeeper.  I had a bookkeeper.

 2   Q    Did she ever — when I say financial statement, I really

 3   mean like a list of assets and liabilities.

 4            MRS. FURR:  The franchise tax.  Is that — that's

 5   not a --

 6            MR. FURR:  The only financial statement would be the

 7   one that the CPA prepared to be filed with the state

 8   franchise tax board.

 9   Q    (By Ms. Mouser)  And that would be in the State of Texas

10   where the corporation was incorporated?

11   A    Also Sacramento.

12   Q    And the state law in both of those states required like

13   a list of assets and liabilities to go with the franchise tax

14   report?

15   A    I don't --

16            MR. FURR:  Right.

17            MS. MOUSER:  That would make sense because that

18   would be what they would look at to determine how much

19   franchise tax you were to pay.

20            MR. FURR:  Yeah.

21            MS. MOUSER:  Do you recall --

22            MR. FURR:  The nonprofit corporation didn't pay any

23   — I think a $10 filing fee or something like that.

24   A    No.  Texas wasn't anything.  I had to send a $5 check to

25   Sacramento.  I believe that’s --



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Q    (By Ms. Mouser)  Because it was a nonprofit.  Do you

 2   recall if the legion had to file an excise tax report in

 3   either state or was it just franchise?

 4            MR. FURR:  Franchise.

 5   A    It was franchise.

 6   Q    (By Ms. Mouser)  Now, Mrs. Furr, sometimes I think --

 7   several times I've seen your name signed as secretary.  Does

 8   that sound familiar to you?

 9   A    Yes.

10   Q    Now, to the extent that you would sign any form, like a

11   franchise tax form, did someone else prepare that?

12   A    Yes.

13   Q    Any then you signed it as secretary?

14   A    Right.  Secretary or treasurer.  Sometimes — I don't

15   know.

16   Q    Sure.

17   A    Sometimes --

18   Q    Is it safe to say — and certainly I don't want to

19   impute your intelligence — but you signed it and hoped that

20   the people who prepared it did it correctly?

21   A    Right.

22   Q    Because you would have no independent knowledge about

23   franchise taxes and the franchise laws, et cetera, tax laws

24   size tax.

25   A    I didn't even make out the W-2 forms.



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Q    Do you recall when you last signed one of those, what

 2   year it was?

 3   A    1993 in June just before --

 4   Q    And why would you — would that have been like for '92?

 5   A    I guess.

 6   Q    Why would you have not signed any since then?

 7   A    Nothing has been sent to me.

 8   Q    So if they've been filed, you don't know who’s doing it?

 9   A    I don't know who’s filed it.

10            MS. MOUSER:  Did you ever sign, Mr. Furr, any of

11   those franchise tax reports or anything like — not anything.

12   Just any franchise reports?

13            MR. FURR:  I don't recall any.

14            MS. MOUSER:  I don't remember seeing any either.

15   A    Now, I knew it was correct when I was there because I

16   helped the bookkeeper do all that.

17   Q    (By Ms. Mouser)  Was that a man or a woman?  Do you

18   remember?

19   A    Robert Fenchel.

20   Q    I'm sorry?

21   A    Robert Fenchel.

22   Q    How do you spell that last name?

23            MR. FURR:  F-e-n-c-h-e-l.

24   Q    (By Ms. Mouser)  And was he actually like a regular

25   employee or did he just --



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    No.

 2   Q    — come on board to do that?

 3   A    He was a professional CPA or whatever.

 4   Q    He wasn't an employee?

 5   A    No.

 6   Q    He just did that for the legion.  Or maybe — was it

 7   filed under the legion’s name or American Mercury’s name?  Do

 8   you remember?  I bet it was legion because I think legion was

 9   the corporation.

10   A    Right.  I think so.

11   Q    Has Mr. or Mrs. Carto ever been to your home here in Hot

12   Springs?

13   A    Mr. Carto has.

14   Q    And when was that?

15   A    He was on his — right after my father died.

16   Q    And did he come basically to see you due to your dad's

17   death?

18   A    No.  No.  He just wanted to see where we would live, I

19   guess.

20   Q    How long did he stay?

21   A    A day and a half.

22            MS. MOUSER:  Were you there, Mr. Furr?

23            MR. FURR:  Yes.

24   Q    (By Ms. Mouser)  Did you-all discuss anything about the

25   business?  What year was that, Mrs. Furr?  '92?



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    No.  '93.

 2   Q    '93.

 3        Did you discuss anything about the business aspects of

 4   the legion, not the philosophy or the --

 5   A    We probably did, but it was not much because he wasn't

 6   there long.

 7   Q    Did you talk about the Farrell estate money at all?

 8   A    No.

 9            MS. MOUSER:  What about you, Mr. Furr?  Did you have

10   any discussions with Mr. Carto at that time about the Farrell

11   estate?

12            MR. FURR:  No.

13   Q    (By Ms. Mouser)  Now, there were millions of dollars, we

14   thought, involved in the Farrell estate, and you didn't think

15   to ask him about where any of that money went, Mrs. Furr?

16   A    No.

17            MS. MOUSER:  Neither you, Mr. Furr?

18            MR. FURR:  No.

19   Q    (By Ms. Mouser)  And if less than a million went to the

20   legion, do you have any concern about where the other money

21   is, Mrs. Furr?

22   A    No, I don't.

23   Q    And why is that?

24   A    Well, I feel like it’s his money, and I don't ask --

25   like I wouldn't ask you or whatever.  And my disconcernment



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   — after my mother died, my father came to live with me.  He

 2   was a basket case until he died in '93.  I took care of him.

 3   And Lewis had — his sister died in '91.  Lewis had major

 4   cancer.  My mind has never been — I mean, that’s why some of

 5   it is so bad.  I just didn't care.

 6   Q    That’s a lot of trauma to go through in a short period

 7   of time.

 8   A    We lost nine people in less than seven years.  And one

 9   was my dad and one was his sister.

10   Q    And then, of course --

11   A    And I just — so whatever he said, I did.  I mean, I --

12   that’s why I just — I just don't remember.  I had too much.

13   Q    Has Elisabeth Carto ever been in your home here in Hot

14   Springs?

15   A    No.

16   Q    I think when you filed bankruptcy, you listed the lot in

17   Texas as your homestead.  Do you — is that lot --

18   A    Not a homestead.  It’s a vacant --

19   Q    A vacant lot?

20   A    — unimproved lot.

21   Q    Is it like in a subdivision or a retirement division?

22            MR. FURR:  It was supposed to — was supposed to be

23   developed as one of these --

24            MS. MOUSER:  Resort communities?

25            MR. FURR:  Yeah.



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1            MRS. FURR:  Yeah.

 2            MR. FURR:  One of these things where you --

 3            MS. MOUSER:  Like Fairfield Bay.

 4            MR. FURR:  — swap out.  You stay there at my place

 5   a while and I'll --

 6            MS. MOUSER:  Yeah.  Time shares.

 7            MR. HONEY:  Time shares.

 8            MS. MOUSER:  Time shares.

 9            MR. FURR:  Time shares.

10   Q    (By Ms. Mouser)  And it was never developed?

11   A    Never.  We've quit paying on it.

12   Q    Yeah.  I've got a lot — my family has a lot very

13   similar to that.

14   A    I don't know why we bought it.

15   Q    Yeah.  Well, thank goodness we don't have to explain

16   everything.

17   A    It’s probably even gone for taxes because they didn't

18   live up to what they were doing.

19   Q    Sure.

20   A    We had to pay $22 --

21   Q    We never even get utilities to the lot?

22   A    Oh, no.

23   Q    We never even got utilities to ours.

24   A    That’s why we quit because $22 dollars a month, beside

25   the cost of the lot, was supposed to go to improvements.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Q    Right.

 2   A    And the last time we were there, we couldn't even find

 3   the lot, and nobody knew where it was at.  So we just quit

 4   paying.  And I got a call last week and they said, When are

 5   you going to make a payment?  I said no.  I says, We can't

 6   afford it.  This is — you know, and they quit calling.  I

 7   don't know whether they are going to put it up for taxes or

 8   not.

 9            MR. FURR:  I got a tax notice — bill from the tax

10   collector, and I don't think I've paid it in two years.  I

11   don't know whether they even — I don't think they even sell

12   it at the sheriff’s sale.

13            MS. MOUSER:  Right.

14   Q    (By Ms. Mouser)  Tell me who is or who was Courtney

15   Smith, Mrs. Furr.

16   A    He sells --

17   Q    Oh, it’s a man, mister.

18   A    Mr. Furr — Mr. Smith.

19        — for Independence Trust, revokable and irrevocable.

20   Q    Is Independence Trust a business?

21   A    That’s his business.

22   Q    That’s his business.  And you had evidently some type of

23   partnership with him at one time?

24   A    No.  A partnership with his wife and --

25   Q    What was her name?



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    Jean Smith.

 2   Q    And when was that?

 3   A    Just '81 and '82, I think.

 4   Q    And what was basically the partnership you had with Jean

 5   Smith?

 6   A    She and I — that was all his idea.  And we hired him,

 7   and I just did the typing.  He wrote up all the — he had a

 8   manual that Dr. Larson put out.

 9   Q    A manual about what, now?

10   A    Taxes — trusts, I mean.  Not taxes.  And we bought the

11   manual from him.  And he sold it to people, and he helped,

12   which he still does, set up your own trust.

13   Q    And your involvement was what, now?

14   A    I was — did the packaging.

15   Q    And was --

16   A    And the typing.

17   Q    Yes, ma'am.  Was there a separate business name that you

18   and Mrs. Smith used?

19   A    No.  Not that I know of.  It was just --

20   Q    How was there a tax liability resulting from your

21   partnership with Mrs. Smith?  Tell me about that.

22   A    The tax liability?

23   Q    Yes, ma'am.

24   A    It was on paper only.  He filled out the income tax or

25   he had someone do it.  And the taxes — the IRS came back and



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   said they disallowed the $25 royalty that we had to pay

 2   Dr. Larson.  They disallowed the advertisement, and there was

 3   some other stuff they disallowed.  It ended up that I owed

 4   $6,000 more to the IRS, and she owed $6,000 more to the IRS.

 5   Q    Was that because you-all were partners in this

 6   partnership?

 7   A    Right.

 8   Q    Now, what was the name of the partnership?

 9   A    Independence Trust.

10   Q    But I thought you said that that was the name of

11   Mr. Smith’s business.

12   A    Well, it was, but then he — he worked for Independence

13   Trust.

14   Q    Was it a corporation or a partnership?

15   A    No.  No.  It was just a piece of paper that we're — and

16   he says if we make any money, I got $5 an hour.  And I worked

17   maybe three days a week or something like that.

18   Q    So the reason why it got up to almost --

19   A    He said, I'll take care of it.  Don't worry.  And I'll

20   explain it.  And we went to court, and it got up and up and

21   up.  And finally, it got up to 27,000.  And after we moved up

22   here, we tried to contact the IRS.  They wouldn't answer.  We

23   wrote.  And finally, it has — I think it got up --

24            MRS. FURR:  What was the last figure?

25            MR. FURR:  26,000 and something dollars.



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Q    (By Ms. Mouser)  And that was really the main — or let

 2   me ask.  Was that the main reason why the bankruptcy was

 3   filed?

 4   A    That’s right.  We couldn't pay it.  We couldn't get no

 5   cooperation.

 6   Q    What state was the Independence Trust in?  Was that

 7   Texas?

 8   A    Louisiana.

 9   Q    Louisiana.

10        Now, you also listed in your bankruptcy schedules a debt

11   to a fellow Donald E. — and then is it Boehlje?

12   A    Boehlje, my cousin.

13   Q    B-o-e-h-l-j-e.  He’s your cousin.  Now, what did he loan

14   you money for?

15   A    We were improving the house.

16   Q    Here in Hot Springs?

17   A    Yes.

18   Q    And is that what you used that money for?

19   A    Right.  Probably some other bills too.  Doctor bills or

20   whatever.

21            MS. MOUSER:  Mr. Furr, through your serving as clerk

22   of the court, did you — I think it was 12 years.  Did you

23   get any retirement benefits during that time?

24            MR. FURR:  They hadn't set up a retirement system

25   when I was there.



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 1            MS. MOUSER:  They had not?

 2            MR. FURR:  Had not.  I think it just started just

 3   before I got out of there, and you have to contribute

 4   something like 10 percent of you salary.  And I wasn't

 5   getting enough salary to give anyway.

 6            MS. MOUSER:  Okay.  On your bankruptcy schedules, as

 7   I recall — and I've got a copy; Mr. Honey may as well — you

 8   listed some income under interest and dividends, Mr. Furr.

 9   What would that have been?

10            MR. HONEY:  She’s referring to a schedule of your

11   bankruptcy petition, if you could find it there.  It’s in

12   alphabetical order.  Schedule 5.

13            MR. FURR:  I've got it right here.

14            MR. HONEY:  I believe she’s referring to this $139

15   in interest or dividend.

16            MS. MOUSER:  Do you recall what that would have been

17   from?  This is back in '93.

18            MR. FURR:  It may be interest — the only interest

19   that would be drawing would be on a bank account.

20            MS. MOUSER:  Your schedules don't show that you had

21   a bank account in 1993.  Do you know if that’s --

22            MR. FURR:  I had one, but I don't know --

23            MS. MOUSER:  Do you remember where it was?

24            MR. FURR:  I think it was in the — Horizon Bank at

25   that time.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1            MS. MOUSER:  So if that’s not on your schedules,

 2   that’s just an oversight on your part, isn't it?

 3            MR. FURR:  Yes.

 4            MS. MOUSER:  That 139 would be the interest off that

 5   account?

 6            MRS. FURR:  What are the three checks you get?

 7            MR. FURR:  I get a dividend check every month.

 8            MS. MOUSER:  Who is that from?  Do you recall?

 9            MR. HONEY:  Is it listed back here?

10            MR. FURR:  United Pacific.

11            MS. MOUSER:  Does that have something to do with an

12   insurance policy?

13            MR. FURR:  No.

14            MS. MOUSER:  No?  What is that?

15            MR. FURR:  That’s retirement from the place where I

16   used to work.

