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I - 125 1 Q.
In Exhibit 9, which is the yearbook that Mr. Stilley 2 chose, look at page 19. Does the personal attitude statement 3 pretty well express the philosophy of
Mountain Park about how 4 these students are to behave? 5 A.
Yes, sir. 6 Q.
Do you have a discipline policy at Mountain Park? 7 A.
Yes, sir. 8 Q.
It says the discipline policy has the goal of giving 9 each student maximum opportunity for
self-discipline. How do 10 you do that? 11 A.
Peer pressure. 12 Q.
Do they have opportunities for correction? 13 A.
Yes, sir. 14 Q.
Okay. And do they have a list of
infractions that end 15 up being sort of the rules of the
road? 16 A.
Yes, sir. 17 Q.
And how do students get to know these rules? 18 A.
They are told these rules for school; no cheating, no 19 lying, no -- 20 Q.
And at the same time that you're enforcing those rules, 21 what's Mountain Park and Palm Lane's
position about their 22 personal maintenance and maintenance
of the areas in which 23 they live? 24 A.
Must be clean. 25 Q.
You have this policy, if you look at page 31 of that
I - 126 1 handbook, every student, for every
student the basic, very 2 basic of Christian character
development begin with the 3 responsibility to maintain their
personal and common areas. 4 Is that part of the philosophy? 5 A.
Yes, sir. 6 Q.
And how do the students do that? Do
they have to work 7 to do that? 8 A.
Yes, sir. 9 Q.
And what do they do? 10 A.
They have to clean the toilets. They
have to clean 11 their laundry. They have to clean their sinks. They have to 12 clean around their bed. They have to make their own bed. 13 They have to wash their own sheets. 14 Q.
Now, explain to the jury what form this cleaning takes. 15 One person doesn't go wash just his
sheets, do they? 16 A.
Oh, no, sir. They have -- every two
weeks we change 17 their duties. There will be a group that does the laundry, a 18 group that does the cleaning of the
bathrooms, a group that 19 does the vacuuming, a group that does
the different chores 20 that we have. 21 Q.
Are those called teams? 22 A.
Yes, sir. 23 Q.
And who are the team -- are there team leaders? 24 A.
Yes, sir. 25 Q.
And where do those team leaders come from?
I - 127 1 A.
They are students that have been with us for awhile and 2 they show there's been a change in
their life and they want 3 to do what's right and they want to
help others. 4 Q.
Now, as the students develop, do they also go to 5 school? 6 A.
Yes, sir. 7 Q.
And at both schools, do you -- what kind of academics 8 do you use? 9 A.
School of Tomorrow. 10 Q.
That's a Christian school, correct? 11 A.
Yes, sir. 12 Q.
Now, in the handbook you also in addition to explaining 13
how that works, you make reference to Landmark Freedom 14 Baptist curriculum. What's that? 15 A.
It's a bible curriculum. 16 Q.
And why is that taught? 17 A.
To teach them the bible. 18
Q. And is that integrated
with the academic program? 19 A.
Yes, sir. 20 Q.
And then it says BEKA curriculum. It
says this 21 material is prepared, distributed
through Pensacola Christian 22 College? 23 A.
Video classes. 24 Q.
And is that for that advanced education? 25 A.
No, sir, it's like Spanish, stuff like that that high
I - 128 1 school students have to have. 2 Q.
So it allows you to have a complete curriculum in 3 Florida and Missouri? 4 A.
Yes, sir. 5 Q.
Now, Mr. Stilley's asked you a lot of things about who 6 got what and things of that nature. You and Pastor Wills 7 take any salary from Palm Lane? 8 A.
No, sir. 9 Q.
Do you take salary from Mountain Park? 10 A.
Yes, sir. 11 Q.
When do you take salary from Mountain Park? 12 A.
When they have the money. 13 Q.
That's not all the time, is it? 14 A.
No, sir. 15 Q.
And the other staff members, inside staff are paid, are 16 they not? 17 A.
Yes, sir. 18 Q.
And some of them, are their houses on Mountain Park? 19 A.
Yes, sir. 20 Q.
Some of them have houses to live in, correct? 21 A. Yes,
sir. 22 Q.
Now, Mountain Park own those houses or those people? 23 A.
Mountain Park. 24 Q.
Now, you indicated that from time to time in addition 25 to cleaning that we've discussed,
students are obligated to
I - 129 1 do other chores. How does that work? 2 A.
Sometimes when -- like at my house I have a house at 3 Mountain Park when I'm up there. And the girls will beg me 4 to let them come over and wash my
windows or sweep my porches 5 off or things like this. They can do chores like that, it's 6 only voluntary like that. 7 Q.
And in the afternoon, let's take the
boys, in the 8 afternoon do the boys have a work or
play period? 9 A.
Sometimes they work and sometimes they play. 10 Q.
What makes the difference? 11 A.
It's according to how much work has to be done. 12 Q.
What's the purpose of the work? 13 A.
