SECTION I: Answers to questions regarding Directors, Officers and Employees
18 Q. Who
at Trinity Christian Center of
19 Santa Ana, Inc. chooses the officers of that
20 organization?
21 A. The
board of directors.
22 Q. And
who is on the board of directors?
23 A. I
am chairman of the board and president.
24 My wife, Janice Crouch, is vice president and a
25 director. Until just recently, Mr. Norman Juggert, an
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1 attorney in Orange County, California, was our
2 secretary/treasurer, but he has become quite ill and
3 has just recently been forced to resign. And, as
I
4 indicated yesterday, my sister, Ruth Brown, has been
5 added to the board of directors and as an officer.
6 That officership is secretary/treasurer.
7 Q.
Trinity Christian Center of Santa Ana, Inc.
8 loaned money to TBN Productions, Inc. for the making
of
9 The Omega Code movie; is that correct?
10 A. Yes.
11 Q. Who
made the decision to make that loan?
12 A. The
board of directors.
13 Q. Was
there a meeting of the board of
14 directors where that subject was voted upon?
15 A. Yes.
16 Q. When
did that meeting take place?
17 A. I
can't remember.
18 Q. Were
minutes of that meeting taken?
19 A. Yes.
20 Q. Who
took the minutes?
21 A. Either
Mr. Juggert or Mr. Terry Hickey, who
22 is not a director but an assistant secretary and an
23 officer.
24 Q. At
some point, you, Paul Crouch, became the
25 executive producer of The Omega Code film; is that
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1 correct?
2 A.
Yes.
3 Q.
And who made the decision that you would be
4 the executive producer of The Omega Code film?
5 A.
I don't think a decision was even
6 necessary. The entity and/or individual furnishing
the
7 financing is just, according to my understanding in
8 Hollywood standards, is just automatically named the
9 executive producer.
10 Q. Is
Paul Crouch, Jr. an officer of Trinity
11 Christian Center of Santa Ana, Inc.?
12 A. Yes.
13 Q. What
position does he hold?
14 A. It's
either an assistant secretary or an
15 assistant vice president. And I'm not sure. I
don't
16 remember just which.
17 Q. What
duties does he have as an officer of
18 Trinity Christian Center of Santa Ana, Inc.?
19 A. You're
distinguishing that as opposed to
20 being an employee; is that correct?
21 Q. Is
he also an employee?
22 A. Yes.
23 Q. What
is his position as employee?
24 A. He
heads up the IT department, information
25 technology, which generally oversees the Internet, the
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1 computers, the computer programs that facilitate the
2 Internet. He also works in the production area
as a
3 cameraman and does many different duties, really.
4 Q.
Who supervises those duties of Paul Crouch,
5 Jr.?
6
MR. RAWLS: Assumes facts not in
7 evidence.
8
THE WITNESS: Generally speaking, I
9 do.
10 BY MR. QUISENBERRY:
11 Q. What
are his duties as an assistant
12 secretary or whatever his officer position is with
13 Trinity Christian Center of Santa Ana, Inc.?
14 A. Very
little. We have named a few
15 individuals as assistant secretaries primarily just to
16 have a signatory for a document that requires a
17 secretarial signature since many of us travel and
18 sometimes it's difficult to gain one of those
19 signatures.
20 Q. Is
Paul Crouch, Jr. paid for his duties as
21 assistant secretary?
22
MR. RAWLS: Excuse me. That is beyond
23 the scope. So you can answer of your own individual
24 knowledge.
25
THE WITNESS: No one is paid as an
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1 officer of any of the corporations.
2 BY MR. QUISENBERRY:
3 Q.
And is Paul Crouch, Jr. paid as an employee
4 in his position as head of the IT department for
5 Trinity Christian Center of Santa Ana, Inc.?
6
MR. RAWLS: Objection. That is beyond
7 the scope. You are not designated on behalf of
the
8 corporation, but you can answer yes or no if you have
9 any individual knowledge.