17            MS. MOUSER:  In California maybe?

18            MR. FURR:  I get two of them.  One is from

19   California and one from Louisiana, but I don't know which is

20   which.

21            MS. MOUSER:  But, of course, you each get Social

22   Security.  Okay.

23            MR. FURR:  One of them pays me $26.91 a month and

24   the other one pays $112.10 a month.

25            MS. MOUSER:  Okay.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1            MRS. FURR:  Big deal.

 2            MR. FURR:  And then I get a dividend check of $42 a

 3   year from somebody.

 4            MS. MOUSER:  And that annuity with United Pacific

 5   Life, that was through one of your previous employers.

 6   Right?

 7            MR. FURR:  Right.

 8            MS. MOUSER:  Yes, sir.  Southern National Bank,

 9   Mr. Furr, is that in Louisiana?

10            MR. FURR:  Yes.

11            MS. MOUSER:  And when the IRS levied on that

12   account, did that have to do with the Independence Trust

13   thing?

14            MR. FURR:  No.

15            MS. MOUSER:  What was that all about?

16            MR. FURR:  That was on our tax levy.  Yeah.  It

17   would be the Independence Trust thing, but I mean, it was a

18   result of the Independence Trust thing.

19            MS. MOUSER:  Right.  It wasn't a result of your

20   failure to file a tax return?

21            MR. FURR:  Oh, no.  No.

22   Q    (By Ms. Mouser)  Now, I think somewhere I read that one

23   of Ms. Farrell’s — well, I mean, obviously I don't know;

24   I've just read it — that Ms. Farrell had become very

25   disgruntled with the United States and IRS.  I think we can



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   all somewhat understand that, if that’s true.  Do you know

 2   anything about that, Mrs. Furr?

 3   A    I don't know.  I just read it in the Spotlight.

 4            MR. HONEY:  Well, there was some reference to that

 5   in that letter she just showed you a few minutes ago in

 6   general terms.

 7            MS. MOUSER:  Yeah.  Yeah.

 8   Q    (By Ms. Mouser)  But, once again, as I recall, you

 9   really don't know — you don't have any personal knowledge of

10   Ms. Farrell or any of her beliefs?

11   A    No.

12   Q    Or anything like that.

13            MS. MOUSER:  What about you?  Same with you,

14   Mr. Furr.  Right?

15            MR. FURR:  No.

16            MS. MOUSER:  Yeah.

17            MRS. FURR:  How can you when you don't know anybody?

18            MS. MOUSER:  Right.

19   Q    (By Ms. Mouser)  Let me hand you just — here.  I'm just

20   going to hand them kind of — these are my only copies,

21   Mrs. Furr — and ask you just to take a look at these and see

22   if you can recognize those.  And Mr. Honey would probably

23   want to look at those too.

24   A    Yeah.

25            MS. MOUSER:  Excuse me.  Can we go off the record



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   for just a moment.

 2              (AN OFF-THE-RECORD DISCUSSION WAS HELD.)

 3            MS. MOUSER:  Let’s go back on the record.

 4        And, I think, Ms. Miller, is, I'll inquire of these

 5   documents, and then if we feel it’s necessary to attach them

 6   as an exhibit, we'll do so.

 7        Mr. Honey, if you don't mind.

 8            MR. HONEY:  It’s up to you.  Sure.

 9            MS. MOUSER:  But these are the only copies I have,

10   so I'm going to briefly refresh my memory, Mrs. Furr and

11   Mr. Furr, as I hand them to you.

12   Q    (By Ms. Mouser)  Mrs. Furr, the first thing I'd like to

13   do is hand to you a document and ask if you can identify it.

14   And if you don't mind, I'm going to come over there and stand

15   beside you and look at those since that’s my only copy.  Do

16   you recognize that document?

17   A    Yes, I do.

18   Q    And what is that document that you recall?

19   A    Appointing power of attorney to John Henry Fischer.

20            MR. HONEY:  Why don't you identify it by date also

21   for the record.

22   A    The 6th day of 1985.

23   Q    (By Ms. Mouser)  Yeah.  The 6th day of November 1985?

24   A    Right.

25   Q    And it says it’s a power of attorney appointing



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Mr. Henry John Fischer as an attorney in fact for the legion?

 2   A    The Institute of Historical Review and the legion also.

 3   Q    Now, why would you have given Mr. Fisher a power of

 4   attorney for NECA Corporation?

 5   A    He was a friend.  I do not know.  He was a friend of

 6   Mr. Carto, and he spoke several languages.  And I guess Mr.

 7   Carto couldn't go over there.

 8   Q    I guess my question was, what authority did you have to

 9   sign anything for NECA Corporation, I guess was my question.

10   We discussed how you were an incorporator on the board of

11   legion, but how would you have had any authority to sign for

12   NECA?  And if you don't know, you just don't know.

13            MR. HONEY:  Tell her if you don't know.  Tell her

14   you don't know.

15   A    I don't know.

16   Q    (By Ms. Mouser)  Do you recall who prepared that

17   document for your signature?

18   A    Probably Mr. Carto.

19   Q    And then I think the other one is IHR.  And, of course,

20   that’s a part of legion, so that makes sense.

21   A    Right.

22   Q    Was this document executed in regard to the Farrell

23   estate that we've been talking about?

24   A    I believe so.

25            MS. MOUSER:  Let’s go ahead and let Ms. Miller mark



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 156



 1   that as Deposition Exhibit No. 1.

 2           (EXHIBIT NO. 1 WAS MARKED FOR IDENTIFICATION.)

 3            MS. MOUSER:  And let’s go ahead and mark that one as

 4   2.

 5           (EXHIBIT NO. 2 WAS MARKED FOR IDENTIFICATION.)

 6   Q    (By Ms. Mouser)  Let me hand to you what Ms. Miller has

 7   marked as Deposition Exhibit 2 and ask you if you recognize

 8   that document.

 9   A    Yes, I do.

10   Q    I guess I should go back and ask you, these are both

11   copies, aren't they, Mrs. Furr?  They're not originals.  They

12   don't appear to be originals to me.  Do they appear to be

13   originals to you, both Exhibit 1 and 2?  Those signatures

14   don't look like originals.  There are no raised seals that

15   you can tell?

16   A    I don't think these are originals.

17   Q    Yeah.  They don't seem to me either.  On Exhibit 1, back

18   on Exhibit 1, do you recognize that as your signature?

19   A    Oh, yes.  That’s my signature.

20   Q    What about on what we've marked as Deposition Exhibit

21   No. 2?  Once again, that appears to be a copy, doesn't it?

22   A    I believe it’s a copy.

23   Q    Does that appear to be your signature?

24   A    It is.

25   Q    And what is Deposition Exhibit 2?  What is that?



                          AMY MILLER, CCR-RPR
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 1   A    Power of attorney to Henry Fisher.

 2   Q    And it’s different from Exhibit 1, isn't it?   It’s not

 3   the same document, is it?

 4   A    No.  It’s not the same document.

 5   Q    I mean --

 6            MR. HONEY:  Give the date also.

 7   Q    (By Ms. Mouser)  Yeah.  Let’s go ahead and — what date?

 8   A    July 1991.  26th day of July 1991.

 9   Q    And not only is it not the same document, what I meant

10   to say, it’s not like — it’s not the same words on Exhibit

11   2.

12   A    Correct.

13   Q    What’s your understanding of what Exhibit 2 does?

14   A    To expedite Jean Farrell’s estate.

15   Q    Now, why — if the bequest out of her estate was to

16   Mr. Carto individually, why was the legion — why were you,

17   on behalf of the legion, giving anybody a power of attorney

18   regarding that estate?

19   A    Again, I have to answer I don't know.

20   Q    Who prepared that document?

21   A    Probably Mr. Carto.

22   Q    At the time — did he mail it to you?

23   A    I do not — well, he had to.  He wasn't --

24   Q    Because '91 — let’s see.  You-all were — well, July of

25   '91, were you-all in Hot Springs already?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1            MR. FURR:  No.

 2            MS. MOUSER:  No.  Louisiana.  Yes.  You're pointing

 3   to the notary obviously.

 4   Q    (By Ms. Mouser)  So he mailed it to you.  Do you recall

 5   any discussions you had with him in regard to that document?

 6   A    I know we discussed it, but I don't remember what was

 7   said.

 8   Q      I mean, do you recall ever asking him — do you call

 9   him Willis or Mr. Carto?

10   A    Willis.

11   Q    Did you ever say, Willis, why does the legion need to

12   sign anything if we're not a beneficiary of the estate?

13   A    I didn't ask any questions like that.

14   Q    Why not?

15   A    I don't know.

16   Q    During the whole course of the business relationship

17   with Mr. Carto, you never asked questions like that?

18   A    Not when it comes to legal stuff.  That’s not my cup of

19   tea.

20   Q    In reading that document today, do you see how someone

21   — it would be possible for someone to think that the legion

22   thought it was entitled to some money out of that estate and

23   you were giving Mr. Fisher authority to move forward on

24   behalf of the legion?  Do you see how someone could possibly

25   detect that from the language on that power of attorney?



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1            MR. HONEY:  Let me ask her not to speculate.  I

 2   don't know the answer — if you can answer it.  If not --

 3   A    I don't know.

 4   Q    (By Ms. Mouser)  Did you appear in front of a notary

 5   when you signed that?

 6   A    I certainly did.

 7   Q    Do you recall discussing either Exhibit 1 or 2 with

 8   Mr. Furr when you signed them?

 9   A    No.  Except I got to go in front of a notary.

10   Q    You had to go find a notary.  Okay.

11   A    He was at work.

12   Q    Mr. Furr was.

13            MS. MOUSER:  Let me ask Ms. Miller to mark this as

14   Deposition Exhibit No. 3, please.

15           (EXHIBIT NO. 3 WAS MARKED FOR IDENTIFICATION.)

16   Q    (By Ms. Mouser)  And then let me hand to you what we've

17   marked as Deposition Exhibit No. 3.  And once again, that

18   appears to be a copy of a document, not the original.  Does

19   that appear to be a copy to you?

20   A    It appears to be a copy.

21   Q    Yes, ma'am.  And does that appear to be your signature

22   on the document?

23   A    Yes.

24   Q    And what is the date of the document?

25   A    September the 16th, 1985.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Q    And basically, what does that document say?

 2   A    He will take --

 3            MR. HONEY:  Let me interrupt.  I don't think that's

 4   right.  I think the date you just referred to is just

 5   referenced in the --

 6            MRS. FURR:  Oh.

 7            MR. HONEY:  I think the date of the document is down

 8   here.  Doesn't that look like August the 2nd of '94?

 9            MRS. FURR:  It does, but --

10   Q    (By Ms. Miller)  Does it maybe reference another date of

11   a letter?

12   A    Oh.  This is an affidavit.

13   Q    Do you remember signing that?

14   A    Yes.  I — vaguely.

15   Q    And basically, what does that document say?

16   A    That a meeting of the directors of September the 19th,

17   1985, agreed that Willis would make contact for the legion

18   and he didn't — legion did not have the funds, and he — at

19   his own expense, he took on the project.

20   Q    And what project was that?

21   A    The Jean Farrell estate.

22   Q    Well, why would the legion agree to pay any expenses for

23   Mr. Carto to go pursue his own bequest from her estate?

24   A    Repeat that.

25   Q    If the legion wasn't to get anything except what



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   Mr. Carto chose to give it, why would the legion choose to

 2   pay Mr. Carto’s expenses to go pursue his own basic

 3   inheritance?  Why would the legion do that?

 4   A    I don't know.

 5   Q    Why would you personally commit the legion to do that?

 6   A    Because like I said before, it was under my impression

 7   that he was to do what he could and that the legion would get

 8   some of the money.

 9   Q    And did you ever discuss with him how much of the money?

10   A    No, I did not.  Because I didn't know how much he would

11   get.  I didn't know what was there to receive.

12   Q    Did you ever limit the amount of his expenses?

13   A    He was paying them.

14   Q    I mean, but the amount that the legion would reimburse

15   him?

16   A    No.

17   Q    So it was your understanding that if he went over there

18   and incurred half a million dollars of expenses,

19   theoretically, that the legion would repay him that even

20   though the legion didn't get any money from the estate?  I

21   mean, under your scenario, that could have happened, couldn't

22   it?

23   A    I don't know.

24   Q    Let me borrow that back for just a minute.  It says here

25   that you got a letter from Mr. Carto in which he stated he



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 162



 1   would personally take full responsibility for recovering the

 2   funds due the legion from the Jean Farrell estate.  Now, that

 3   says to me that you got a letter indicating that the estate

 4   actually left money to the legion.  The words “recovering the

 5   funds due the legion."

 6   A    I was under the impression not all of it was due the

 7   legion.

 8   Q    Were you under the impression that some of it was due to

 9   the legion?

10   A    I don't — I don't know.

11            MR. HONEY:  Let’s go off the record for just a

12   minute.

13              (AN OFF-THE-RECORD DISCUSSION WAS HELD.)

14   Q    (By Ms. Mouser)  Let me ask one other question.  If,

15   Mrs. Furr, the Farrell estate did leave money to the legion

16   and the legion never got it, other than Mr. Carto, who do you

17   think got the money?

18   A    I would think it belonged to Liberty Lobby or whoever

19   Willis chose to leave it to.

20   Q    Let me back up.  I know that it’s your understanding

21   that Mr. Carto was the beneficiary of the estate.  My

22   question is, if, in fact, the legion was a beneficiary for a

23   certain amount and a Swiss judge — there’s an order out

24   there that says, you know, I've looked at everything and the

25   legion should get X dollars and the legion never got it, who



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 163



 1   other than Mr. Carto could have gotten their hands on that

 2   money?  And I'm talking about initially from Switzerland.

 3            MR. HONEY:  And I want to caution you, Mrs. Furr,

 4   just to testify about, you know, what you know.  I mean,

 5   don't speculate about that because that’s an important issue.

 6   So tell her what you know from your --

 7   A    I don't know.

 8   Q    (By Ms. Mouser)  I mean, other than Mr. Carto, there was

 9   no one over there, to your knowledge, that was acting on

10   behalf of the legion, was there?  He was the only one, wasn't

11   he, that you knew of?

