1 1 NO. 90-CI-06033 JEFFERSON CIRCUIT COURT DIVISION ONE 2 3 4 JOYCE FENTRESS, et al PLAINTIFFS 5 6 VS TRANSCRIPT_OF_THE_PROCEEDINGS __________ __ ___ ___________ 7 8 9 SHEA COMMUNICATIONS, et al DEFENDANTS 10 11 * * * 12 13 14 FRIDAY, OCTOBER 28, 1994 15 VOLUME XXV 16 17 * * * 18 19 20 21 _____________________________________________________________ REPORTER: JULIA K. McBRIDE 22 Coulter, Shay, McBride & Rice 1221 Starks Building 23 455 South Fourth Avenue Louisville, Kentucky 40202 24 (502) 582-1627 FAX: (502) 587-6299 25 2 1 2 I_N_D_E_X _ _ _ _ _ 3 4 WITNESS: BRENDA_J._CAMP _______ ______ __ ____ 5 By Mr. Stopher........................................... 7 6 * * * 7 8 Hearing in Chambers......................................104 9 Reporter's Certificate...................................106 10 * * * 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 1 2 A_P_P_E_A_R_A_N_C_E_S _ _ _ _ _ _ _ _ _ _ _ 3 4 FOR THE PLAINTIFFS: 5 PAUL L. SMITH Suite 745 6 Campbell Center II 8150 North Central Expressway 7 Dallas, Texas 75206 8 NANCY ZETTLER 1405 West Norwell Lane 9 Schaumburg, Illinois 60193 10 IRVIN D. FOLEY Rubin, Hays & Foley 11 300 South, First Trust Centre Louisville, Kentucky 40202 12 13 FOR THE DEFENDANT: 14 EDWARD H. STOPHER Boehl, Stopher & Graves 15 2300 Providian Center Louisville, Kentucky 40202 16 JOE C. FREEMAN, JR. 17 LAWRENCE J. MYERS Freeman & Hawkins 18 4000 One Peachtree Center 303 Peachtree Street, N.E. 19 Atlanta, Georgia 30308 20 * * * 21 22 23 24 25 4 1 The Transcript of the Proceedings, taken before 2 The Honorable John Potter in the Multipurpose Courtroom, Old 3 Jail Office Building, Louisville, Kentucky, commencing on 4 Friday, October 28, 1994, at approximately 9:05 A.M., said 5 proceedings occurred as follows: 6 7 * * * 8 9 SHERIFF CECIL: All rise. The Honorable Judge 10 John Potter is now presiding. Court is now in session. 11 JUDGE POTTER: Please be seated. Good morning, 12 ladies and gentlemen of the jury. Did anybody have any 13 problems observing the admonition about not letting anybody 14 communicate with you about this case? How about you, Ms. 15 Selby, have you had any difficulty? I'm picking on you to let 16 you know I've learned how to say your name. 17 All right. You-all probably haven't been 18 reading the newspaper, and since this is not a criminal case I 19 think I can mention this. There's an article in this 20 morning's paper that there's been a study that the United 21 States passed a milestone recently. We've got over a million 22 people in the prisons and that doesn't include the 500,000 in 23 the jails. Sometimes I think the prisons are kind of like my 24 garage. I once lived where I had a one-car garage, and I 25 filled it up with lawn mowers and stuff, and I was parking my 5 1 car in the driveway. 2 And then I got another house and it was a 3 two-car garage, and pretty soon I was back to parking my car 4 in the driveway because the lawn mowers and stuff started 5 building up. 6 And then I got a two-car garage with a little 7 room next to it and, you know, pretty soon that filled up and 8 spilled over in the garage and I was back in the driveway. 9 And then I had a carpenter come and put in kind 10 of an attic, where they laid boards over it. When I drove 11 away this morning, there was fog all over my windshield 12 because I'm parked in the driveway again. You know, I can't 13 help but feel that if I took time and kind of managed my 14 affairs a little better I'd be parking my car in the garage 15 instead of out in the street. 16 I kind of wonder if that's not what we do with 17 our prisons. As I say, this is not a criminal case, so I can 18 comment on that. When this is over, I'll chat with you and 19 give you my views about it, but I just wanted you to know we 20 passed that milestone recently. 21 Okay. Mr. Stopher, do you want to call your 22 first witness. 23 MR. STOPHER: Thank you, Your Honor. We'll call 24 Brenda Camp. 25 JUDGE POTTER: Ma'am, would you step up here and 6 1 raise your right hand. That's fine. 2 3 BRENDA CAMP, after first being duly sworn, was 4 examined and testified as follows: 5 6 JUDGE POTTER: Would you walk around and have a 7 seat in the witness box there. Keep your voice up good and 8 loud. 9 And, Marsha, is the brown microphone out? 10 And would you state your name loudly for me, 11 please, and then spell your first and last name. 12 MS. CAMP: Brenda Joyce Camp, B-R-E-N-D-A, and 13 Camp is C-A-M-P. 14 JUDGE POTTER: All right. I can tell that the 15 microphone is not working now for some reason. Will you check 16 it out? Maybe we didn't turn it on this morning. 17 (OFF THE RECORD) 18 JUDGE POTTER: Ladies and gentlemen of the jury, 19 we're going to go ahead, and if for some reason you can't 20 hear, let us know, and we'll take a recess and really try to 21 organize the thing. 22 Ms. Camp, I'll remind you to keep your voice up 23 loud and clear. 24 Mr. Stopher. 25 Q. Ms. Camp, can you hear me all right? 7 1 A. Yes, sir. 2 MR. STOPHER: Can you hear me, Judge? 3 JUDGE POTTER: Yeah, but I'm not getting it over 4 the microphone. Can you-all hear? I'll tell you what. Let's 5 take a five-minute recess. As I've mentioned to you-all 6 before, do not permit anybody to speak to or communicate with 7 you about this case. Do not discuss it among yourselves and 8 do not form or express opinions about it. We'll take a 9 five-minute recess. 10 (RECESS) 11 SHERIFF CECIL: The jury is now entering. All 12 jurors are present. Court is back in session. 13 JUDGE POTTER: Please be seated. I'll remind 14 you you're still under oath and keep your voice up. 15 Mr. Stopher. 16 17 EXAMINATION ___________ 18 19 BY_MR._STOPHER: __ ___ _______ 20 Q. Ms. Camp, would you tell us the city and the 21 state in which you presently live? 22 A. I live in Louisville, Kentucky; Valley Station, 23 Kentucky. 24 Q. And how old are you, please? 25 A. I'm 44. I'll be 45 next Saturday. 8 1 Q. And am I correct, Ms. Camp, that you were 2 married for approximately three years to Joseph Wesbecker? 3 A. Yes. 4 Q. Ms. Camp, let me ask you to go back very briefly 5 and tell us about yourself a bit. How long approximately have 6 you lived in Louisville? 7 A. Since I was born. I lived in Cleveland, Ohio, 8 for two years; other than that, Kentucky the whole time. 9 Q. And did you go to school in this area? 10 A. No. My ex-husband -- my first ex-husband went 11 to podiatric school there. 12 Q. In Cleveland? 13 A. Yes, sir. 14 Q. I made my question unclear, to you at least. 15 Did you attend school in Louisville? 16 A. Yes, sir. 17 Q. And did you go to high school here? 18 A. Yes, sir. 19 Q. And where did you go to high school? 20 A. Valley High School. 21 Q. Ms. Camp, after you got out of high school, what 22 did you do? 23 A. I went to beauty school and high school at the 24 same time, and I went to work as soon as I got out of high 25 school. 9 1 Q. And are you a cosmetologist or connected with a 2 beauty school in Kentucky? 3 A. Yes, sir. I teach at a beauty school and I work 4 in a salon. 5 Q. Do you get licensed as a beautician or a 6 cosmetologist? 