10
THE WITNESS: Yes, he is.
11 BY MR. QUISENBERRY:
12 Q. What's
his annual salary?
13
MR. RAWLS: Objection. That is beyond
14 the scope of the deposition notice. It is neither
15 likely to lead to -- it is neither relevant to the
16 subject matter in the action or likely to lead to the
17 discovery of admissible evidence, and it seeks private,
18 confidential financial information about a nonparty to
19 the action, and I'm going to instruct the witness not
20 to answer that question.
21
Well, I'll take that back. If the
22 answer is that you don't know, we can put that on the
23 record. But if you know, I'm instructing you not to
24 reveal that information.
25
THE WITNESS: Oh, I know.
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1
MR. RAWLS: All right. Then I'm
2 instructing you not to answer that question.
3
THE WITNESS: Okay.
4
MR. CASORIA: And as the personal
5 attorney of Mr. Crouch, this is beyond the 30(b)(6)
6 deposition. I'll join in the instruction to him
not to
7 answer, as his personal attorney.
8 BY MR. QUISENBERRY:
9 Q.
Is Matthew Crouch an officer of Trinity
10 Christian Center of Santa Ana, Inc.?
11 A. Yes.
12 Q. What
is his position as an officer of
13 Trinity Christian Center of Santa Ana, Inc.?
14 A. He
is not an employee and only an officer.
15 Q. And
what is his position?
16 A. Again,
only as kind of a signature of last
17 resort if everyone is traveling.
18 Q. Do
you know what his title is?
19 A. Assistant
secretary.
20 Q. Are
there any other relatives of yours that
21 are officers of Trinity Christian Center of Santa Ana,
22 Inc.?
23 A. No.
Other than the ones we've already
24 mentioned.
25 Q. I
understand. Are there any relatives
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1 other than those that we've already mentioned that are
2 employees of Trinity Christian Center of Santa Ana,
3 Inc.?
4 A.
Yes
.
5 Q.
Who?
6 A.
My wife Janice Crouch's sister, Dorothy
7 Casoria, is manager of the Atlanta, Georgia, station.
8 And her other sister, Lori Quinn, is manager of the
9 Miami, Florida, station.
10 Q. Any
others?
11 A. We're
speaking strictly of Trinity
12 Christian Center of Santa Ana now?
13 Q. That's
correct.
14 A. There
are no others. Excuse me. You're
15 speaking of any related employees within Trinity
16 Christian Center of Santa Ana, Inc.?
17 Q. That's
correct.
18 A. Okay.
My sister, Ruth Brown, who is the
19 new secretary/treasurer and director of Trinity
20 Christian Center of Santa Ana. Her husband, Allen
21 Brown, is head of the finance department of Trinity
22 Christian Center of Santa Ana.
23 Q. Any
other relatives of yours that you can
24 think of that are employees of Trinity Christian Center
25 of Santa Ana, Inc.?
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1 A.
No.
2 Q.
Are there any of your relatives that are
3 employees of Trinity Broadcasting Network, Inc.?
4
MR. RAWLS: Objection. It's beyond
5 the scope of this deposition. You can answer of
your
6 own personal knowledge, but you are not designated to
7 answer on behalf of Trinity Christian Center.
8
THE WITNESS: Trinity Broadcasting
9 Network, Inc. has no employees.
10 BY MR. QUISENBERRY:
11 Q. Is
your wife, Jan Crouch, an employee of
12 Trinity Christian Center of Santa Ana, Inc.?
13 A. Yes.
14 Q. What
is her position as an employee?
15 A. Program
director.
16 Q. And
what are her duties in that regard?
17 A. She
oversees the production of several, in
18 fact, all, of the programs that are produced by Trinity
19 Christian Center of Santa Ana, Inc.
20 Q. And
who is her supervisor over those
21 duties?
22
MR. RAWLS: Objection. Assumes facts
23 not in evidence.
24
THE WITNESS: I am.
25 ///
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