12   A    That I knew of.

13   Q    There could have been 20 other people over there, but as

14   far as you knew, he was the only one over there that really

15   had any connection to the legion; is that correct?

16   A    I don't know.

17   Q    And, in fact, you had given him the power of the

18   attorney as the secretary for the legion to act on the

19   legion’s behalf; is that correct?

20   A    Yes, I did.

21   Q    And if, in fact, the legion was left money and Mr. Carto

22   got it, you think it may have gone to some other entities;

23   Liberty Lobby, maybe International Legion for the Survival of

24   Freedom, some other organizations?

25   A    I trust Willis enough to know that whatever Jean



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 1   Farrell, since they were friends — I didn't know her — that

 2   he would do what she wanted.

 3   Q    Now, when you filed bankruptcy, Mrs. Furr, you were an

 4   officer of the legion.  Correct?

 5   A    Right.

 6   Q    And why did you not list that on your schedules?

 7   A    A bankruptcy?  It’s a nonprofit organization.  I had no

 8   money.  I mean, no money --

 9   Q    That’s fine.  That’s fine.  That’s all I needed.

10            MS. MOUSER:  Let’s go ahead and mark these each,

11   please, ma'am.  I think we're on 4.

12    (EXHIBITS NOS. 4 THROUGH 14 WERE MARKED FOR IDENTIFICATION.)

13              (AN OFF-THE-RECORD DISCUSSION WAS HELD.)

14             MS. MOUSER:  Mr. Furr, I think the other documents

15   that we're looking at — I'll hand them to Mr. Honey.  I

16   think that your name is on those.  And let me just ask you to

17   look at what has been marked as Deposition Exhibit No. 4 and

18   ask if you can identify that document.  Once again, it

19   appears to be a copy, not an original.

20            MR. FURR:  It’s a copy of a letter I wrote to

21   Mister --

22            MS. MOUSER:  You might want to spell it.

23            MR. FURR:  — Touboul, T-o-u-b-o-u-l.

24            MS. MOUSER:  Where was Mr. Touboul?  Was he in this

25   country?



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1            MR. FURR:  I think he was in Switzerland.

 2            MS. MOUSER:  And is that your signature on the

 3   letter?

 4            MR. FURR:  Yes.

 5            MS. MOUSER:  And did you sign as chairman of the

 6   legion?

 7            MR. FURR:  Yes.

 8            MS. MOUSER:  And what’s the date of the letter?

 9            MR. FURR:  October 25, 1993.

10            MS. MOUSER:  Yes, sir.  Now, so you believed you

11   were an officer of the legion at the time you filed

12   bankruptcy; is that correct?

13            MR. FURR:  Right.

14            MS. MOUSER:  And why did you not list that on your

15   bankruptcy schedules?

16            MR. FURR:  List what on the bankruptcy schedules?

17            MS. MOUSER:  That you were an officer in that

18   corporation.

19            MR. HONEY:  Just a second.  I'm going to ask if

20   you've got a copy of the bankruptcy petition, if you would

21   refer to a specific question because --

22            MS. MOUSER:  Sure.

23            MR. HONEY:  — you know, I'm not sure --

24            MS. MOUSER:  I think it’s question 16.

25            MR. HONEY:  Of the statement of --



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 1            MS. MOUSER:  And I'm very willing to accept your

 2   answer and Mrs. Furr’s answer that as a nonprofit you did not

 3   think that that was — let me rephrase.

 4   Q    (By Ms. Mouser)  Mrs. Furr, I take it that you felt that

 5   if it was a nonprofit corporation, that would not have needed

 6   to be disclosed in your schedules.  I'm sorry.  Is that — am

 7   I misinterpreting your answer?  In other words, if you had

 8   been a shareholder or an officer in Coca-Cola, you would have

 9   put that on there?

10   A    Right.

11   Q    But as a nonprofit, you did not feel that that was even

12   relevant?

13   A    There was no — it was a volunteer.

14   Q    Sure.

15            MS. MOUSER:  And, Marc, I'm very willing to accept

16   that answer.  I think that’s --

17            MR. HONEY:  Okay.

18            MS. MOUSER:  I think that makes sense.  The question

19   — the reason I'm asking it is, paragraph 16 in the schedule

20   — did you see that, Mr. Furr?

21            MR. FURR:  Here’s the question she’s asking about.

22            MS. MOUSER:  It asks you to list any and all --

23   well, what it says is, for the record, for individuals --

24   naming like if you're an individual filing bankruptcy as

25   opposed to a partnership or a corporation — list the names



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 167



 1   and addresses of all business in which either debtor was an

 2   officer, director, partner, or managing executive of a

 3   corporation, partnership, sole proprietorship, or — and it

 4   says if you're self-employed — within the two years

 5   immediately preceding.

 6        And technically, at the time you-all filed bankruptcy,

 7   you both felt you were officers of the legion.  And as I

 8   understand, the answer to my question as to why you did not

 9   list it is because the legion is a nonprofit.

10            MRS. FURR:  Right.

11            MS. MOUSER:  Yes.  I understand that.

12            MR. HONEY:  I think it’s also correct that a Court

13   had made a determination that they had resigned, I think is

14   also the testimony.  Is that right?

15            MRS. FURR:  I don't --

16            MS. MOUSER:  No.  I'm very willing, Marc, and I'm

17   very comfortable and willing --

18            MR. HONEY:  All right.

19            MS. MOUSER:  I can understand how someone would

20   think that a nonprofit would not be — I mean, I think that

21   makes all the sense in the world, and that answers my

22   question.

23            MR. HONEY:  And also for our record, we did make a

24   note of this issue as part of our bankruptcy order too, as

25   you recall.  We did point that out.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1            MS. MOUSER:  Yes.

 2             (AN OFF-THE-RECORD DISCUSSION WAS HELD.)

 3            MS. MOUSER:  Let’s look at No. 5, if you don't mind,

 4   and just kind of go through these.  And I'm sitting over here

 5   next to you, Mr. Furr, just because I don't have any other

 6   copies.  Now, do you recognize that document?

 7            MR. FURR:  I don't remember this one.

 8            MS. MOUSER:  Okay.  You've never seen that before?

 9            MR. FURR:  If I have, I don't remember.

10            MS. MOUSER:  Okay.  And that’s Exhibit No. 5.

11   Q    (By Ms. Mouser)  Mrs. Furr, did you recognize Exhibit

12   No. 5?

13   A    I don't recognize it.

14            MS. MOUSER:  If I might just look at it, please,

15   sir, for just a second.  Okay.  Now let’s look at — let me

16   ask, is any of that handwriting on Exhibit No. 5 your

17   handwriting, Mr. Furr, to the extent you can recognize it.

18            MR. FURR:  No.

19            MS. MOUSER:  Your name certainly does not appear on

20   that document, does it?

21            MR. FURR:  No.

22            MS. MOUSER:  And neither does a purported signature

23   for you either, does it?

24            MR. FURR:  No.

25            MS. MOUSER:  It looks like it’s — we're going to



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 169



 1   try to read a little French here — order of payment.

 2   Obviously, I can't read.  Confirmation of some type of a

 3   telephone order to a bank out of Lausanne Switzerland.  Does

 4   that appear like what it is to you?

 5            MR. FURR:  Yeah.

 6            MS. MOUSER:  I mean, if it’s a legitimate document.

 7            MR. HONEY:  And you're reading in French.  That

 8   language you're reading is French.

 9            MS. MOUSER:  Yeah.  Right.

10        And it looks like there was a transfer made of $100,000

11   where it says montant, money, and the beneficiary bank was

12   National Capital Bank of Washington.  Have you ever had a

13   bank account there?

14            MR. FURR:  No.

15            MS. MOUSER:  And the beneficiary was Liberty Lobby.

16   Does that seem like what it is to you?

17            MR. FURR:  Yes.

18            MS. MOUSER:  But obviously, you did not — you did

19   not author this document, did you?

20            MR. FURR:  No.  I don't — I don't remember ever

21   seeing it.

22            MS. MOUSER:  Never seen it.  That’s right.  Okay.

23        What about No. 6?  Do you recognize Exhibit No. 6?

24            MR. FURR:  Yes.  That’s my signature.

25            MS. MOUSER:  But do you recognize the document?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1            MR. FURR:  I wrote that letter to Mr. Touboul,

 2   T-o-u-b-o-u-l.

 3            MS. MOUSER:  And basically what were you asking or

 4   telling Mr. Touboul to do?

 5            MR. FURR:  That I was — had revoked my resignation

 6   and that I was still chairman of the board, and that LaVonne

 7   D. Furr was a member of the board of directors.

 8            MS. MOUSER:  Yes, sir.  And what’s the date of that

 9   letter?  Is there a date at the top?

10            MR. FURR:  November 1st, 1993.

11            MS. MOUSER:  And let’s look at Exhibit No. 7 and see

12   if you recognize that document.

13            MR. FURR:  It has my signature on it, but I don't

14   remember it.  So I must have signed it.  I must have seen it

15   before.

16            MS. MOUSER:  Well, you may not have.  I mean, are

17   you sure that’s your signature?

18            MR. FURR:  Yes.  I'm sure it’s my signature.

19            MS. MOUSER:  And what does that document purport to

20   do or say?

21            MR. FURR:  It’s a letter to Mr. Touboul to wire

22   $100,000 to National Capitol Bank of Washington to the

23   account of Liberty Lobby.

24            MS. MOUSER:  And when you compare that document to

25   what we marked as Exhibit 5, it seems like some of the bank



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 171



 1   names and the amount of the money are the same, doesn't it?

 2            MR. FURR:  Yes.

 3            MS. MOUSER:  Now, why — Exhibit No. 7 is on the

 4   legion letterhead.  Right?

 5            MR. FURR:  Right.

 6            MS. MOUSER:  Now, why would the Legion for the

 7   Survival of Freedom be giving bank instructions to a bank in

 8   Switzerland to wire money from Switzerland to Liberty Lobby?

 9            MR. FURR:  I don't know.

10            MS. MOUSER:  You don't remember any of the

11   circumstances under which you signed that?

12            MR. FURR:  No.

13            MS. MOUSER:  You know, sometimes at the end of

14   letters, you know how they have the typist’s initials down

15   here?

16            MR. FURR:  Yeah.

17            MS. MOUSER:  Nothing like that on that, huh?  Is

18   there?

19            MR. FURR:  No.

20            MS. MOUSER:  Did you prepare that document?

21            MR. FURR:  I don't think so.

22            MS. MOUSER:  Do you do --

23            MR. FURR:  Too deep for me.

24            MS. MOUSER:  Do you do a lot typing, Mr. Furr?

25            MR. FURR:  I do — or I did.  I haven't done any



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 172



 1   lately.

 2            MS. MOUSER:  Do you think Mrs. Furr would have

 3   prepared that?

 4            MR. FURR:  No.

 5            MS. MOUSER:  Do you think maybe Mr. Carto prepared

 6   it?

 7            MR. FURR:  He probably prepared this.

 8            MS. MOUSER:  And when you say he probably did, why

 9   do you use the word “probably"?

10            MR. FURR:  Because he was familiar with the

11   transaction since it involved — it was --

12            MS. MOUSER:  And did he ever explain to you why you,

13   as chairman of the board of legion, would be authorized to

14   transfer money to Liberty Lobby?  Did he ever explain that to

15   you?

16            MR. FURR:  Not that I recall.

17            MS. MOUSER:  Do you ever recall asking him why you

18   were signing that?

19            MR. FURR:  No, I didn't.  I'm sure I didn't ask him.

20            MS. MOUSER:  And why are you sure you would have not

21   have asked him?

22            MR. FURR:  I don't know.

23            MS. MOUSER:  I mean --

24            MR. FURR:  I don't think I would have asked him

25   that.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 173



 1            MS. MOUSER:  Why don't you think you would have

 2   asked him?

 3            MR. FURR:  Because I trusted he knew what he was

 4   doing.

 5            MS. MOUSER:  Now looking back on it, does it seem

 6   kind of strange that as chairman of one board, you would be

 7   authorizing — I guess that was the legion’s money, I guess.

 8   I mean, you were chair of the board — why you as chair of

 9   one board would be transferring money or directing it to be

10   deposited in another corporation’s checking account or

11   whatever kind of account that was?  Looking back on it, does

12   that seem a little unusual to you?

13            MR. FURR:  Since you put it that way, yes.

14            MS. MOUSER:  I mean, you're 12 years in the clerk's

15   office.  You're probably more than most lay people — I know

16   it was some time ago, but more than most lay people, you can

17   understand a lot of legalities that they may not be able to

18   understand.  And certainly you can understand how as chairman

19   of one board, if there was money moved from one corporation

20   to another without adequate consideration, that would be kind

21   of unusual, wouldn't it?

22            MR. FURR:  Normally, I would say yes.

23            MS. MOUSER:  Yeah.  Do you remember — did legion

24   get anything for that $100,000?  Do you remember?

25            MR. FURR:  No.  I'm sure of that.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 174



 1            MS. MOUSER:  Oh.  You don't know or you're --

 2            MR. FURR:  I'm sure they didn't get nothing.

 3            MS. MOUSER:  You're sure they didn't?

 4            MR. FURR:  Did not get any money.

 5            MS. MOUSER:  Now, why are you sure?

 6            MR. FURR:  Because I would have known about it.

 7            MS. MOUSER:  That was a lot --

 8            MR. FURR:  Legion never had enough money to do

 9   anything with, much less $100,000.

10            MS. MOUSER:  $100,000, that’s a lot of money to me

11   today, but back in '93 that would have been a lot of money

12   too.

13            MR. FURR:  Yeah.

14            MS. MOUSER:  Yeah.  Okay.  Let’s look at No. 8.

15   Could you identify No. 8.

16            MR. FURR:  A letter dated December 9, 1993, with my

17   signature to Mr. William S. Hulsey.

18            MS. MOUSER:  And he’s the one that you believe got

19   in cahoots with Mr. Raven and Mr. Marcellus and had an

20   unfortunate incident with Mr. Carto.