7 A. Yes, sir. 8 Q. Now, approximately when did you first get 9 married? 10 A. In my first marriage? 11 Q. Yes, ma'am. 12 A. I married in 1969. 13 Q. And who was your husband? 14 A. Doctor William Thomas Beasley. 15 Q. And approximately how long were you married to 16 him, Ms. Camp? 17 A. Twelve years. A few months short of twelve 18 years. 19 Q. So about 1981 or thereabouts; is that about 20 right? 21 A. 1980 is when we divorced, February of 1980. 22 Q. All right. And I think you told us earlier that 23 he attended, while you were married to him, I believe, a 24 school for podiatrists or foot doctors in Cleveland, did I 25 understand correctly? 10 1 A. Yes. 2 Q. And is that his occupation or was that his 3 occupation? 4 A. It still is. He's a podiatrist. 5 Q. While you were married to Doctor Beasley, did 6 you have children with him? 7 A. Yes, sir. 8 Q. And how many children did you have? 9 A. One daughter and one son. 10 Q. What is the daughter's name, Ms. Camp? 11 A. Melissa Beasley. 12 Q. And about when was she born? 13 A. 1970. 14 Q. And the son, his name again was? 15 A. Chris. 16 Q. Chris. And about when was he born? 17 A. 1976. 18 Q. Now, if I understand correctly, you were married 19 to Mr. Wesbecker from approximately 1981, am I correct about 20 that? 21 A. August of '81 till November of '84. 22 Q. And did that marriage end in divorce? 23 A. Yes. 24 Q. Have you married since then? 25 A. I remarried in eighty -- I remarried in '91, 11 1 October of '91. 2 Q. And are you still married? 3 A. Yes, sir. 4 Q. And what is your husband's name? 5 A. Daniel King. 6 Q. And you're going by the name of Camp, Brenda 7 Camp? 8 A. Yes, sir. I will keep my birthright name. 9 Q. Is that your -- what's sometimes called your 10 maiden name? 11 A. That is my maiden name. 12 Q. All right. Now, Ms. Camp, are you employed at 13 the present time? 14 A. Yes, sir. 15 Q. And where do you work? 16 A. Roy's of Louisville, St. Matthews school. 17 Q. And what type work do you do there? 18 A. Teach cosmetology. 19 Q. Now, Ms. Camp, let me go back to the early 20 1980s, and let me ask you to tell us when and under what 21 circumstances you first met Joseph Wesbecker. 22 A. I met him at Parents Without Partners. 23 Q. And what is Parents Without Partners? 24 A. It's an organization for divorced people or 25 widowed people with children. 12 1 Q. And what sort of an occasion did you meet him in 2 connection with that organization? 3 A. They have, like, meeting you go to when you 4 first join and then they have dances and they have trips you 5 can go on with your children, just all kinds of different 6 things. The night we met was like a normal dance-type night. 7 Q. Do you recall when that dance-type night was 8 that you met him? 9 A. It was the Friday before Thanksgiving of 1980. 10 Q. So that would be sometime in November of 1980? 11 A. It was the weekend before Thanksgiving. 12 Q. Ms. Camp, how did your relationship then with 13 him develop after that first meeting? 14 A. We began to date about three weeks later, 15 continued to date. 16 Q. Were you separated or divorced from Doctor 17 Beasley at that time? 18 A. I divorced -- my divorce was final in February 19 of 1980, and I met Joe, November of 1980. 20 Q. And were your children living -- you had two 21 children at that time. Were they living with you or with 22 Doctor Beasley? 23 A. They were living with me. 24 Q. And were you living in the home where you lived 25 with Doctor Beasley and your two children? 13 1 A. Yes, sir. 2 Q. Now, when you began to date Mr. Wesbecker, do 3 you recall where he was living at that time? 4 A. He was living in a house on Mount Holyoke in 5 Wilkie Heights subdivision. 6 Q. And was he married at that time? 7 A. No. He was single. 8 Q. When you began to date him in late 1980, would 9 you be with him alone or would you be with other people, or 10 how were the relationships at that time? 11 A. We did both. We went out with other groups of 12 people in PWP and, you know, we went out with couples and we 13 went out alone. 14 Q. Did he at that time before you got married 15 introduce you to his children? 16 A. Of course. 17 Q. And you knew that he had two sons? 18 A. I knew the night we first met because we talked 19 a lot about both of our children. 20 Q. Did he tell you where he worked? 21 A. The first night, yes; we discussed all of that. 22 Q. And did he give you information about his 23 family, mother, father, that sort of thing? 24 A. Not the first night. Later on. 25 Q. All right. In -- prior to the marriage, did he 14 1 give you any information about his background and his history 2 as to where he came from and what his life story had been? 3 A. I mean, he talked about his children; he talked 4 about his family, you know, mother, grandmother; talked about 5 work a lot, talked about -- basically that's what he talked 6 about. 7 Q. All right. Prior to the marriage, did he talk 8 about his mother? 9 A. Yes. I mean, I would see her and the 10 relationship was good then. 11 Q. All right. And what about his two sons? Did he 12 talk about them and his relationship with them before the 13 marriage? 14 A. Of course. I wouldn't marry somebody and become 15 their stepmother that I didn't meet their children and have an 16 active role. 17 Q. And did he talk about his grandmother? 18 A. He loved her. He constantly -- that's who he 19 was the closest to. 20 Q. Do you remember her name? 21 A. I just always called her Grandma Montgomery. 22 Q. Did he tell you why he was so close to her? 23 A. Yes, sir. 24 Q. Would you tell us about that? 25 A. He told me that she mostly raised him; that if 15 1 it hadn't been for her he don't know what his life would have 2 been like. He enjoyed growing up with her raising him. 3 Q. Did -- prior to the marriage to Mr. Wesbecker, 4 did he talk about your ex-husband, Doctor Beasley? 5 A. No. He was kind about that in the beginning. I 6 was coming through having more problems and going through a 7 lot as just beginning to have divorced, you know, the first 8 year after you divorce. I talked more about it and was going 9 through more stress than he was. So he didn't talk a lot in 10 the beginning. I was having more coping problems. 11 Q. All right. Now, you told us earlier and I think 12 I wrote down the -- you married in August of 1981? 13 A. August the 11th of 1981. 14 Q. And did his mother come to the wedding? 15 A. No. We married privately. 16 Q. And were his sons there? 17 A. No. We married in Indiana, in a house, and we 18 only told approximately about six people we were even getting 19 married. 20 Q. Now, Ms. Camp, in those early years in 19 -- the 21 early 1980s, did he talk about money and his finances at all? 22 A. I mean, he talked about he enjoyed work; that he 23 felt he was paid fairly. He talked about, you know, he always 24 wanted to make sure he paid his child support on time. He 25 always wanted to give his children more -- more than he had. 16 1 So if you're talking finances that way, I mean, that's how he 2 talked about it. 3 Q. Did he talk about working overtime and that sort 4 of thing? 