To teach them to work. 14 Q.
Is that part of your philosophy of restoring basic life 15 skills so they can reintegrate in the
community? 16 A.
Yes, sir. 17 Q.
Part of the educational process? 18 A.
Yes, sir. 19 Q.
Now, does anybody derive any money benefit from that? 20 A.
No, sir. 21 Q.
I mean, these kids, you don't run them around town and 22 have them stack firewood for other
people, right? 23 A.
No, sir. 24 Q.
Does Mountain Park or Palm Lane make anything for sale? 25 A. No,
sir.
I - 130 1 Q.
You buy and repair equipment or anything like that for 2 resale? 3 A.
No, sir. 4 Q.
Do you make anything that you sell? 5 A.
No, sir. 6 Q.
You run any cows or horses or anything like that at 7 Mountain Park? 8 A.
No, sir. 9 Q.
What about at Palm Lane? 10 A.
No, sir. 11 Q.
You engaged in any business other than saving of the 12 souls? 13 A.
No, sir. 14 Q.
Any business other than trying to bring these troubled 15 youth to the Lord? 16 A.
No, sir. 17
MR. OLIVER: No further questions, Your
Honor. 18
THE COURT: Any redirect? 19
MR. STILLEY: Yes, Your Honor, briefly. 20
REDIRECT EXAMINATION 21 BY MR. STILLEY: 22 Q.
Is there a particular reason on this barbed wire fence 23 that there's barbs sticking out both
directions? 24 A.
I said it was for the safety to keep the girls in. 25 Q.
Is it to keep -- but if the barbs were going both
I - 131 1 directions, you're trying to keep
people from either coming 2 in or going out; isn't that correct? 3 A.
Yes, sir. 4 Q.
How tall is that fence? 5 A.
I'd say eight feet I guess. I wouldn't
know exactly. 6 It's probably more than that. I don't know. 7 Q.
Do the kids ever get out of that fence? 8 A.
Have they every gotten out? 9 Q.
Yes. 10 A.
Mountain Park they have, yes, sir. 11 Q.
How about Palm Lane? 12 A.
No, sir. 13 Q.
You said something about peer pressure? 14 A.
Uh-huh. 15 Q.
What do you mean when you say peer pressure? 16 A.
You have good peer pressure and you have bad peer 17 pressure. You put kids with kids that want to do good and 18 you're going to do good. You put kids with people that want 19 to do bad and they are going to do
bad. 20 Q.
Is that what you mean by peer pressure? 21 A.
That's peer pressure. 22 Q.
Now, you talked about a written set of rules; isn't 23 that correct? 24 A.
In our handbook, yes, sir. 25 Q.
Correct. But the kids don't get a copy
of that, do
I
- 132 1 they? 2 A.
No, sir, but their parents do. 3 Q.
Now, you said that the kids sometimes came and did work 4 for you but they begged to come and
work for you; is that 5 correct? 6 A.
Yes, sir. 7 Q.
Have they ever come and worked for you when they 8 weren't begging or asking you to do
that? 9 A.
No, sir, they are asked do they want to do that. 10 Q.
Are there any negative consequences for not wanting to 11 do that? 12 A.
Oh, no, sir. 13 Q.
How about cows at Palm Lane, do you have any cows at 14 Palm Lane? 15 A.
There are cows at Palm Lane,
but they don't belong to 16 us, they belong to Mr. -- I can't
think of his name right 17 now, the man that is using our land to
produce cows on. 18 Q.
Do you lease your land, your pasture land to this 19 gentleman? 20 A.
No, sir. 21 Q.
What is the arrangement that you have between Palm Lane 22 and the gentleman that has the cows? 23 A.
Verbal. 24 Q.
Okay. What's the terms? 25 A.
He can just use our property.
I - 133 1 Q.
No charge? 2 A.
No charge. 3 Q.
Do you do any upkeep on the pastures? 4 A.
No, sir. 5 Q.
Do the kids have to do any upkeep on the pastures? 6 A.
No, sir. 7 Q.
You positive about that? 8 A.
Yes, sir. 9
MR. STILLEY: Pass the witness. 10
MR. OLIVER: Nothing further, Your
Honor. May she 11 step down? 12
THE COURT: Very well. Thank you, Ms. Wills. You 13 may step down. 14
THE WITNESS: Thank you. 15
THE COURT: Ladies and gentlemen of the
jury, we'll 16 take our afternoon recess at this
time. Recall the 17 admonition. Be prepared to return to the courtroom at ten 18 minutes of four. We'll be out of here by five. Recall the 19 admonition. 20
(Court in recess from 3:28 p.m. until 3:55 p.m.) 21
THE COURT: Good afternoon again,
ladies and 22 gentlemen of the jury. Shall we continue, Mr. Stilley. Go 23 ahead.
Call your next witness. 24
MR. STILLEY: Call plaintiff, Jordan
Blair. 25
THE COURT: Very well. |
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