21            MR. FURR:  Yes.  He was present when they physically

22   threw him out of the office.

23            MS. MOUSER:  Let’s look at No. 9, if we might,

24   please, sir.  Do you --

25            MR. FURR:  That’s a letter dated March 22, 1994,



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 175



 1   with my signature.

 2            MS. MOUSER:  And it looks like it’s to that same

 3   bank in Lausanne, Switzerland, isn't it?

 4            MR. FURR:  Yes.

 5            MS. MOUSER:  And, once again, that’s not an

 6   original.  All of these appear to be copies, don't they?

 7            MR. FURR:  Right.

 8            MS. MOUSER:  Does that appear to be your signature

 9   on Exhibit 8 as well?

10            MR. FURR:  Yes.  It’s my signature on this one too.

11            MS. MOUSER:  Now, in this letter, it seems like in

12   the second paragraph — and once again, this is on legion

13   letterhead, isn't it?

14            MR. FURR:  Yes.  And it says that — paragraph 2

15   indicates that they got some legion money over there, but I

16   don't know.

17            MS. MOUSER:  And, once again, you signed it as

18   chair, but there’s no, like, little initials at the end

19   showing who prepared the letter, does it?

20            MR. FURR:  No.

21            MS. MOUSER:  Who do you think prepared that letter?

22            MR. FURR:  I'm not sure.  I don't know.

23            MS. MOUSER:  Did you prepare it?

24            MR. FURR:  I probably prepared it at the direction

25   of Mr. Carto.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 176



 1            MS. MOUSER:  Now, in '94 you-all were here in Hot

 2   Springs.

 3            MR. FURR:  Yes.

 4            MS. MOUSER:  Do you think you typed that letter up

 5   here in Hot Springs?

 6            MR. FURR:  Yeah.

 7            MS. MOUSER:  Are you sure about that?

 8            MR. FURR:  I could have.

 9            MS. MOUSER:  Yeah.  You could have.  I mean, I want

10   — if you don't remember --

11            MR. FURR:  I don't remember.

12            MS. MOUSER:  If you don't remember, let’s just say

13   you don't remember.

14        Now, do you remember thinking at one time — for example

15   on March 22 of '94, the date of Exhibit 9 — that you thought

16   the legion had money over in Switzerland?

17            MR. FURR:  No.  I don't recall that.  I don't recall

18   ever thinking the legion had any money over there.

19            MS. MOUSER:  So why would you sign a letter that

20   said that?

21            MR. FURR:  (No response.)

22            MS. MOUSER:  May I suggest an answer?

23            MR. FURR:  Yeah.

24            MS. MOUSER:  Did Willis Carto tell you that?  How

25   else would you have had known?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 177



 1            MR. FURR:  Yes.  I'm sure he had to tell me that.

 2            MS. MOUSER:  And if he is as truthful as you and

 3   Mrs. Furr say he is, then that was probably true, wasn't it?

 4            MR. FURR:  Well, if he said it was, if he said

 5   there’s some over there.

 6            MS. MOUSER:  I'm going to ask you the same question

 7   I asked Mrs. Furr.  So if there was legion money over there

 8   and the legion never got it, other than Mr. Carto, who could

 9   have gotten it?

10            MR. FURR:  I don't know.

11            MS. MOUSER:  Are you aware of anyone else over in

12   Switzerland acting on behalf of the legion other than

13   Mr. Carto and any person he hired?

14            MR. FURR:  No.  I don't know who he hired over

15   there.

16            MS. MOUSER:  But you don't know any other person

17   over there acting on behalf of the legion?

18            MR. FURR:  No.

19            MS. MOUSER:  Did anybody from this bank in Lausanne

20   ever contact you?  Do you remember here in — you would have

21   been in Hot Springs?

22            MR. FURR:  Not that I recall.

23            MS. MOUSER:  Why were they — why were they

24   impounding the funds?  Do you remember why that was going on?

25   Your letter says, We understand that --



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 178



 1            MR. FURR:  No, I don't.

 2            MS. MOUSER:  Do you have any recollection that the

 3   legion funds were ever impounded?

 4            MR. FURR:  No, I don't.  No.

 5            MS. MOUSER:  Because I think your testimony is, you

 6   don't ever really recall there ever being any funds.

 7            MR. FURR:  No.

 8            MS. MOUSER:  And, once again, the only reason why

 9   you would have thought that is if Mr. Carto told you?

10            MR. FURR:  Correct.

11            MS. MOUSER:  Okay.

12            MR. HONEY:  Let’s take a break right here.

13            MS. MOUSER:  Sure.

14                     (A SHORT BREAK WAS TAKEN.)

15            MS. MOUSER:  Let’s look at No. 10, Mr. Furr, and ask

16   you if you can identify No. 10.

17            MR. FURR:  It’s a letter with my signature date,

18   June 30th, 1994.

19            MS. MOUSER:  And who is it to?

20            MR. FURR:  Mr. Pierre, P-i-e-r-r-e, Ammann,

21   A-m-m-a-n-n.

22            MS. MOUSER:  And he’s now at that same bank, but in

23   a Zurich — it looks like it’s a telefax to Zurich, isn't it?

24            MR. FURR:  Correct.

25            MS. MOUSER:  Is that your signature — excuse me.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 179



 1   That’s a copy of a document, isn't it?

 2            MR. FURR:  That’s a copy of a document.

 3            MS. MOUSER:  Does that appear to be your signature

 4   as chairman of legion?

 5            MR. FURR:  It appears to be my signature.

 6            MS. MOUSER:  And what does that document basically

 7   do?

 8            MR. FURR:  I don't remember this.  I don't recall

 9   this document at all.

10            MS. MOUSER:  Do you think you would have prepared

11   that here in Hot Springs or --

12            MR. FURR:  No.

13            MS. MOUSER:  Do you think that that would have been

14   prepared by someone else and mailed to you here in Hot

15   Springs to sign?

16            MR. FURR:  That, I think, is what happened.

17            MS. MOUSER:  Do you remember signing the letter?

18            MR. FURR:  No.

19            MS. MOUSER:  Do you remember anything about the

20   facts that are discussed in the letter?

21            MR. FURR:  I don't remember any facts of the letter.

22            MS. MOUSER:  May I see that for just a moment?

23            MR. FURR:  Yeah.  (Handed.)

24            MS. MOUSER:  And, once again, I guess my question

25   is, if the legion had no interest in the Farrell estate, why



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 180



 1   were you, as chairman of the board, communicating at all with

 2   someone in Switzerland?  I'm assuming that had to do --

 3   something about that Farrell estate.  Is that what you

 4   assume?  Why else would you, as chairman of the legion board,

 5   be communicating to someone in Switzerland?

 6            MR. FURR:  Well, I don't see an indication in this

 7   letter that it had anything to do with the Jean Farrell

 8   estate.

 9            MS. MOUSER:  Yeah.  It’s not mentioned in there, is

10   it?

11            MR. FURR:  No.

12            MS. MOUSER:  Why else, though, would you have sent a

13   letter to someone in --

14            MR. FURR:  You would presume that’s what it's

15   talking about.

16            MS. MOUSER:  And so the question arises, if the

17   legion wasn't due any of the money from the Farrell estate,

18   why would you, as chairman of the board, have been

19   communicating with someone in Zurich?

20            MR. FURR:  I don't know.

21            MS. MOUSER:  Did the legion ever have any other

22   business in Switzerland, other than the Farrell estate, to

23   the best of your knowledge?

24            MR. FURR:  To the best of my knowledge, no.

25            MS. MOUSER:  And let’s look at No. 11.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 181



 1            MR. FURR:  I never saw that document before.

 2            MS. MOUSER:  And your name is not on there and your

 3   signature is not on there either, is it?

 4            MR. FURR:  No.  He’s quoting me there, but I don't

 5   know anything about that.  I don't remember anything about

 6   that.

 7            MS. MOUSER:  And let’s look at No. 12, please, sir.

 8   Now, I'll be the first to admit these are very bad copies.

 9            MR. HONEY:  No. 12, you know, purports to be a

10   check, the front and back, of — it’s not legible to me.

11   Now, somebody has typed some information at the bottom, but,

12   I suppose, that your office or some other office analyzing

13   this check did that.  But — is that the way it appears to

14   you?

15            MS. MOUSER:  Yes.  That is exactly what it is.  It

16   appears to be probably a picture made off of a microfiche,

17   and, of course, those pictures or photocopies are not usually

18   very legible.

19        What the legion believes it to be, Mr. Furr, is a check

20   No. 2004 drawn on Committee to Defend Liberty Lobby.  Now, I

21   think I can read that.

22            MR. FURR:  Yeah.

23            MS. MOUSER:  Community to Defend Liberty — it looks

24   like it’s a check belonging to Committee to Defend Liberty

25   Lobby.  Could we agree to that?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 182



 1            MR. FURR:  Right.

 2            MS. MOUSER:  And it appears — they think that if

 3   you could read that date — and I guess you could see August

 4   17, '98, barely, for $3,000 payable to you and Mrs. Furr.

 5   Now, do you recall why — first of all, do you know anything

 6   about the Committee to Defend Liberty Lobby?

 7            MR. FURR:  I've heard of it.

 8            MS. MOUSER:  What have you heard about that?

 9            MR. FURR:  I've just read some promotions in

10   Spotlight about it.

11            MS. MOUSER:  I'm assuming it’s a committee — I'm

12   sorry?

13            MR. FURR:  A committee that was established to raise

14   funds for Liberty Lobby.

15            MS. MOUSER:  And I'm assuming Liberty Lobby either

16   set up the committee or it was done with its approval.

17            MR. FURR:  Right.

18            MS. MOUSER:  Is someone trying to attack Liberty

19   Lobby?  When you say committee to defend, do you know, are

20   they attacked by somebody or is that just a name?

21            MR. FURR:  Presumably so.  I don't know.

22            MS. MOUSER:  Why would the Committee to Defend

23   Liberty Lobby — well, first, let me ask you this:  Did you

24   and Mrs. Furr ever get a check for $3,000 from that

25   committee?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 183



 1            MR. FURR:  Looking at it, it’s a copy, but I --

 2   right.

 3            MS. MOUSER:  Well, but that doesn't mean you got it.

 4            MR. FURR:  Yes.

 5            MS. MOUSER:  See, I can't see any endorsement --

 6   somebody barely.  I mean, barely.  I mean, it’s not very

 7   legible.  I mean, do you recall if you and Mrs. Furr received

 8   that check?

 9            MR. FURR:  Yes.

10            MS. MOUSER:  Now, why would that committee have been

11   giving you-all money in '98?

12            MR. FURR:  Mr. Carto was reimbursing us for attorney

13   fees that we paid, incurred.

14            MRS. FURR:  Expenses, postage, telephone calls.

15   Q    (By Ms. Mouser)  And in what piece of litigation was

16   that reimbursement for?

17   A    Sometime it went on for a whole year.  Expense, you

18   know, accumulated.  It wasn't --

19   Q    I'm sorry.  For what litigation?  Was it for the Texas

20   proceeding or the California proceeding or --

21   A    Could have been here.  Could have been California.

22   Well, we haven't been to California, so it could have been

23   even some in Texas too.

24   Q    So you-all actually — let’s take them one at a time.

25   Attorney’s fees.  Did you pay Jack Dickerson any money to



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 184



 1   file your bankruptcy?

 2   A    That was personal.  Nobody else paid that.

 3   Q    That would not have been any of this money?

 4   A    No.

 5            MR. FURR:  No.

 6   A    No.

 7   Q    (By Ms. Mouser)  So this $3,000 — what attorneys, if

 8   any, would this have gone to — what attorneys' fees?  What

 9   attorneys received those fees if this reimbursed you for

10   attorneys' fees?  Attorneys in Texas?

11   A    Texas and here.

12   Q    Mr. Honey?

13   A    Mr. Carl Crow.

14   Q    Oh, Carl Crow.  Okay.

15        Now, why was the Committee to Defend Liberty Lobby

16   reimbursing you for your personal attorney’s fees or

17   expenses, for that matter?

18   A    Because Liberty Lobby was involved in all of this, and I

19   think — to me — I haven't read about the committee, but

20   just like Bill Clinton set up for his lawyer’s fees,

21   something like that, to help with the expenses of all this

22   litigation.  And --

23   Q    Do you think that Mr. Carto, through this committee or

24   through Liberty Lobby, feels somewhat responsible for the

25   legalities you and Mr. Furr have found yourself in?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 185



 1   A    I feel like he does.

 2   Q    And why — if he’s not done anything wrong, why do you

 3   feel that he feels that?

 4   A    The misinterpretation of what Tom Marcellus and all that

 5   — you know, how they all went about it.  And that’s all I

 6   can say.

 7            MS. MOUSER:  Mr. Furr, what would your response be

 8   to the question of why Mr. Carto, or through the committee or

 9   through Liberty Lobby, would feel the necessity to reimburse

10   your personal attorney’s fees and costs?

11            MR. FURR:  Because he feels that like we got

12   involved because of him.

13            MS. MOUSER:  Is that not true?

14            MR. FURR:  Well, I would think so, yes.

15            MS. MOUSER:  Okay.  Did you-all — or excuse me.  Do

16   you recall that you or Mrs. Furr, or both of you, deposited

17   your $3,000 in your checking account?

18            MR. FURR:  We probably cashed it to pay the

19   attorney.

20            MS. MOUSER:  Let’s look at No. 13.  I'm sorry, sir.

21   Excuse me.  This is even worse than the first one.

22            MRS. FURR:  That would be a fee.

23            MS. MOUSER:  Yeah.  This is also a check.  It seems

24   like Committee to Defend Liberty Lobby and then what — you

25   might can see $1,000 in September of '98.  And that’s what



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 186



 1   they've typed down here.  Would that have also been the same

 2   thing as the other check?

 3            MR. FURR:  Same thing.  This one is the same thing.

 4   I'm sure --

 5            MS. MOUSER:  And when you say this one, this is

 6   Exhibit 14.

 7            MR. FURR:  14.  It’s payable to Lewis Furr and

 8   endorsed by me with my account number on it, so I'm sure that

 9   was cashed.