5 A. Yes, sir. 6 Q. What did he have to say about that? 7 A. He just always wanted to work overtime to make 8 sure he could save money, to make sure that he was never 9 needy, because he always thought in his childhood, you know, 10 he struggled with that. He wanted to give his children a lot. 11 Q. Before you and he married, was there an 12 agreement about money? 13 A. We had a prenuptial contract before we married. 14 Q. Let me show you a copy of a document that's been 15 marked as Defendant's Exhibit 253, and ask you if you can 16 identify this document for us, please. 17 A. This is the prenuptial contract that we drew up 18 prior to getting married. 19 Q. And it is apparently dated August 9, 1981? 20 A. Yes, sir. 21 Q. This contract, without reading the precise 22 language of it, basically provides that he kept his money and 23 you kept your money? 24 A. Yes, sir. 25 MR. STOPHER: Your Honor, we would move for the 17 1 admission of Defendant's Exhibit 253 and ask that it be 2 published to the jury. 3 JUDGE POTTER: Be admitted. 4 SHERIFF CECIL: (Hands document to jurors). 5 Q. Ms. Camp, after that agreement was signed and 6 during the marriage, did he ever mix his money with yours? 7 A. No, sir; other than we gave each other gifts. 8 But this was as much my choice as his, due to what went on in 9 my first marriage. We both agreed to that totally. 10 Q. Did you keep a joint checking account with him? 11 A. No, sir. We mixed nothing whatsoever. 12 Q. He had his money, paid what he wanted to pay, 13 and you did the same? 14 A. Yes, sir. 15 Q. Now, Ms. Camp, during the three years, then, 16 that you were married to him, approximately -- first of all, 17 did you move in with him after the marriage? 18 A. I moved in with him before the marriage. 19 Q. And was that at a home on Mount Holyoke? 20 A. Yes, sir. 21 Q. Was that his home? 22 A. That was his home. 23 Q. And did your two children move in with him at 24 that time, also? 25 A. Yes, sir. My home was going into foreclosure 18 1 and I would have either moved in with my parents because I 2 didn't have the money to move at that time, so... 3 Q. And your children were, what, 11 and about -- 4 A. Well, my daughter was born in 1970. She was ten 5 years old and my son was four years old at that time. 6 Q. And were either one of Mr. Wesbecker's sons 7 living in that home with the three of you or the four of you? 8 A. No, sir. They come on visitation. They lived 9 with his ex-wife, Sue. 10 Q. Now, after the marriage, did you learn that 11 Kevin Wesbecker had a spinal problem, a scoliosis of the 12 spine? 13 A. I knew before the marriage. 14 Q. Did you ever hear Mr. Wesbecker, Joseph 15 Wesbecker, talk about that problem? 16 A. Yes, sir. 17 Q. What did he have to say about it? 18 A. In the beginning, he felt like Kevin was born 19 that way and -- he felt like he was born that way, you know. 20 Later, he wanted Kevin to have surgery to correct that 21 problem, and Kevin never did have the surgery. 22 Q. And did that change some of Mr. Wesbecker's 23 ideas about Kevin and his condition? 24 A. At the time he wanted him to have the surgery, 25 they were starting to grow apart, so I guess that attributed 19 1 to it. 2 Q. What were his ideas later about Kevin's 3 condition? 4 A. The scoliosis? 5 Q. Yes, ma'am. 6 A. He felt he should have had the surgery to live a 7 better life and he felt, because he didn't, that he most 8 definitely needed a college education. 9 Q. Did he have any ideas or make any statements as 10 to why his son had that condition? 11 A. He said he felt when him and Susie first got 12 married that he felt like Susie didn't eat properly and, 13 quote, he said he didn't think she took good enough care of 14 herself when she was pregnant. 15 Q. And did he think that caused the problem in 16 Kevin? 17 A. I mean, I can only speak with what he said. 18 Q. Yes, ma'am. 19 A. I mean, these are the things he would say to me. 20 Q. Did he ever blame or find fault with any other 21 situation that he thought contributed or caused Kevin's 22 scoliosis or spinal problem? 23 A. Not that he said to me. 24 Q. When you began or when you were married to Joe 25 Wesbecker those three years, approximately, did you become 20 1 aware that his other son, James, or Jimmy, had a problem? 2 A. I knew before the marriage -- well, not right -- 3 about the same time we married, right about the marriage and a 4 few months after, I knew of the other problem. 5 Q. How did you first learn about that? 6 A. Thinking back, you know, it kind of happened -- 7 I would say Kevin talked with his father. I don't know. I 8 wasn't always involved when his ex-wife and him talked, so I 9 don't know if his ex-wife told him first or Kevin told him 10 first. 11 Q. And it's your recollection that Kevin told Joe 12 Wesbecker that Jimmy had a problem with exhibiting? 13 A. That's the first I knew of it. 14 Q. All right. How did he take that news from 15 Kevin? 16 A. He wanted Jimmy watched more closely. He wanted 17 Jimmy with a baby-sitter at all times when he come home from 18 school. He wanted Susie to let him have Jimmy more. Just 19 more supervision and to get him help immediately. 20 Q. Did you ever hear him later say what he thought 21 caused or may have caused Jimmy's problem? 22 A. Probably the four things he mentioned to me was 23 not enough supervision; he thought that Kevin should be 24 watching him more, which I always told him I didn't think it 25 was an older child's place to baby-sit a younger brother. Joe 21 1 went over a few times to his ex-wife's house, and he said he 2 would find Jimmy unsupervised. He would say Kevin was 3 supposed to be watching him, but Kevin wasn't there, is what 4 Joe was saying. I'm not there, so I can only talk from 5 hearsay. He just felt like he was lied to sometimes by his 6 oldest son and his ex-wife. He felt like he was kept in the 7 dark about the situation; not always, but sometimes. 8 Q. Did he ever assign any other blame or cause for 9 Jimmy's problem? 10 A. You know, it's hard to say. Those are probably 11 the main reasons. Maybe he blamed his and his first wife's 12 divorce; that he felt like as an absentee father that he 13 wasn't there. I think he always lived with the guilt thinking 14 that if he had been there he could have done something, you 15 know. But even in divorce he was active in his children's 16 lives so, I mean, that's the best I can, you know, figure. 17 Q. Ms. Camp, during that marriage or perhaps even 18 before or after, I'm not certain, did you ever hear him talk 19 about his childhood? 20 A. I mean, he talked explicit about his childhood 21 with me. 22 Q. What statements do you recall that he made about 23 growing up? 24 A. His father had fallen off St. James' roof had an 25 impact on him; losing his grandfather around the same time, 22 1 living in the projects, having to drop out of school, working 2 in factory work. He always said a factory owned you; that if 3 you didn't save your money you could lose your job. Ask me 4 the question again. 5 Q. All right. Did he ever mention while he was 6 living in the projects anything about Murrell Wesbecker? 7 A. Yeah. I can't honestly remember. Was that his 8 grandmother? 9 Q. That's my understanding. 10 A. He said when he was a child she used to baby-sit 11 him and he was extremely close to her, and he remembers them 12 coming to get her. He blamed his mother and he blamed a 13 relative of hers, I can't remember who it was, and I don't 14 want to say wrong under oath. It was one of Martha's 15 relatives, that they wanted her money. And she was admitted, 16 I believe, into Central State until she died there, and that 17 had an impact on him as a child. He remembers seeing them 18 come and get her, and at that point -- you know, I'm not 19 there, I can only talk from what the man's saying. He said he 20 remembers being taken into I guess you would say custody, and 21 he said he remembered not having anyone watch him the rest of 22 the afternoon after they put her in the car. And I think that 23 always horrified him. I mean, he talked about it till he 24 died, so... 25 Q. Did he ever mention his attitude or ideas about 23 1 Central State Hospital or mental institutions in general? 2 A. He always made sure he paid his insurance. He 3 always made sure he took his medicine. He had a fear of being 4 put in a place like that. You know, the two times I had him 5 put in the hospital probably one of his greatest fears was 6 declining mentally and spending the rest of his life in a 7 place like Central State or Our Lady of Peace or whatever. 8 So, I mean, if you say talk about it, he always said it would 9 be better to be dead than to remain the rest of your life in a 10 place like that. 11 Q. Ms. Camp, about the time of the marriage in that 12 early time with him, did you ever hear him talk about your 13 ex-husband, Doctor Beasley? 14 A. You know, to bring up my divorce and my 15 relationship with my ex-husband, my divorce was a very 16 devastating, hard divorce. Joe was a friend to me in the 17 beginning when I was going through a lot with child support, 18 with moving back in with my parents, with not having a car to 19 drive, with trying to work two jobs to support my children, 20 you know, he'd come into a nightmare with me when I was going 21 through my divorce. I was already divorced, but I was still 22 going through trouble after it. 23 Q. Did Joe Wesbecker ever talk about Doctor Beasley 24 and what he thought of him? 25 A. In the beginning, Joe didn't talk a whole lot 24 1 about him because I tried not to bother him with the problems. 2 I didn't think it was fair to a second husband to talk about a 3 17-year relationship with another man, but you kind of do. It 4 kind of comes up in quiet time. He tried to help me with my 5 kids. He couldn't have been a nicer man the first -- we dated 6 and lived together a year before we married, from November to 7 August, and if it hadn't have been for him, I don't know how I 8 would have made it. I'm okay. 9 Q. All right. I understand that none of this is 10 easy for you, and, Ms. Camp, you can take a sip of water 11 and... 12 JUDGE POTTER: If you'd like to take a recess, 13 ma'am, just tell me. 14 THE WITNESS: No, I'm fine. I'll just go on 15 through. 16 Q. Did his attitude and his statements about Doctor 17 Beasley change over the years? 18 A. When my home was going through foreclosure, I 19 had two children and no car, I borrowed my father's station 20 wagon. My father loaned me money. They stamped foreclosure 21 on my home and I didn't ever want to remarry. So Joe offered 22 me his home. I didn't want to put my parents through -- they 23 had been through enough in my marriage. So he offered me his 24 home on Mount Holyoke and I agreed to live with him. My 25 ex-husband started suing me for custody of my two children 25 1 because I lived with a man, so Joe kept on feeding us, helping 2 me, he even said he would move out of that home. I went into 3 custody battle over my two children, so my ex-husband put a 4 social worker on me because I lived with a man. And he did 5 nothing but help the first three years. My children loved 6 him. 7 I went on and decided to marry him not just for 8 that reason but I was torn between -- I don't think that's a 9 good environment to raise your children up living with a man, 10 so we agreed to marry each other, you know. I contacted my 11 attorney, some attorney said that's ground to take your 12 children away and some attorney says it wasn't. So Joe and I 13 was friends. We married as friends and we remained friends 14 till he died. That's basically what we had, friendship. 15 Q. Ms. Camp, did Joe Wesbecker ever talk about 16 wanting to do any harm to Doctor Beasley? 17 A. Yes. He threatened to kill him. He threatened 18 to kill him approximately three times. One time during our 19 marriage, and he threatened to kill him about two years -- I 20 mean, we went back to dating and living together in 1985, so 21 verbally I would say -- recollection under the pressure of 22 everything -- he threatened to kill him probably three times. 23 Q. Did he ever talk about how he was going to do 24 that? 25 A. Yes. He said one time he would wait at his 26 1 Southern Parkway office and when he left the office he would 2 roll down the window and blow his brains out when he left the 3 medical practice. The other time he said he passed him on 4 Dixie Highway. He said, "It would be so easy for me to roll 5 the window down and blow his brains out." That was about two 6 years prior to Standard Gravure and him dying. 7 Q. Did you -- during the marriage did he ever 8 threaten or harm you in any way? 9 A. Joe never, ever hit me. He was never violent. 10 The only form of abuse, he would become extremely quiet and 11 recluse. He might go three weeks without talking to you. He 12 might get in his car and leave. He might shade the windows 13 down on the house and tell you not to come in. When he 14 attempted suicide on his life two times, you locked yourself 15 in another bedroom and you knew, he would prewarn you, not to 16 come around him. So I would sleep at a friend's house or he 17 would tell me it was okay for me to lock the other bedroom and 18 leave before he got up and don't come home until he's in bed. 19 So I lived under that at Mount Holyoke and I lived under that 20 at Nottoway. 21 Q. Ms. Camp, if I understand correctly, you 22 divorced him in 1984; am I right about that? 23 A. Our divorce was final -- because we had no 24 children and a prenuptial contract, we used the same attorney, 25 and our divorce was final -- we filed -- it was final on my 27 1 birthday, November the 5th, 1984. 2 Q. And let me show you Defendant's Exhibit 295, I 3 believe. Excuse me, 301. This purports to be a 4 dissolution -- decree of dissolution of marriage between 5 Joseph T. Wesbecker and Brenda Joyce Wesbecker dated November 6 5, 1984, which is your birthday? 7 A. Yes, sir. 8 MR. STOPHER: Your Honor, we ask that 9 Defendant's Exhibit 301 be filed and be published to the jury. 10 JUDGE POTTER: Be admitted. 11 SHERIFF CECIL: (Hands document to jurors). 12 Q. Ms. Camp, why did you want to divorce Joe 13 Wesbecker in 1984? 