10            MS. MOUSER:  And this one was for $2,055.06.  That

11   would be the same thing as the others?

12            MR. FURR:  Right.  That includes some odd cents.

13   I'm sure that includes expenses too.

14            MS. MOUSER:  Yes, sir.  With that six cents, it

15   certainly is an odd amount, isn't it?

16            MR. FURR:  Yeah.

17            MS. MOUSER:  So I'm going to now give, while you're

18   looking at me, Ms. Miller all these originals.

19            MR. FURR:  Original copies.

20            MR. HONEY:  Copies, actually.

21            MS. MOUSER:  But the original exhibits, though.  I'm

22   sorry.  Excuse me.  They're copies, but they are the original

23   exhibits.

24            MR. FURR:  That’s a better way to put it.

25            MS. MOUSER:  Yes, sir.  I'm sorry.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 187



 1   Q    (By Ms. Mouser)  And then I think we've already talked

 2   about when you-all — excuse me.  Mrs. Furr, when the

 3   bankruptcy was filed, do you recall that you-all maintained

 4   an account at the Bank of Hot Springs?  Does that sound

 5   familiar to you?

 6   A    Yes.

 7            MS. MOUSER:  And, Mr. Furr, does that sound familiar

 8   to you as well?

 9            MR. FURR:  Say what?

10            MS. MOUSER:  That when you filed bankruptcy in 1993

11   that you had an account at the Bank of Hot Springs.

12            MR. FURR:  Yes.

13            MRS. FURR:  It changed names last week.

14            MR. FURR:  That’s the name of it then.  It’s changed

15   names since then.  It’s hard to keep up with.

16            MS. MOUSER:  Yeah.  Well, I'll tell you, you go to

17   sleep, these banks change names, don't they?

18            MR. HONEY:  And let me add about that, Ms. Mouser.

19   And I'm referring to Schedule B on the bankruptcy schedule.

20            MS. MOUSER:  Yeah.

21            MR. HONEY:  My understanding of the way that these

22   schedules are prepared is that the Furrs, like any other

23   clients, would fill out a questionnaire, and the

24   questionnaire would contain this information.  And it would

25   be turned in to the attorney’s office, and one of two things



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 188



 1   could happen.  Either they could leave the information about

 2   the checking account off their questionnaire or it was on the

 3   questionnaire and the attorney’s office --

 4            MS. MOUSER:  A zero balance.

 5            MR. HONEY:  Well, no.  The attorney’s office omitted

 6   it from the schedules.

 7            MS. MOUSER:  Sure.

 8            MR. HONEY:  And I don't think that we have — or I

 9   don't believe we have access to the actual questionnaire they

10   filled out.  So I'm not sure that we know which of those two

11   took place.

12            MS. MOUSER:  Yes.  And obviously, anything to do

13   with the schedules, that is water under the bridge and that

14   will not be — that’s not an issue, it being omitted.

15            MR. HONEY:  Good.

16   Q    (By Ms. Mouser)  Follow-up question, that account — I

17   know the name of the bank may have changed — did you have

18   any other deposit accounts at the time you filed bankruptcy?

19   A    No.

20   Q    Do you have any other --

21            MR. FURR:  Yes.  Yes.

22            MS. MOUSER:  Oh, excuse me.  I'm sorry.

23            MR. FURR:  We had a small account with Southern

24   National Bank in Tallulah, Louisiana.

25            MS. MOUSER:  Now, that’s the one that you describe



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 189



 1   as being levied.

 2            MR. FURR:  They levied on it, yes.

 3            MS. MOUSER:  Did they reduce it to zero?

 4            MR. FURR:  Zero.

 5            MS. MOUSER:  They usually do that.

 6            MR. FURR:  That’s Tallulah, T-a-l-l-u-l-a-h.

 7            MS. MOUSER:  Do you remember just how --

 8   approximately how much was in that account?

 9            MR. FURR:  No.  A very small account.

10            MS. MOUSER:  Uh-huh.

11            MRS. FURR:  We had even forgotten about it, it was

12   so small.

13            MR. FURR:  Yeah.  The IRS found it.  I had forgotten

14   about it.

15          (EXHIBIT NO. 15 WAS MARKED FOR IDENTIFICATION.)

16   Q    (By Ms. Mouser)  Mrs. Furr, let me hand to you what Ms.

17   Miller has marked as Exhibit 15 — and it appears to be a

18   copy of a signature card — and ask if you recognize that

19   document.

20   A    Yes, I do.

21   Q    And what is that document?

22   A    Signature cards for a bank.

23   Q    In?

24   A    Houston.

25   Q    Is it Post Oak Bank?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 190



 1   A    Yes.

 2   Q    And what involvement did — what was the name on the

 3   account?

 4   A    Institute for Historical Review.

 5   Q    And what was that account opened for?

 6   A    I really don't know.

 7   Q    Is that your — a copy of your signature on the card?

 8   A    That’s a copy of my signature.

 9   Q    Why would you sign a signature card if you did not know

10   what the bank account was going to be used for?

11   A    Commercial checking account.

12   Q    Uh-huh.  And what was that commercial checking account

13   going to be used for?

14   A    If that was under the Institute for Historical Review, I

15   don't know.

16   Q    I'm only going to ask one other time.  I don't want to

17   be repetitious.  So you signed the signature card on a

18   commercial account for the Institute for Historical Review

19   and you did not know why the account was being opened?

20   A    She probably told me, but I don't remember.

21   Q    Who is she?

22   A    Mrs. Carto.

23   Q    Now, Jean Scott is also on there, isn't she?

24   A    Right.

25   Q    But that is not Jean Smith, Courtney Smith’s wife.  This



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 191



 1   is a different woman?

 2   A    Oh, no.  This is --

 3   Q    Who is Jean Scott?

 4   A    She worked for Tom Marcellus, and she’s now Elisabeth

 5   Carto’s secretary, I guess.

 6   Q    That appears to be in July of '94.  Is that what you

 7   note on there?

 8   A    Yes.

 9   Q    Why would you have been involved to the extent in '94

10   that you would be a signer on a commercial account for the

11   Institute for Historical Review?  What were you doing for

12   them at that time?

13   A    Nothing.

14   Q    So why would your name appear on the signature card?

15   A    I guess just like Mr. Carto was on the American Mercury.

16   In case something happened to somebody else, that I'd do it.

17   I was the fall guy.

18   Q    Were you having regular communication with Mrs. Carto

19   about IHR at that time?

20   A    No.

21   Q    What about Mr. Carto?

22   A    No.

23   Q    What about Mrs. Scott?

24   A    No.

25   Q    So did you get a card about this card?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 192



 1   A    She just mailed it and said, Please sign that.

 2   Q    And you just signed it?

 3   A    Signed it.

 4   Q    Did you talk to Mr. Furr before you signed it?

 5   A    No.

 6   Q    Did you ever write any checks or sign any deposit slips

 7   out of that account?

 8   A    No.  This is the only thing I've ever seen.

 9   Q    Does that seem a little unusual to you?

10   A    No.  I don't know.  I just --

11   Q    Do you know a Henry B. Furr in Abilene, Texas?

12   A    No.

13   Q    Have you ever heard of a Furr Foundation, Incorporated?

14   A    No.  The only Furr I know, it was in El Paso and he’s a

15   Mexican.  I don't know him.  My brother was in El Paso.

16   Q    Yes, ma'am.  Do you feel that the legion was ever sold

17   to Willis Carto or vice versa?  Do you feel Willis Carto ever

18   bought the legion?

19   A    At the time he thought he did.

20   Q    He thought he had bought it?

21   A    Yes.

22   Q    Now, when was that approximately?

23   A    That was when we were at the lawyer’s office.

24   Q    Back in '67?

25   A    Yeah.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 193



 1   Q    He thought when he became an incorporator he had bought

 2   it?

 3   A    Right.  He didn't understand a nonprofit organization.

 4   It wasn't until all this happened that he realized that you

 5   can't buy — he said you just donated the money to the

 6   legion, is what you did.

 7   Q    Well, let me ask you this:  In '67 when he became an

 8   incorporator, did he infuse some money into the business?

 9   A    No.

10   Q    So when you say that he thought he bought it, what did

11   he actually do to buy it?

12   A    Mr. Matthews had borrowed — Mr. Platzer had given a lot

13   of money.  This time Mr. Matthews borrowed $10,000.  And at

14   my insistence — Mr. Matthews needed the money, and I said,

15   Well, you can have an interest in the — Marchita and I said,

16   You can have an interest in if you'll pay Mr. Platzer the

17   money, repay the loan.

18   Q    So Mr. Matthews owed Mr. Platzer $10,000?

19   A    Right.

20   Q    And this was in '67, approximately, when you-all were at

21   Graham’s office discussing all of this?

22   A    Right.  But Mr. Matthews borrowed it before he died.

23   Q    Sure.  Obviously.  Right.  And obviously — let’s see.

24   Now, not obviously.  Did Mr. Carto pay back Mr. Platzer

25   before Mr. Matthews died?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 194



 1   A    No.

 2   Q    It was afterwards?

 3   A    Afterwards.

 4   Q    And Mr. Carto felt that when he repaid that $10,000

 5   loan that Mr. Matthews owed and Mr. Matthews was already

 6   passed away that that’s when he thought he bought the legion?

 7   A    He paid a little bit at a time, not the full 10,000.

 8   Q    Yes, ma'am.

 9   A    In fact, I have a letter from Mr. Platzer saying that

10   the balance that you owed me, I want you to pay to LaVonne

11   Furr.

12   Q    And did you bring that letter with you today?

13   A    No, I did not.  I just thought that was — it was

14   personal.  And I forgot about it.

15   Q    Did Mr. Carto ever pay you that difference?

16   A    No.

17   Q    And why is that?

18   A    It’s part of my donation, I guess.

19   Q    Have you asked him to pay you that money?

20   A    No.

21   Q    And why is that?

22   A    Just the same thing.  He didn't have it at the time the

23   letter came in.  I hardly got a salary, so the — the legion

24   at that time just did not have any money.

25   Q    Did Mr. Carto have money?



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 195



 1   A    No.

 2   Q    Did Liberty Lobby have money?

 3   A    That I don't know.

 4   Q    When Mr. Carto got this money in Switzerland, why didn't

 5   he pay you back?

 6   A    Probably couldn't find the letter.

 7   Q    How much do you think he owes you?

 8   A    I think it was 2,000 something.  He paid most of it --

 9   most of it back.

10   Q    And that’s Platzer Shipyard, isn't it?

11   A    Correct.

12   Q    In fact — let me see here.  You know what?  This may be

13   that letter you were visiting about.  Let me see here.  We're

14   not going to make it — I bet that’s that letter.  We're not

15   going to make it an exhibit, but I bet that’s what you're

16   talking about.  Let’s look at it and see if it is.

17   A    That’s it.  But this is — this letter, but then a

18   couple of months later or so is when the balance was due.

19   Q    Yes, ma'am.

20   A    It’s the same principal.  Or same subject, I should say.

21            MS. MOUSER:   We won't make that an exhibit.

22            MR. HONEY:  All right.

23            MS. MOUSER:  If you don't mind.

24        And if you could mark these.  I think we're on 16 and

25   17, please, ma'am.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 196



 1     (EXHIBITS NOS. 16 and 17 WERE MARKED FOR IDENTIFICATION.)

 2            MS. MOUSER:  Mr. Furr, through Mr. Honey, I'm going

 3   to hand you copies of two other checks — and I think those

 4   copies are a little bit more legible — and ask if you can

 5   identify those.  I think that’s 16 and 17.

 6            MR. FURR:  Same thing applies to each of those.

 7            MS. MOUSER:  Now, let’s go over those, if you don't

 8   mind, please, sir.  Let’s start with No. 16.

 9            MR. FURR:  No. 16 is a copy of a check on the

10   account of Liberty Lobby dated April 4, 1997, in the amount

11   of $500 payable to me.

12            MS. MOUSER:  And you would have used that money --

13   you did get that check?

14            MR. FURR:  Yes.  I'm sure I did.  I don't know, but

15   I imagine — I'm sure I did.

16            MS. MOUSER:  But you don't really know, but if you

17   did, you would have used that money for the attorney's

18   fees --

19            MR. FURR:  Right.

20            MS. MOUSER:  — expenses, et cetera?

21            MR. FURR:  Yeah.

22            MS. MOUSER:  What about Exhibit 17?

23            MR. FURR:  Exhibit 17 is a check payable to me from

24   Liberty Lobby account in the amount of $1,000, and it's

25   marked for legal.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 197



 1            MS. MOUSER:  That’s like on the little memo or “for"

 2   line, isn't it?

 3            MR. FURR:  Right.

 4            MS. MOUSER:  And do you recall getting that check?

 5            MR. FURR:  I don't recall it, but I --

 6            MS. MOUSER:  But if you did get it, that money would

 7   have been used for what we talked about before?

 8            MR. FURR:  Right.

 9            MR. HONEY:  And neither one of those checks have the

10   backs reflected to show what happened to those, actually.

11            MS. MOUSER:  Right.  And Mr. Furr does not recall

12   that he actually got them.

13        Right, Mr. Furr?

14            MR. FURR:  Right.  I don't.

15            MS. MOUSER:  And if you could just pass those back

16   down through Mr. Honey to Ms. Miller.

17   Q    (By Ms. Mouser)  Mrs. Furr, do you know what Liberty

18   Lifeline Foundation is?  Have you ever heard of that

19   foundation?

20   A    I've heard of them, but I don't remember what it was.

21   Q    Who did you hear of it from?

22   A    Mr. Carto.

23   Q    And what did he say about it that you recall?

24   A    I don't — that’s been so long ago, I don't even

25   remember anything.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 198



 1            MS. MOUSER:  What about you, Mr. Furr?  Have you

 2   ever heard someone mention Liberty Lifeline Foundation?

 3            MR. FURR:  I've heard of it, but I don't know a

 4   thing in the world about it.

 5   Q    (By Ms. Mouser)  And then I think I asked both of you --

 6   but I don't recall, so let me ask again.  This International

 7   Legion for Survival of Freedom, do you know if it was

 8   incorporated, Mrs. Furr?