14 A. I stayed with my first now ex-husband too long, 15 and it become bitter, and after the end of my first marriage, 16 I had learned a lot. I said if it couldn't be a cordial 17 relationship, if it couldn't be workable, you should leave 18 before it becomes bitter. So when we could no longer mix our 19 children, when Joe would go through times that he did not want 20 you around him, I did not want to be married to a man that if 21 he ended up in a mental hospital I could not get a divorce. I 22 had gone through enough in my first marriage that at the end 23 of my second marriage, I did not want to spend every weekend 24 of my life going to a mental hospital if Joe didn't make it, 25 as he declined mentally with mental illness. 28 1 He lied to me and I didn't know he had been ill 2 prior to us meeting at Parents Without Partners, but I had 3 already married him. We did not say traditional wedding vows 4 when we married. I said to him as long as I could remain his 5 friend, trust him, be a good companion, I'd remain married. 6 When I could no longer do that, I could no longer cope with 7 having my children around him when he wouldn't speak, the 8 emotional impact; I could no longer be around that man who 9 wanted to murder the father of my children, I felt if I just 10 went away, it would be okay. I would still date him. I would 11 still check on him. I always remained his friend; I just 12 would no longer be his wife. 13 I thought for safety, my children did not need 14 to be around that. After he threatened to kill my daughter, 15 that was enough, on a New Year's Eve night and I walked 16 Bardstown Road. My daughter is the closest thing to me. So 17 after he threatens to kill my ex-husband, after he threatens 18 to kill my daughter, I think I've had enough. So I asked for 19 a divorce, and I promised him I would always remain his friend 20 and I got my divorce. 21 Q. Ms. Camp, let me ask you about his relationship 22 with your daughter, Melissa. I take it from what you've 23 already told us that before the marriage and shortly after the 24 marriage that he was good to her? 25 A. Yes, sir. 29 1 Q. Would you explain to us how that went from that 2 time forward? 3 A. When we first met, he was very good to both of 4 my children. My son is hyperactive. He's diagnosed that way. 5 He went to Meredith-Dunn special needs school, so it put a lot 6 of stress. My ex-husband and I have handled our 18-year-old 7 son with a lot of education and a lot of love and a lot of 8 nurturing, and I thank my ex-husband for that and I thank 9 myself for that. So in having a child like that it can place 10 stress at times. My son's doing fine now but... So that 11 placed stress on Joe that he didn't need along with his son 12 James. When I was in therapy to help my own son, they told me 13 it is not good with a boy that has exposure problems to have a 14 young boy around him. So I am faced -- the Doctor told me, 15 you know, I'm faced that I do not need to mix all that. So 16 the situation between Joe and my daughter, Melissa, begin to 17 deteriorate because, Number One, my daughter and I are 18 extremely close and still are. Joe was somewhat jealous of 19 that relationship because it was normal and it was healthy. 20 If I know something, my daughter knows something. We're 21 extremely close. I just thought if I divide all that, I'll 22 conquer it and everybody -- I kept looking for normality. I 23 thought I'd make everybody happy. Due to my daughter's 24 closeness to me, when Joe would put her through not talking to 25 me for two or three weeks, she would come home from an 30 1 environment -- I don't think it's good to raise children 2 around a mentally-ill person. I don't think it's healthy to 3 raise children around -- I didn't have no children by the man, 4 so I didn't see why I had to stay. 5 Q. Was there ever a time that he said that he 6 didn't want to speak to your young daughter, Melissa? 7 A. He didn't speak to her the last five years he 8 lived. On Thanksgiving, we ate in separate rooms of the 9 house. On Christmas, we did not exchange gifts. He did not 10 acknowledge my daughter the last five years he lived. 11 Q. She was just a young girl? 12 A. Well, he cared about her the first two years. 13 He said, "I don't have to put up with her, I don't have to 14 look at her, I don't have to do anything for her." He grew 15 bitter because my ex-husband did not come and get the children 16 on visitation; he went about nine months without even seeing 17 them. He become bitter because my ex-husband did not pick up 18 the children every other weekend and on Wednesday nights. He 19 become bitter because I had my children all the time. He 20 become bitter because it cost him money. He become bitter 21 because he had to help me with legal bills because my 22 ex-husband was suing me. He become bitter because my children 23 lived in his house. And I just thought if I didn't live there 24 and my children didn't live there, he'd get well. And I 25 wanted more than anything for him to get better as a friend, 31 1 and I just couldn't see putting any more stress on him. 2 Q. Ms. Camp, you mentioned that on one occasion he 3 threatened to kill your daughter? 4 A. On New Year's Eve. 5 Q. Do you recall which New Year's Eve that was? 6 A. Wait a minute. We went back to living together 7 in August of 1985. I would say it was New Year's -- I'm close 8 -- 1987. 9 Q. Where did that occur? Would you tell us the 10 circumstances? 11 A. Bardstown Road. We went out to dinner and was 12 going to a movie for New Year's Eve. And my daughter is a 13 real cordial -- I'm not bragging on her because she's my kid, 14 but, you know, I guess you reminisce and get sentimental on 15 New Year's Eve. And I always told Joe, "I speak to your son, 16 I speak" -- he didn't speak to Kevin the last I guess -- that 17 always -- and he wouldn't speak to Martha, that was my 18 mother-in-law. And I was forbidden to speak to her, too, or 19 Kevin. So I'd go to things, family activities even after we 20 divorced to see her. Melissa still made attempts to speak to 21 the man. She did it thinking she could make a difference. 22 She just couldn't see where that wasn't okay. So in making 23 attempts to speak to him on Christmas or New Year's Eve or 24 whatever, she went through enough with having a mother that's 25 divorced twice, so she just couldn't foresee it. On the day 32 1 we put his cremains, she carried them. In the bizarre moment, 2 she said, "Mom, I just have to carry them." So I guess she 3 was looking for normality, too, and there wasn't any. 4 Q. On the New Year's Eve you had had dinner with 5 him, was it just the two of you? 6 A. Just the two of us. 7 Q. And were you in the car? 8 A. Yes. 9 Q. And you were going on Bardstown Road? 10 A. To go to the movies at the Cinemas. 11 Q. How did it come up? 12 A. He always liked to talk about stopping at 13 stoplights and blowing somebody's brains out at stoplights. 