 9   A    I don't know whether it was incorporated.

10   Q    Do you know anything about it?

11   A    Whatever Mr. Carto said.  It was a foreign corporation.

12   Q    A foreign corporation?

13   A    Right.

14   Q    And what else did he say about it?

15   A    I don't remember.

16            MS. MOUSER:  Do you remember, Mr. Furr?

17            MR. FURR:  No, I don't.

18            MS. MOUSER:  Let’s make this 18.

19          (EXHIBIT NO. 18 WAS MARKED FOR IDENTIFICATION.)

20            MS. MOUSER:  Mr. Furr, this is a multiple-page

21   exhibit, 18.  It’s four pages.  I'm going to pass that to

22   Mr. Honey.  And would you look at that and see if you can

23   identify that document, please, sir.

24            MR. FURR:  That has my signature on it.  It’s a

25   power of attorney dated 2 January, 1991.



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 199



 1            MS. MOUSER:  What does that power of attorney

 2   purport to do?

 3            MR. FURR:  Give Mr. Carto power to represent the

 4   Legion for Survival of Freedom in managing the assets in

 5   Bordier & Company, B-o-r-d-i-e-r.

 6            MS. MOUSER:  And then there’s --

 7            MR. FURR:  And I don't remember.  I don't recall.

 8            MS. MOUSER:  It appears to be on letterhead from

 9   Bordier & Cie, C-i-e, out of Geneva, Switzerland, doesn't it?

10            MR. FURR:  Yes.

11            MS. MOUSER:  And, once again, I would ask — and

12   that’s the very first of that four-page exhibit, isn't it?

13            MR. FURR:  Yes.

14            MS. MOUSER:  I would ask again why you as — did you

15   sign it as chair of the legion?  Is that why you signed that?

16            MR. FURR:  Yes.  That’s what it says.

17            MS. MOUSER:  Yes, sir.  I guess I'd ask you again

18   why you're signing a document or why you signed a document

19   for Mr. Carto to have power of attorney for the legion in

20   Switzerland if the legion didn't have any money over there.

21            MR. FURR:  I don't know.  He signed it too, so --

22            MS. MOUSER:  But he never explained that document to

23   you?

24            MR. FURR:  I signed it, but I don't remember ever

25   seeing it.  I mean, that’s my signature, but I don't recall



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 200



 1   ever --

 2            MS. MOUSER:  And certainly you don't recall him

 3   saying anything about it?

 4            MR. FURR:  No.

 5            MS. MOUSER:  What’s the second page?

 6            MR. FURR:  That’s --

 7            MS. MOUSER:  Does your signature appear on the

 8   second page?

 9            MR. FURR:  No.  My signature is not on the second

10   page.

11            MS. MOUSER:  Is your name typed in there or is

12   Mrs. Furr’s name typed in?

13            MR. FURR:  Yeah.  Mrs. Furr’s name is typed in.

14            MS. MOUSER:  What does that page 2 purport to do?

15            MR. FURR:  It says authorization to establish a bank

16   account.

17            MS. MOUSER:  Do you ever remember being involved in

18   establishing a bank account in Geneva, Switzerland, at

19   Bordier & Cie?

20            MR. FURR:  No.

21            MS. MOUSER:  Do you ever remember Mrs. Furr being

22   involved in setting up an account in Geneva?

23            MR. FURR:  No.  No.

24            MS. MOUSER:  Would the only reason — let me

25   rephrase.  If that ever did occur, would the only reason for



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 201



 1   that to have occurred been in connection with the Farrell

 2   estate?

 3            MR. FURR:  I don't know, but I would presume so.

 4            MS. MOUSER:  I mean, the legion has never had any

 5   other business over there that you're aware of, has it?

 6            MR. FURR:  No.

 7            MS. MOUSER:  Have you personally ever had any

 8   business in Switzerland?

 9            MR. FURR:  No.

10            MS. MOUSER:  To your knowledge, has Mrs. Furr ever

11   had any personal knowledge — or business — excuse me — in

12   Switzerland?

13            MR. FURR:  No.

14            MS. MOUSER:  And then what does page 3 appear to be?

15            MR. FURR:  It says register of stockholders — of

16   shareholders as of January 20, 1992.

17            MS. MOUSER:  And your name is not on there, is it?

18            MR. FURR:  No.

19            MS. MOUSER:  And neither is Mrs. Furr?

20            MR. FURR:  No.

21            MS. MOUSER:  The International Legion for the

22   Survival of Freedom is on there, isn't it?

23            MR. FURR:  Right.

24            MS. MOUSER:  And then that page 4, what is it?

25            MR. FURR:  It’s a register of directors and officers



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 202



 1   of Atlantic Fixtures, Incorporated.

 2            MS. MOUSER:  Do you know what Atlantic Fixtures,

 3   Incorporated, is?

 4            MR. FURR:  I've never heard of it.

 5   Q    (By Ms. Mouser)  Mrs. Furr, have you ever heard of

 6   Atlantic Fixtures?

 7   A    Never.

 8   Q    Do you know anything about the international legion

 9   having any accounts in the British West Indies, Mrs. Furr?

10   A    No, I sure don't.

11            MS. MOUSER:   Mr. Furr, do you know anything about

12   that?

13            MR. FURR:  No.

14            MR. HONEY:  I would suggest making this first page

15   of Exhibit 18 a separate exhibit from the last three pages.

16            MS. MOUSER:  I don't have a problem with that.

17            MR. HONEY:  I don't believe they're part of the same

18   document.  They were executed a year apart from each other.

19            MS. MOUSER:  That’s not a problem at all.  We'll

20   make page one only Exhibit 18 and the other three pages be

21   Exhibit 19.

22          (EXHIBIT NO. 19 WAS MARKED FOR IDENTIFICATION.)

23   Q    (By Ms. Mouser)  Mrs. Furr, there was some mention of a

24   Lewin, L-e-w-i-n, lawsuit.  Do you remember the name Lewin?

25   A    Never heard of it.



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 1   Q    First name or last name?

 2   A    No.

 3            MS. MOUSER:  What about you, Mr. Furr?

 4            MR. FURR:  No.

 5   Q    (By Ms. Mouser)  And then a Gallipoli,

 6   G-a-l-l-i-p-o-l-i.  Did you ever --

 7   A    Never heard of that either.

 8   Q    Okay.

 9            MS. MOUSER:  What about you, Mr. Furr?

10            MR. FURR:  No.

11   Q    (By Ms. Mouser)  And then Degrelle, D-e-g-r-e-l-l-e.

12   Something about a book regarding Hitler.  Do you ever

13   remember that name?

14   A    I don't remember that name.

15            MS. MOUSER:  What about you?

16            MR. FURR:  I've heard of the name.  They were trying

17   to get it published in California.  I don't know what --

18            MS. MOUSER:  When you say they, was that the IHR?

19            MR. FURR:  IHR.

20   Q    (By Ms. Mouser)  And then there was also mention of,

21   quote, The Countess Business.  Was there ever a countess that

22   you know of?

23   A    No.

24            MS. MOUSER:  What about you, Mr. Furr?

25            MR. FURR:  I've heard of the name.  I don't know who



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 1   he is or anything about it.

 2   Q    (By Ms. Mouser)  You had mentioned the radio program

 3   Mr. Matthews had at the very beginning.  Did Mr. Carto have

 4   another radio program at one time that you're aware of,

 5   Mrs. Furr?

 6   A    Yes, he did.

 7   Q    And where --

 8   A    It was a health broadcast out of Florida.

 9   Q    When was that approximately?

10   A    Several years ago.

11   Q    Like in the '80s or before that?

12   A    No.  I think it’s the early '90s.

13   Q    Did that have anything to do with what we've been

14   talking about today?

15   A    It was a health program.  Had nothing to do --

16   Q    Nothing to do.  Okay.

17        And I'm sorry.  It’s getting late.  And I know I'm not

18   old enough to be doing this, but did I ask you — and even if

19   I did, would you repeat it again?  Do you know if Mr. Carto,

20   did he attend college?  Do you know about his educational

21   background?

22   A    You asked that before.  No.

23   Q    And you said you don't know?

24   A    I don't know anything about him attending college.  I

25   did say I heard that he started out for a lawyer.



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 1   Q    That’s right.

 2   A    Whether he was in it only a week or two weeks, that I

 3   don't know.

 4   Q    Right.

 5            MS. MOUSER:  And, Mr. Furr, I think I asked you too,

 6   and you said you did not know.

 7            MR. FURR:  I don't have any idea.

 8   Q    (By Ms. Mouser)  Do you know anything about, other than

 9   his involvement with Liberty Lobby, what he did before that?

10   A    No.  Except that he was a door-to-door salesman for, I'm

11   going to say, Ivory Soap.  But I don't think it was Ivory

12   Soap, but it was something.

13   Q    A cleaning agent or something?

14   A    Yeah.  Maybe it was Fuller Brush.  I don't know.  That

15   was just a joke.  That’s all I know about him.

16   Q    You mean he made that as a joke; that really wasn't what

17   he did?

18   A    Yeah, he did.

19   Q    Oh, he did do it.  Okay.

20            MS. MOUSER:  What about you, Mr. Furr?  Do you

21   know --

22            MR. FURR:  I don't have any idea what he did.

23   Q    (By Ms. Mouser)  Now, you know, Mrs. Furr, to have

24   talked with him so much and worked with him so much and he's

25   been in your home here and you've been in his home in



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 1   California, not to know any more about his background, does

 2   that seem unusual to you?

 3   A    Lewis and I, we don't ask.  Like the other day, we were

 4   some place.  Lewis said, Did you notice that?  I said no.  I

 5   said, That’s why I'm worried about your driving.  I said, If

 6   I'm talking to somebody, I don't know what they wear.  I

 7   would not be — I just don't care.  Beside that, you got to

 8   realize, I had three children.  I worked 14 to 15 hours a

 9   day, and I had to cook and wash.  I've never had a dryer.

10   Whatever anybody else does, I don't care.

11   Q    It would just seem like in the course of those — what

12   were they?  About 13 years — no.  From '67 to '79.

13            MR. FURR:  About 30 years.

14   Q    (By Ms. Mouser)  Yeah.  About 16 years.  That at some

15   point, he would have mentioned some previous work or

16   schooling or something.

17   A    He might have, but --

18   Q    You don't recall?

19   A    I don't recall.  And I wasn't interested.

20   Q    Do you know where he’s from?  Do you recall if he ever

21   said where he’s from?

22   A    I'm going to say he was either from Indiana or Illinois.

23            MR. FURR:  Ohio.

24   Q    (By Ms. Mouser)  Somewhere in the mid part of the

25   country?



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 1   A    Oh, Ohio.

 2   Q    Okay.

 3   A    I just --

 4   Q    Just wasn't something you talked about?

 5   A    You tend to your business; I tend to mine.

 6   Q    Do you recall what happened to his health radio show?

 7   A    No.  Well, it folded up.  It’s not no more.  So I guess

 8   you might call it that.  It folded up.

 9   Q    It’s not Marmelstain but Mermelstain,

10   M-e-r-m-e-l-s-t-a-i-n.  Is that name familiar to you?

11   A    I have heard of it.

12   Q    And how have you heard of that name?

13   A    I think there was a lawsuit.  I think that’s the one

14   that Mr. Hulsey, you know — but I don't know anything about

15   it or what happened to it or what exactly really went on with

16   that.

17   Q    Did Mr. Hulsey represent the legion in a lawsuit

18   involving Mermelstain?  Is that what you recall or — you may

19   not recall.

20   A    Shall I say I think so, but I don't know so.

21   Q    Do you know anything of what the lawsuit was about?

22   A    I do not know.

23            MS. MOUSER:  What about you, Mr. Furr?  Does that

24   name sound familiar to you?

25            MR. FURR:  It’s familiar, and I'm trying to recall



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 1   what that lawsuit was about.

 2            MS. MOUSER:  Yeah.  I couldn't find anything out

 3   about that.

 4   Q    (By Ms. Mouser)  Mrs. Furr, any financial statements

 5   that would be attached to the franchise tax reports, where

 6   would the legion’s copies of those reports and financial

 7   statements be, to the best of your knowledge?

 8   A    In California.

 9   Q    With Mr. Carto?

10   A    That I don't know.

11            MS. MOUSER:  Mr. Furr, do you recall at your

12   deposition in the California case that took place here in Hot

13   Springs, do you recall being shown a letter to Biddle,

14   B-i-d-d-l-e, & Company?

15            MR. FURR:  I don't recall it.

16            MS. MOUSER:  And then let's, for the record, go

17   ahead and mark — and I'll ask you to identify them — let's

18   mark these two documents as 20 and 21, I think is where we

19   are.

20     (EXHIBITS NOS. 20 and 21 WERE MARKED FOR IDENTIFICATION.)

21   Q    (By Ms. Mouser)  And then, Mrs. Furr, if you'll look at

22   those two documents and let me ask if you can identify those

23   documents.

24   A    Yes.  I remember that.

25   Q    It seems like one of those is when you and Mr. Furr



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   resigned, and then the other document, which would be, I

 2   think, Exhibit 21, is when basically you and Mr. Furr revoked

 3   your resignation.

 4   A    Right.

 5   Q    Is that what those are?

 6   A    Yes.

 7   Q    And if you wouldn't mind handing those to Mr. Furr

 8   through Mr. Honey and let him just look at those for just a

 9   moment.

10   A    I had one of those in your files, but I couldn't find --

11   Q    The other one?  That’s okay.

12   A    You know --

13   Q    Yeah.  That’s okay.  That’s not a problem.

14            MS. MOUSER:  Mr. Furr, I would just ask you the same

15   questions.  Those appeared to be the documents where, number

16   one, you and Mrs. Furr resigned from the board of directors,

17   and then the latter one was where you revoked that

18   resignation.  Is that accurate?

19            MR. FURR:  That’s correct.

20            MRS. FURR:  I think ours have the seal on them.

21            MS. MOUSER:  They do, and that’s just fine.

22   Q    (By Ms. Mouser)  Now, Mrs. Furr, do you have any

23   knowledge of the corporation Council on Dangerous Drugs?