14 He had an infatuation with stoplights; why, I don't know. But 15 that stoplight right beside Steak N Shake, he looked right at 16 me and said, "You know, it would be easy for me -- same 17 figment of speech -- to blow your daughter's brains out, and 18 then I wouldn't have to look at her. I wouldn't have to see 19 her and I wouldn't have to be jealous of yours and her 20 relationship." So I hit him. I got out of the car and I 21 walked Bardstown Road at about -- I don't know -- 10:30 at 22 night. We didn't go to no movies. 23 Q. Ms. Camp, had your daughter ever done anything 24 to incite him or to make him -- 25 A. No, sir. 33 1 Q. Or to deserve that kind of -- 2 A. No, sir. Nobody deserves that. No one deserves 3 to die like that. 4 Q. Ms. Camp, did his relationship with Kevin change 5 during the 1980s from what it had been before you married 6 until later? 7 A. When Joe and I met, Kevin was always my favorite 8 kid of Joe's, too. I loved him. Couldn't have been a finer 9 young man. The last time I seen him is after Joe died, I 10 called both boys and I wanted to see them a final time. So I 11 had them over at my father's home where I now live, and I went 12 through things and gave them things. And I used to tell Joe, 13 "It's not right to speak to your mother and it's not right to 14 not speak to your son." So I'd drive by Little Caesar's 15 sometimes just to look at him, and I'd sit in my car and I'd 16 think, "I'm going to hug him and see him." He was always my 17 favorite. 18 So after Joe killed hisself, I gave them the 19 things I thought -- that were still stored in boxes, and I 20 asked my new husband to go with me to the house across from 21 Zayre's on Dixie Highway and to take his bed and his TV and 22 pictures and clothes. I waited awhile because I didn't get 23 into the stuff myself for six months to a year. I just wasn't 24 up to it. I had the stuff stored in a garage. You know, and 25 I hugged Kevin. And I told him maybe some day in the future, 34 1 you know, I could speak to him or see him. But I've went on, 2 tried to, with my life for the sake of my children, my 3 ex-husband, my own reputation, just to get through it the 4 best. So, you know, I guess that answers it. 5 Q. Did he stop speaking to Kevin? 6 A. Yes. He disinherited him. He was mad at him 7 because he didn't have the surgery on scoliosis. He did not 8 like the woman Kevin married. He did not like -- he always 9 blamed Kevin. He didn't think he did enough for his younger 10 brother. 11 Q. He didn't think Kevin did enough for Jimmy? 12 A. Which I don't think it's any child's place to 13 raise another child. I disagreed. Of course, I was the 14 stepmother, and if I didn't say what Joe wanted to hear -- 15 which I asked for a vasectomy when we first married because I 16 did not want children by him and I most definitely did not 17 want an accident where I got pregnant by the man. He didn't 18 speak to him at all. 19 Q. Let me show you a copy of Defendant's Exhibit 20 255. Do you recognize this, Ms. Camp, as the -- or a will of 21 Joseph Wesbecker? And it's dated on the last page, I 22 believe -- next-to-last page February 14, 1984, so that would 23 be about 10 or 11 months or thereabouts before the divorce; 24 right? 25 A. Let's see. We divorced November the 5th of 35 1 1984, so -- 2 Q. Yes, ma'am. 3 A. -- yeah. 4 Q. So this would be during the marriage and near 5 the end of the marriage? 6 A. Yes, sir. 7 MR. STOPHER: Would you take a look at -- first 8 of all, Your Honor, I'd like to introduce this exhibit and 9 have it published for the jury. 10 JUDGE POTTER: Be admitted. 11 JUROR HIGGS: Your Honor, may I -- have you got 12 an extra 301? I've got two 253s. 13 JUDGE POTTER: Swap him out, Madame Judge. 14 JUROR HIGGS: Thank you. 15 SHERIFF CECIL: (Hands document to jurors). 16 Q. Ms. Camp, on the first page of this document 17 under Item Number Two, it says, "I have a son by the name of 18 Joseph Kevin Wesbecker and I do not wish to bequeath or devise 19 him any property from my estate." Did he discuss this with 20 you and why he wanted to disinherit his son? 21 A. It's like I've said in the other questions, he 22 just -- I can't understand that in the first place as a parent 23 myself, so I don't guess I could totally understand that. 24 That's the best I'd know to answer it. He was mad at Kevin 25 for not completing college. Kevin dropped out of school and 36 1 didn't tell his dad. So I guess -- you can't look for 2 normality here, so... 3 Q. Ms. Camp, did he during the 1980s, keep a good 4 relationship with his mother or what sort of relationship did 5 he have with her? 6 A. He wasn't happy growing up. I think he blamed 7 her for a lot of things, but I used to always say, "Just 8 forget it, you know, and go on." 9 Q. What sorts of things did he blame his mother 10 for? 11 A. He blamed her and said she went through 12 insurance money and Social Security money when his father was 13 accidentally killed on the roof and fell. He blamed her 14 that -- he said he was left. He blamed her for saying he had 15 to live in projects when he shouldn't have had to. He blamed 16 her for putting him in an orphanage. He blamed her and said 17 that he grew up a hard childhood because she mismanaged -- I 18 don't know. I wasn't there. He said his father died with 19 insurance money. They were only married I guess a year or two 20 before the man died and Joe was the only baby born. So I 21 guess he just blamed -- he used to make the saying he would 22 just pack him a brown paper bag and he'd just leave and he'd 23 never come back, and he used to laugh about it, and he said 24 anywhere would be better than with her. 25 Q. Speaking of his mother? 37 1 A. (Nods head affirmatively). He used to say, 2 "I'll just pack," and I remember -- because he used to always 3 brown-bag it to work, he used to just -- and he always had a 4 sense of humor, so he would just say, "I'll just get lost and 5 never find." And he'd make me ride through the projects with 6 him and he'd tell me how it was when him and Sue first got 7 married. And I'd try to be a good listener and he always used 8 to say he didn't want -- he always had the fear -- he never 9 wanted to be at anybody's mercy again. I guess that answers 10 it. 11 Q. What did he mean by the statement he didn't want 12 to be at anybody's mercy again? 13 A. He always blamed not getting to -- he was so 14 proud of his GED. He even toted some of his books. He made 15 me look back through all them when he got his GED. And I 16 guess with a sense of humor and a good person up to what he 17 did that morning, I guess you could say -- I don't know, I 18 never totally knew the man, either, but he just -- he always 19 had a fear -- he knew he had relatives with mental illness. I 20 met the one that Grandma Montgomery took care of. I don't 21 even remember his name now, but at wedding receptions and at 22 Christmas things -- I don't remember which son it was; you-all 23 have it in documents, but he was schizophrenic. Joe used to 24 always go up and hug him and shake his hand. And Nancy had a 25 handicapped son that's in a wheelchair or walks with a walker. 38 1 I don't remember all these names. I was only married to Joe 2 for three years and dated him for a year. 3 But Joe always had a fear of losing his health. 