24   A    I have knowledge of it.

25   Q    What knowledge do you have of that?



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 1   A    It was — I don't know whether it was Elizabeth’s little

 2   pet peeve, but they had a little magazine that the PTA or

 3   church could write in.  They were fighting drugs, just like

 4   they do today, and people could write in the dangers.  That

 5   lasted probably a year or two.

 6   Q    And then Liberty Lifeline Foundation.  Do you know

 7   anything about Liberty Lifeline?

 8   A    I've heard of it, but I don't remember that.

 9            MS. MOUSER:  What about you, Mr. Furr?  Have you

10   ever heard of the Council on Dangerous Drugs?

11            MR. FURR:  Yes.  They passed or sent out — mailed

12   out literature on the dangers of drugs to different --

13            MS. MOUSER:  And when you say they, you mean the

14   council itself?

15            MR. FURR:  Well, it was affiliated with the Legion

16   for Survival of Freedom.

17            MRS. FURR:  No, it was not.

18            MR. FURR:  I don't think it was.  Maybe it was

19   Liberty Lobby.  I don't know --

20            MS. MOUSER:  But Elisabeth Carto was involved, to

21   the best of your knowledge?  Was she even involved in that or

22   do you know?

23            MR. FURR:  I'm not sure.

24            MS. MOUSER:  What about, have you ever heard of

25   Liberty Lifeline Foundation?



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1            MR. FURR:  I've heard of it, but I don't know a

 2   thing about it.

 3   Q    (By Ms. Mouser)  And, Mrs. Furr, do you recall that you

 4   might have been secretary of that Council on Dangerous Drugs

 5   at one time?

 6   A    I probably could have, but I don't remember.

 7   Q    What about Independence House, Mrs. Furr?  Do you know

 8   anything about that?

 9   A    That’s under Liberty Lobby.

10   Q    And what do you know about it?

11   A    I don't know anything about it.

12            MS. MOUSER:  Let’s mark this as Exhibit 22

13          (EXHIBIT NO. 22 WAS MARKED FOR IDENTIFICATION.)

14            MS. MOUSER:  Mr. Furr, let me hand to you through

15   Mr. Honey what we've marked as Exhibit 22 and ask you if you

16   know anything about Independence House.

17            MR. HONEY:  I'm passing this back to Mrs. Furr.

18   A    That’s my signature, but I don't remember.

19   Q    (By Ms. Mouser)  Does it say L. M. Furr?

20   A    Yes.  LaVonne Mariam Furr.

21   Q    I thought we've been using LaVonne D. Furr?

22   A    Well, that was only on American Mercury.  And then I

23   signed L. M. Furr because the bank kept getting everything

24   mixed up.

25   Q    And L. M. Furr, when did you sign that way?



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 1   A    Whatever — it’s been years ago.

 2   Q    But, I mean, did you only sign for like Independence

 3   House, L. M. Furr?

 4   A    That’s right.  That was — I think it came and gone.  I

 5   don't even remember what it did.

 6   Q    You mean the entity Independence House?

 7   A    Right.  But that was under Liberty Lobby.  It wasn't

 8   under — sometime I did this to help Elisabeth Carto if she

 9   was out of town and — well, in fact, you see this blank.

10   Q    Sure.  It appears to be like just two pages of blank

11   checks copied.

12   A    So she said in case you need to write something, but she

13   filled in all — that was her business.  That wasn't mine.

14   Q    You must have been on a signature card, though.

15   A    I probably was.  Sure I was.

16   Q    For Independence House?

17   A    Yeah.

18   Q    What other signature cards do you think were you on for

19   — were you on a signature card for Liberty Lobby, Inc.?

20   A    Oh, heavens, no.

21   Q    What about any other Liberty Lobby entities?

22   A    I don't remember.

23   Q    IHR?

24   A    No.  That was --

25   Q    That was legion.



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 1   A    That was foreign.

 2   Q    That was legion.  Yeah.

 3        Other than LaVonne D. and L. M., have you ever used any

 4   other or signed your name any other ways that you can

 5   remember?

 6   A    Mother and grandmother.

 7   Q    No.  I mean — you know, I'm talking about like on

 8   checks and stuff like that.

 9            MR. FURR:  Mrs. Lewis B.

10   A    Mrs. Lewis B. Furr.

11   Q    (By Ms. Mouser)  Yeah.

12   A    I've never signed our personal account except Mrs. Lewis

13   B. Furr.

14   Q    But for all practical purposes, those would be the only

15   two ways?

16   A    Right.

17   Q    The documents that I've shown you today, Mrs. Furr --

18   let me start off with Mr. Furr.

19            MS. MOUSER:  Mr. Furr, the documents that I've shown

20   you today that you signed in regard to the business in

21   Switzerland, does looking at those documents — does it make

22   you have any different opinion as to what happened to the

23   money coming out of that Swiss estate?

24            MR. FURR:  I don't know what happened to it.

25            MS. MOUSER:  Do you feel that Willis Carto should



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 1   know?

 2            MR. FURR:  If anybody does, he should know.

 3   Q    (By Ms. Mouser)  What about you, Mrs. Furr?

 4   A    The same thing.  If anybody would know, it was him.  As

 5   you can see, we don't know.

 6   Q    How do you feel about Mr. Carto preparing documents for

 7   Mr. Furr to sign and for you to sign when you-all didn't even

 8   know whether or not the stuff in the document was true or

 9   not?

10   A    I told you, I believe him.  I still believe him today.

11   And as purported, he said that he would try and whatever --

12   some of the money he could get would go to the legion and the

13   other as to what Jean Farrell wanted it to go to.

14   Q    Other than family members, have you ever allowed anyone

15   to prepare documents for you like that and you sign them not

16   knowing whether the facts in them are true or not?

17   A    I signed those documents feeling like they were true.  I

18   didn't always understand them.

19            MS. MOUSER:  What about you, Mr. Furr?  Do you know

20   of — other than family members, have you ever allowed people

21   to prepare documents like you saw today and sign them when

22   you didn't know whether the stuff in them was true or not?

23            MR. FURR:  No.

24            MR. HONEY:  Both of you have had a lot of attorneys

25   over the years and been involved in a lot of litigation.  I



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   don't know if that would be included in that.

 2            MR. FURR:  Yeah.

 3            MS. MOUSER:  Well — but, yeah.  But, no.  I was

 4   excluding anything to do with lawsuits and stuff.

 5        Let’s take a little break.  I think I'm through.

 6        I think you-all brought some documents today, and I'll

 7   take a look at those.  And then I think we're done.

 8            MR. HONEY:  I think you're going to find that most,

 9   if not all of it, are things that you already have.

10            MRS. FURR:  You already have.

11            MS. MOUSER:  Can you just kind of summarize what you

12   have brought and that way — because I certainly don't want a

13   bunch of copies of stuff.  I assure you I've already got

14   plenty of stuff.

15            MR. FURR:  What we brought is complying with your

16   request.

17            MS. MOUSER:  Yes, sir.

18            MRS. FURR:  You've asked everything on this.  The

19   only thing you haven't looked at is our bank statements.

20            MS. MOUSER:  And are those your personal bank

21   statements?

22            MRS. FURR:  Those are personal.

23            MS. MOUSER:  I really don't want to look at those.

24   I do appreciate you bringing them.

25            MR. FURR:  Sure.  Yeah.



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 1            MS. MOUSER:  And I hope that didn't cause you a

 2   great deal of inconvenience.

 3        Let me ask you this:  I believe the way the settlement

 4   agreement reads, this is it.  One deposition.  And this is

 5   it.  I think that’s what the agreement is.  If the legion --

 6        And maybe, Marc, let me ask you this and you may want to

 7   visit with them.

 8            MR. HONEY:  Uh-huh.

 9            MS. MOUSER:  As I understand the agreement, the

10   legion has no claims any more to the Furrs, as long as the

11   agreement is kept, and right now it appears to be being kept.

12            MR. HONEY:  That’s our understanding, and that's

13   right.

14            MS. MOUSER:  I don't see why we would need to look

15   — are those bank statements for what period of time?

16            MR. HONEY:  Well, you requested from the date of the

17   bankruptcy, you know, currently, and that’s what they

18   prepared and brought.  They basically don't show anything.

19   They don't have anything to hide.  They did show more than

20   they --

21            MS. MOUSER:  Yeah.  I would prefer not to spend our

22   time looking at those.  I'm willing to take Mr. Honey’s word

23   for it.  My question would be, in the future, if my client

24   spanks my hand and said I should have looked through every

25   check, would there be any problem with you asking the Furrs



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   to bring them to your office and I'll just come look through

 2   them.  And I can't imagine they would want to do that.

 3            MR. HONEY:  I would think so.  You know, because we

 4   never know what circumstances will apply in the future, but I

 5   don't anticipate a problem.

 6            MS. MOUSER:  Okay.

 7            MR. HONEY:  Because we have them here available

 8   today.

 9            MS. MOUSER:  But I would prefer not to do that

10   today, to be quite honest.

11            MR. HONEY:  Okay.  That’s fine with us.

12            MRS. FURR:  You see our records.  We tithe.

13            MS. MOUSER:  Sure.  That’s exactly — I feel very

14   comfortable with the answers you-all have given me today.

15   I'm not surprised.  We just kind of had to go through this,

16   and I'm very grateful we're going through this as we are now

17   as opposed to another way.  But I feel very comfortable that

18   you've been very truthful with me.  And I just really don't

19   care to look through them.  They're personal.

20            MRS. FURR:  Utilities.

21            MS. MOUSER:  No.  That’s okay.  I pay them too.  But

22   I do appreciate you.

23        Now, the other documents, that’s all stuff I've got

24   copies of?

25            MRS. FURR:  Everything you asked here except --



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 1            MS. MOUSER:  Is that my list — that’s not my list?

 2            MRS. FURR:  No.

 3            MR. HONEY:  Those are our just responses.

 4            MRS. FURR:  This is --

 5            MS. MOUSER:  Oh, okay.  Okay.

 6            MR. HONEY:  Are we done?

 7            MS. MOUSER:  I think so.  Let me take just a break.

 8                     (A SHORT BREAK WAS TAKEN.)

 9   Q    (By Ms. Mouser)  Mrs. Furr, I believe I've already asked

10   you, but I was looking over some other notes.  And let me

11   just ask again.  Have you ever heard of a Hereford,

12   H-e-r-e-f-o-r-d, Corporation, SA?

13   A    I did just the other day in reading some affidavit from

14   the litigation on something from California.

15   Q    And did — what do you recall about that or do you

16   recall anything?

17   A    No.

18   Q    And then let me ask you, I had been provided this

19   document --

20            MS. MOUSER:  23, I believe.  Let’s go ahead and mark

21   that document as 23.

22          (EXHIBIT NO. 23 WAS MARKED FOR IDENTIFICATION.)

23   Q    (By Ms. Mouser)  And, Mrs. Furr, let me pass that to you

24   through Mr. Honey and ask if you can identify that document.

25   A    Yes.



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 1   Q    I don't know — have any idea what it is.  Can you

 2   enlighten me on that?  Do you know whose handwriting it is?

 3   Do you know where it came from?

 4   A    I don't know where it came from.

 5   Q    Do you know whose handwriting that is?

 6   A    Marcellus.

 7   Q    Do you think that’s Tom Marcellus' handwriting?

 8   A    It looks like expenses to me.  I don't know what it is.

 9   And --

10   Q    Well, let’s back up.  Do you know that’s Tom's

11   handwriting?

12   A    No.  I don't know whose handwriting it is.

13   Q    And do you know — I mean, there’s no identification on

14   it.  It looks like it was used as an exhibit in another

15   proceeding, and that’s all I could tell from it.  And I was

16   wondering if you had seen it before and, if so, knew how it

17   was used.

18   A    No.  I haven't seen it before.

19   Q    Would you mind showing that to Mr. Furr.  We're talking

20   now about Deposition Exhibit 22.

21   A    Marcellus' name.

22   Q    Some of those words I could read and some of them I

23   couldn't, to be quite honest.

24            MS. MOUSER:  Do you recognize that document,

25   Mr. Furr?



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 1            MR. FURR:  No.

 2   Q    (By Ms. Mouser)  And one last question, the documents

 3   that you-all brought with you today, other than your — and

 4   I'll ask you first, Mrs. Furr.  Other than your personal bank

 5   account records, are any of those other documents original

 6   documents?

 7   A    No.  Oh, I think they're original from Tom Marcellus,

 8   which you already have.

 9            MR. FURR:  Yeah.

10   Q    (By Ms. Mouser)  Oh, you mean those letters that he

11   wrote to you?

12   A    Right.  I finally got them back.

13   Q    Where did they go?

14   A    Where?

15   Q    Yes, ma'am.  I mean, you say you got them back.  Who --

16   oh.  From Singleton.

17   A    Yeah.

18   Q    Yes.  From Singleton.

19   A    And I don't — he got them, I guess, from Mr. Ware.

20   Q    Well, there were original letters to you, and you gave

21   them to --

22   A    Because I was asked for them.

23   Q    Yeah.  You gave them to one of your attorneys.

24   A    Right.

25   Q    Who then may have given them to another one of your



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 1   attorneys.

 2   A    Right.

 3   Q    Other than the letters --

 4   A    Some of them are still copies, but I think one of them

 5   or two — well, I think the one that you have a copy of, I

 6   think that was an original.

 7   Q    Can I just briefly look through those to make sure?

 8   We've come all this way.  Let me just briefly look through

 9   those to be sure, and then we'll be done.

10            MR. FURR:  Let me get them back in numerical order.

11            MRS. FURR:  Which one do you want?

12            MS. MOUSER:  Not your bank records.  The other

13   documents that you brought.  Because I think I'm pretty

14   familiar with them.  If there’s something new in there, I'll

15   be able to pick it out pretty quick.

16            MR. HONEY:  She doesn't want to see all of this.

17   This is bankruptcy stuff.

18            MS. MOUSER:  I don't need to see any of the

19   bankruptcy schedules.

20   Q    (By Ms. Mouser)  And for the record, Mrs. Furr, these

21   are the only copies or originals of any records, written

22   documents you have to do with any of the companies we've

23   mentioned today?