4 He always had a fear of declining mentally. He always had a 5 fear of the power of money, that if you didn't have it other 6 people would control you. He always felt like he could have 7 been a brilliant man if he had got to complete school, and it 8 was evident that -- I don't know what his I.Q. was and I don't 9 know that that even matters, but he accomplished a lot for a 10 man with a GED, and he was always a hard worker, you know. 11 Q. Ms. Camp, did he ever talk about death to you? 12 A. Yes. 13 Q. What did he say? 14 A. In the beginning when we first met, he was a 15 very happy person. I didn't know he had had a mental -- I 16 read things, and in my depositions and in reading the paper 17 myself I've learned things that helps me go on, I guess, 18 because a lot of things I didn't know. You know, in the 19 beginning, I think he thought there was hope for him. He was 20 always good about taking his medicine. He was good about not 21 drinking alcohol. He was good about going to work. He was 22 good when he didn't feel good that he tried to not bother 23 other people with it; he'd just go off to hisself. So I guess 24 the deterioration started -- severe deterioration I'd guess is 25 1987, is when I would say it started to where he was no longer 39 1 happy, you know, it just wasn't the same. 2 Q. Did he ever talk about death or your death? 3 A. Yeah. He asked me how I'd like to die. 4 Q. What prompted that? 5 A. Well, he always had a humanitarian sense of 6 humor. He had a morbid sense of humor. He had an infatuation 7 with death. He didn't fear it. One morning I woke up, I 8 guess it was a Thursday morning, it was a pretty morning, we 9 lived on Nottoway, and I remember waking up, and I remember 10 him beside me. He tapped me like that and said, "How would 11 you like to die today?" So I laughed it off, got up and 12 brushed my teeth, washed my face, got ready to go to work, and 13 I thought, "He just asked me how would I like to die today." 14 I said, "Oh, well, he must have watched a horror movie." I 15 mean, I'm brushing my teeth thinking, how would I like to die 16 today. 17 So I walked back in the bedroom -- I kept my 18 clothes -- we slept a lot of times and lived in separate parts 19 of that house. So I got dressed, proceeded on to work. And 20 my exact answer to him was, "Not this week, it's pay week. 21 No, thank you," and I just ignored him. 22 Q. Did he ever talk about his own death? 23 A. He tried to kill hisself right after we married. 24 He tried to kill hisself a second time, both times when we 25 lived in Mount Holyoke. First time, carbon monoxide, but we 40 1 didn't -- there's a misprint in the newspaper. We didn't have 2 a garage at that house, and when I read the newspaper it said 3 a garage. The house on Mount Holyoke does not have a garage; 4 if it had a garage he might have succeeded. 5 MR. SMITH: May we approach the bench, Your 6 Honor? 7 (BENCH DISCUSSION) 8 MR. SMITH: I don't know if it's possible, but 9 if this Witness could be cautioned not to talk about and not 10 criticize the newspaper coverage I think that would be helpful 11 since the jury has been instructed not to read the paper. 12 JUDGE POTTER: Okay. But I think she's talking 13 about something that was published four or five years ago when 14 this first came out. 15 Anyway, Mr. Stopher, why don't you go another 10 16 or 15 minutes and we'll take a break. I'll let you pick the 17 spot. 18 (BENCH DISCUSSION CONCLUDED) 19 Q. Ms. Camp, with regard to that first suicide 20 attempt, if I understand correctly, you were married at the 21 time to him? 22 A. Yes. Wait a minute. We were living together. 23 Q. All right. On Mount Holyoke; am I right? 24 A. (Nods head affirmatively). 25 Q. How did this come about, this suicide attempt? 41 1 A. I didn't know it was going to happen. I went to 2 bed. What woke me up was duct tape being shredded. I was 3 sleeping in a separate bedroom from him. We didn't always 4 sleep together. 5 Q. Why was that? 6 A. I just didn't always like him. I didn't always 7 agree with what he did. 8 Q. So you woke up hearing -- 9 A. Duct tape in the living room and the car 10 running. And I thought, "Somebody is here at about 2:00 in 11 the morning, I'd best get up." So in this little house you 12 could look out that bedroom and see the driveway, and his 13 black Oldsmobile was running. And I thought, "Something's not 14 right." And then I thought, "I'm not going out there." So I 15 stayed locked in the bedroom and I kept hearing duct tape. If 16 you've ever pulled duct tape -- I ddon't know what it was at 17 that moment, but I did after I found him. He's pulling duct 18 tape. 19 So I let a couple hours go by. I have to go to 20 a hair show in Indianapolis that weekend. It's a Saturday 21 night, because my kids weren't there; they had gone to see 22 their father. So I think, "I'll just doze back off. 23 Everything's okay. He's just working on something." So I let 24 a couple hours go by and I go, "No, he's not working on 25 something; what's he working on. The car's running." 42 1 So I get up -- see, that was a misprint; there 2 was no garage. I was not sleeping beside him, either, I was 3 in the other bedroom. I went in and he was in the hallway on 4 the floor bleeding on the mouth, duct tape all masked around 5 him. I carried him in and put him in the bed, drug him in 6 there and laid him up and called his psychiatrist, Doctor -- I 7 had just met him; I think it was Doctor Hayes I think is the 8 name. It was 1980. It's hard to remember. 9 But I don't like what the psychiatrist told me. 10 He said it didn't matter because we weren't married. I said, 11 "Get me some help." Still to this day it infuriates me. And 12 I said, "I need some help." So he wouldn't talk to me because 13 in society, like I've said in my depositions, they said I 14 didn't matter because I just lived with the man. I said, "It 15 don't matter if I'm his next-door neighbor. Give me some 16 help." 17 So he went on into the hospital -- it was either 18 '80, it's hard to remember. You-all probably have it; you-all 19 find things for me. So that was the first time he went in for 20 mental illness. So then the cold reality hits me, "I'm 21 married to a mentally-ill person. So that was the first 22 attempt. 23 Q. Ms. Camp, did he give you any warning at all 24 that he was going to do that? 25 A. No, sir. None. You couldn't tell. 43 1 Q. Was there anything about him before he did that 2 that was different -- 3 A. No. 4 Q. -- in any way? 5 A. No. 6 Q. Did he leave a note or anything like that? 7 A. No. Nothing. It would be nicer if he would. 8 Q. Did he ever after the fact explain to you why he 9 had attempted to take his own life? 10 A. Nope. He was a private person and he didn't 11 think he owed people explanations. He wasn't the kind of 12 human being that he felt like he owed anybody an explanation. 13 MR. STOPHER: Your Honor, I think this would be 14 a good time to take a break. 15 JUDGE POTTER: Okay. 16 Ladies and gentlemen of the jury, we'll take our 17 morning recess. As I've mentioned to you-all before, do not 18 permit anybody to talk to you about this case; do not discuss 19 it among yourselves; and do not form or express opinions about 20 it. We'll stand in recess for 15 minutes. 