24   A    That’s right.

25   Q    The Council on Dangerous Drugs, VIBET --



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 1   A    I never had some of those.

 2   Q    But you have no other documents in your possession or

 3   under your control regarding any of the entities we've

 4   mentioned today?

 5   A    I don't even know what California has.  But I had to

 6   give them some — you know, I don't even know whether I gave

 7   them copies or originals.

 8   Q    You're talking about your attorneys now?

 9   A    Attorneys.

10   Q    And other than your attorneys who have represented you

11   or are representing you — I'm not talking about if they have

12   anything.  But you personally --

13   A    That’s all I have.

14            MS. MOUSER:  What about you, Mr. Furr?  The

15   documents you've brought today --

16            MR. FURR:  We spent two days looking through stuff.

17            MS. MOUSER:  And I appreciate you doing that.  I do

18   appreciate you doing that.

19        Now, some of these things I don't have.  I tell you

20   what, just to kind of speed it all up — I hate to make

21   copies of all that.

22        I tell you what, Marc.  Would you be willing just to

23   make a copy of these things for me?  And I would be glad to

24   — I don't have that.

25              (AN OFF-THE-RECORD DISCUSSION WAS HELD.)



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 1            MS. MOUSER:  Let me ask you about this document.

 2   Let’s go back on the record.

 3   Q    (By Ms. Mouser)  Let me — I'll just kind of turn it

 4   this way.  This appears to be an original that you-all --

 5   that you or Mr. Furr, Mrs. Furr, have put a little Post-it

 6   note on it that says No. 10.  And we'll make a copy of that.

 7   I'm going to turn it like that so we keep it in order that

 8   you have it.  Can you — let’s see.  Let’s leave the Post-it

 9   on it, No. 10, and we'll mark a copy of it.

10        Can you tell me — do you recognize that?  It appears to

11   be an original.

12   A    No.  You have a copy of this.

13   Q    Oh, I do?  I don't remember seeing that.  But anyway,

14   for the record, do you recognize that document?

15   A    Yes.

16   Q    And what is it?

17   A    To F-o-e-t-i-s-c-h in Switzerland.

18   Q    It’s a person or an entity?  What is it?

19            MR. HONEY:  Patrick Foetisch.

20            MS. MOUSER:  Oh, a person.  Okay.

21   A    April the 16th, 1996.  And again, it was by Henry

22   Fischer becoming — having a power of attorney.

23   Q    (By Ms. Mouser)  Uh-huh.  And does that appear — that

24   appears to be an original to me.  Can you tell?

25   A    I don't think so.



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 1            MR. HONEY:  I can't tell.

 2   Q    (By Ms. Mouser)  Does that appear to be a copy of your

 3   signature?

 4   A    It’s a copy of our — Willis' signature.

 5            MS. MOUSER:  And then let me ask you, Mr. Furr --

 6   Q    (By Ms. Mouser)  Oh.  Is Mr. Furr’s signature not on

 7   there?

 8   A    No.  It’s Willis Carto.

 9   Q    And what does that letter purport to do?

10   A    It just says to others that Henry Fischer was a power of

11   attorney.

12   Q    Let me borrow it back for just a second, please, ma'am.

13   A    (Handed.)

14   Q    And when it’s directing Mr. Foetisch in Lausanne to

15   implement the instructions for Mr. Fischer, what instructions

16   did Mr. Fischer get?

17   A    That I do not know.  That was with Mr. Carto, whatever

18   instructions.

19   Q    Let’s turn --

20   A    I only met Mr. Fischer one time.

21   Q    Was Mr. Fischer — was he a lawyer here in this country?

22   A    No.  He wasn't a lawyer.

23   Q    I'm sorry.  Who is Mr. Henry Fischer, F-i-s-c-h-e-r?

24   A    A friend of Mr. Carto’s.

25   Q    Did he travel to Switzerland on behalf of the legion?



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 1   A    He lived over there.

 2   Q    He lived in Europe.  Was he an American citizen?

 3   A    That I don't know.

 4   Q    When did you meet him?

 5   A    Early in the '70s.

 6   Q    And under what circumstances?

 7   A    He came by the office to meet Mr. Carto.

 8   Q    And when it says to Mr. Foetisch, You are respectfully

 9   requested to implement the instructions from Mr. Fischer, you

10   have no idea what those instructions were?

11   A    No, I do not.

12   Q    And then let’s --

13            MS. MOUSER:  I tell you what.  Since this is just a

14   copy, let’s go ahead and mark these.  This would be 24 and

15   25, please, ma'am.

16   (EXHIBITS NOS. 24 AND 25 WERE WAS MARKED FOR IDENTIFICATION.)

17            MS. MOUSER:  Mr. Furr, let me hand you what we've

18   marked as Exhibit 25 and ask you if you can identify that

19   document.

20            MR. FURR:  This is, I believe, a copy of one we've

21   already gave you.

22            MR. HONEY:  It looks familiar.

23            MS. MOUSER: I didn't recognize that letter, but go

24   ahead and identify it for me again, if you have.

25            MR. FURR:  It’s a letter with my signature dated



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 1   March 24, 1994, to --

 2            MR. HONEY:  Well, it’s to Mr. Touboul.

 3            MR. FURR:  — to Mr. Touboul.

 4            MRS. FURR:  You have one.

 5            MS. MOUSER:  And basically is it — basically, what

 6   does that letter purport to do?

 7            MR. FURR:  To let Mr. Touboul know that there’s some

 8   people misrepresenting themselves at the legion trying to

 9   obtain funds from his bank.

10            MS. MOUSER:  Does that letter imply that at the time

11   you signed it, you thought the legion had some money in that

12   bank?

13            MR. FURR:  That implies that, yes.

14            MS. MOUSER:  Do you remember if you ever had

15   personal knowledge that there was ever any money of the

16   legion’s in that bank.

17            MR. FURR:  Never.  I never had any personal

18   knowledge that the legion had any money in any bank.

19            MS. MOUSER:  Okay.  And then let’s mark this

20   document as 26.

21          (EXHIBIT NO. 26 WAS MARKED FOR IDENTIFICATION.)

22   Q    (By Ms. Mouser)  And, Mrs. Furr, I think that’s a letter

23   that evidently Tom Marcellus wrote to you.  I think you

24   referred to it earlier where he resigns.  Would you mind if

25   — just on the first page, he quotes you as saying some



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                        LAVONNE AND LEWIS FURR                 227



 1   things about the money coming out of the Farrell estate.  And

 2   when you get to those quotes, would you please read them out

 3   loud and tell me whether or not you said that?  I think it's

 4   all on that first page of that document.

 5   A    Yeah.  I didn't say exactly like that.  I don't remember

 6   how I said it, but I was under no obligations to be truthful

 7   to him.

 8   Q    Okay.  Let --

 9   A    Because I didn't know what he was getting at, at the

10   time.

11   Q    Yes, ma'am.  If you don't mind, hand it back to me and

12   let me kind of read — or I'll just come over there.

13        I think in the fourth paragraph, Mr. Marcellus in a

14   letter to you dated August 6, '95, says, I'm sure you can

15   recall, LaVonne, that during a telephone conversation of

16   August 1993, I told you about 100,000 in LSF funds that Carto

17   transferred to Liberty Lobby.  You told me that you were not

18   only unaware of such a transfer, but that Carto had no right

19   to the funds because they belonged to LSF.

20        Now, did you ever, in any way, say something like that

21   to Mr. Marcellus?

22   A    Not exactly like that.  I said, Well, I don't know what

23   their — that he transferred us.  You haven't proved to me

24   that he did transfer it.

25   Q    Did you ever know for the legion to have $100,000 to be



                          AMY MILLER, CCR-RPR
               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   transferred?

 2   A    No, I did not.

 3   Q    And then in the next paragraph he says, During that

 4   conversation, you were also made clear that you were — you

 5   also made clear that you were not aware that those funds were

 6   received from the Farrell request or how they were disbursed.

 7   I distinctly remember how angry you became when I told you

 8   that Carto had told me that he had been disbursing the

 9   Farrell estate funds to quote, good causes, end of quote.

10   You responded by saying, quote, He can't do that.  It’s not

11   his money, end of quote.  Did you ever say that?

12   A    I probably did, but I don't remember that.

13   Q    Well --

14   A    And I don't know — I was really upset.

15   Q    What were you upset about?

16   A    Family problems.  That was when I almost had a nervous

17   breakdown.  And I just started crying right away.

18   Q    Well, if it wasn't the Legion’s money, why would you

19   have said that?

20   A    Because I didn't know.  And just like right here, he

21   said that I did not know Henry Fischer.  I met Henry Fischer,

22   but that doesn't mean I know him.

23   Q    Sure.  Sure.  Oh, I agree with that.

24   A    So he turned some of this stuff around.

25   Q    Is Tom Marcellus a revisionist?



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 1   A    I don't know what he is.  He must be.

 2            MR. FURR:  He’s Church of Scientology, if that makes

 3   any difference.

 4   Q    (By Ms. Mouser)  If you said anything close to either of

 5   those comments, it would seem to me that you thought that

 6   some of that money was the legion’s money.

 7   A    No, I didn't.

 8   Q    No?

 9   A    No.  I knew from prior conversations with Willis that

10   some of it would go to the legion, but I didn't know how much

11   or what or any.  I just don't know.  But I didn't know

12   whether he was on a fishing expedition or — you know.

13   Q    Yes, ma'am.

14   A    See, he was still trying to make a clean break.  They

15   wanted me, you know, to come to their side.  I just feel

16   sorry for him.

17   Q    I'm sorry?  Who do you feel sorry for?

18   A    Tom.

19   Q    Tom Marcellus?

20   A    Right.

21   Q    Why would you feel sorry for him?

22   A    I think he’s down the wrong road and how he, you know --

23   and I trusted him.  And I guess I feel sad how he turned and

24   I liked him so much.

25   Q    But you don't know where he is today?



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 1   A    No.  Huh-uh.

 2   Q    The fact that Mr. Carto has agreed to pay a bunch of

 3   money to legion, do you think that that’s an admission of any

 4   kind on Mr. Carto’s part, Mrs. Furr?

 5            MR. HONEY:  I don't really know that that’s an

 6   appropriate question for you to answer.  If you don't want to

 7   answer it, if you want to talk to me about it --

 8   Q    (By Ms. Mouser)  If you have an opinion.

 9   A    I don't have an opinion.

10            MS. MOUSER:  Do you, Mr. Furr?  Do you --

11            MR. FURR:  I didn't understand your question.

12            MS. MOUSER:  The fact that — as part of settlement

13   agreement that Mr. Carto is making — I mean, literally, he's

14   paying millions of dollars back to the legion.  Do you think

15   his agreement to do that is any type of admission on his

16   part?

17            MR. HONEY:  And did you hear my response to that,

18   that I don't know that’s for you to say one way or the other.

19            MR. FURR:  I don't know.  What I would say is --

20   well, never mind.

21            MS. MOUSER:  Never mind.  You are aware he’s agreed

22   to do that?

23            MR. FURR:  Yes.  It’s in the agreement.

24            MS. MOUSER:  Yes, sir.

25   Q    (By Ms. Mouser)  And you're aware of that, Mrs. Furr?



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
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 1   A    I read the agreement.

 2            MS. MOUSER:  Some of these I don't have, but it

 3   appears — and I'm looking now at the documents that you have

 4   brought in.  It appears almost all of them are from people

 5   that either, I understand, continue to be employed by the

 6   legion or in the past.  I'm assuming they're going to have

 7   these documents or copies of these documents.  The only group

 8   I don't have marked is this very first group.  See, some of

 9   these things that are very dated, I don't think I have.

10        Tell you what.  If I just paper clip these, would you

11   mind making copies and just sending them to me?

12            MR. HONEY:  Huh-uh.  And I would prefer to do that

13   also with these that you've marked as Exhibits 25 and 26, we

14   need copies of them today.

15            MS. MOUSER:  Sure.  And the only — for the record,

16   the only original I see are the minutes from the March 8,

17   1996, meeting, which appears on Jason Matthews & Associates

18   letterhead.  And we'll just get a copy of that, and if they

19   want the original, we can get it back.

20            MRS. FURR:  That’s some of his old stationery.

21            MS. MOUSER:  We're concluded.

22        Thank you, Mrs. Furr.  Thank you, Mr. Furr.

23   WHEREUPON, the deposition was concluded at 4:50 p.m., on

24   March 14, 2000.

25                             * * * * *



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               KELSO COURT REPORTING FIRM (501) 661-1515
			
			
                                                               232



 1   STATE OF ARKANSAS

 2   COUNTY OF JEFFERSON

 3                            CERTIFICATE

 4        I, Amy Pope Miller, Certified Court Reporter, Registered
     Professional Reporter and Notary Public in and for the
 5   aforesaid county and state, do hereby certify that the
     witnesses, LAVONNE AND LEWIS FURR, were duly sworn by me
 6   prior to the taking of testimony as to the truth of the
     matters attested to and contained therein; that the testimony
 7   of said witness was taken by me in machine shorthand and was
     thereafter reduced to typewritten form by me or under my
 8   direction and supervision; that the foregoing transcript is a
     true and accurate record of the testimony given to the best
 9   of my understanding and ability.

10        I FURTHER CERTIFY that I am neither counsel for, related
     to, nor employed by any of the parties to the action in which
11   this proceeding was taken; and, further, that I am not a
     relative or employee of any attorney or counsel employed by
12   the parties hereto, nor financially interested, or otherwise,
     in the outcome of this action; and that I have no contract
13   with the parties, attorneys, or persons with an interest in
     the action that affects or has a substantial tendency to
14   affect impartiality, that requires me to relinquish control
     of an original deposition transcript or copies of the
15   transcript before it is certified and delivered to the
     custodial attorney, or that requires me to provide any
16   service not made available to all parties to the action.

17        IN WITNESS THEREOF, I have hereunto set my hand and seal
     this 25th day of March, 2000.
18

19

20                       Amy Pope Miller, CCR, RPR — Notary Public

21
     MY COMMISSION EXPIRES:                    CERTIFICATE NO. 463
22

23

24

25