21 (RECESS) 22 SHERIFF CECIL: The jury is now entering. All 23 jurors are present. Court is back in session. 24 JUDGE POTTER: Ma'am, I'll remind you you're 25 still under oath. 44 1 Mr. Stopher. 2 Q. Ms. Camp, with regard to that suicide attempt 3 that you were talking about just a moment ago, if I understand 4 correctly, it was about 2:00 in the morning and you heard the 5 sounds that you described, and you went out eventually to 6 another room or to a hallway. Did I understand correctly? 7 A. Yes. 8 Q. What exactly did you find when you got there 9 with regard to him? What was the situation? 10 A. Joe was between the hallway and the bedroom. 11 Q. And how was he situated? Was he on the floor 12 or -- 13 A. Floor. 14 Q. And did you see the tape? 15 A. (Nods head affirmatively). 16 Q. Where was the tape? 17 A. All over him. 18 Q. What was connected to the tape? 19 A. I don't remember anything connected. I can't 20 remember hose. I just remember -- and the shock of it, of 21 seeing duct tape all over him and his mouth kind of bleeding, 22 and I don't remember anything else. 23 Q. You mentioned that there was an automobile, I 24 think you said a black Oldsmobile that was running? 25 A. That was his car. 45 1 Q. And was it running outside in the driveway? 2 A. Yes. 3 Q. Was there a hose connected to the automobile or 4 to the tape? 5 A. Later, there was a hose outside the window 6 coming down. 7 Q. On that occasion did I understand you to say 8 that he would not go to the hospital and there was some 9 difficulty about getting him admitted because you weren't 10 married; is that -- 11 A. Yes, sir. 12 Q. All right. Ms. Camp, would you tell us about 13 the second suicide attempt. 14 A. I had a real nice -- this was about -- because I 15 moved out in '84, I left him and moved out, moved in an 16 apartment on Bardstown Road. I come home from work, I had a 17 real nice lady that lived -- I don't remember her name now; 18 it's been almost ten years, and she tried to help him. Her 19 husband's in a wheelchair. 20 And I come driving down Mount Holyoke and he was 21 running up and down the road. I said, "Oh, my God, it's Joe." 22 He's running up and down the road. I go, "Oh, my God." And 23 he was out of his head and he's banging on my car. And I pull 24 in the driveway and I'm, like, "Oh, Lord." And he had beat 25 the front door at the house. He had tore up stuff in the 46 1 living room. He had tore stuff out of his wallet. He had 2 threw stuff out of the cabinet. He was delirious like he 3 didn't know where he was at, and the thing that kept being on 4 his mind -- when I could finally get him back in the house, I 5 said, "Settle down." He was talking out of his head, like, I 6 can't even remember, like, you know, "Where am I," just kept 7 running up and down the road. I said, "Get in the house." 8 And the only way I could get him settled down was to talk 9 about work. 10 This was about, oh, I don't know, five-thirty, 11 six, because I leave work -- I was at the Dixie campus then 12 and I could get home in about ten minutes, so I leave there at 13 five, so it must have been about quarter after five. And I'm, 14 like, "Get in the house." And the only way I could ration 15 with him, he kept saying, "Call work, I'm going to be late." 16 I said, "Okay, Joe, I'll call work." 17 "Call work." 18 I said, "I'll put you on the phone." 19 He said, "Oh, no, you tell them. Call work." 20 I'm like, "Oh, God." And I don't know the work 21 number, so I could get him to dial, and he was delirious. 22 I finally got him settled down. He wouldn't let 23 me leave him. I said, "I've got to go." I'm lying to him to 24 get to Dixie Manor to get to a pay telephone to call a close 25 friend. I said, "What do I do." They said, "Call EMS." I 47 1 said, "Okay. That's the answer." 2 So I leave him locked in the house half asleep 3 in the chair, and I think, "He won't let me use the phone in 4 the house, I'll go to Dixie Manor." That's real close. So I 5 call EMS. They're there in about 20 or 25 minutes, and I try 6 to talk to them out in the yard. I said, "Get him to the 7 hospital." He lied his way out of it. He didn't go. I said, 8 "Go to the hospital, Joe." He wouldn't go to the hospital. 9 And I said, "Go." 10 Then he becomes mean with me. So then he's 11 threatening to me: "I'm got going. You're not going to put 12 me there." 13 I said, "Joe, you need to go to the hospital." 14 "I'm not going." This went on and on and on. 15 So I stay in the other bedroom again. I don't 16 know what he does. After he settles down, EMS takes his vital 17 signs, you know, he won't go in against his will. I couldn't 18 get him to go. He had overdosed on pills. Either he had 19 saved up some of his medicine -- I seen over-the-counter stuff 20 ripped and tore, like No Doz and all kinds of different things 21 in the kitchen, he had ripped the tops off of them. Funny 22 things. Left water running. Just bizarre, crazy things. And 23 I'm going in and I'm going, my God, driver's license threw 24 over here. You know, well, you can imagine what a house looks 25 like. 48 1 So I went to my next-door neighbor. She said, 2 "Brenda" -- I said, "How long has he been running up and down 3 the road? Why didn't you call me at work?" She said, you 4 know, "I don't know." She said, "Who knows why people don't 5 help other people. I don't know." 6 So after I get him settled down, you know, he 7 won't go. EMS tries to take him. So we just don't speak; we 8 stay away from each other. He's mad at me because I'm trying 9 to put him back in the hospital began. So evidently -- I 10 don't know how many pills the man took. They didn't take him 11 on. They couldn't do blood tests or whatever they would have 12 done because he wouldn't go. He stayed locked in the house, 13 and I proceeded to clean it up over a two- or three-day 14 period, and that was probably near to when I'm about to leave. 15 It's about '84. 16 Q. When you said that he had stuff all over the 17 house -- 18 A. Toilet paper just -- I mean, I don't know how 19 else to describe it. Rolls of toilet paper hanging from the 20 kitchen thing. Stuff threw. I don't know if he even knew. 21 He kept hollering about his keys. "Where's my keys, Brenda?" 22 I said, "Joe, your keys are in your pocket." So he couldn't 23 get in the house, and in his mind he couldn't find his keys. 24 I said, "You're not driving." What was on his mind at that 25 moment was his keys and getting to work and worrying about 49 1 being late to work, and that stayed after -- I don't know, 2 maybe he thought he lost his keys is why he tore the house up. 3 I don't know. 4 Q. Did -- on that occasion, did you stay there that 5 night? 6 A. Yes. I slept -- we slept separate for three 7 days. 8 Q. And did you stay in behind a locked door that 9 night? 10 A. Yes. 11 Q. Ms. Camp, if I understand correctly, after the 12 divorce, you and he would occasionally be together? I think 13 you said earlier this morning that you remained friends. 14 A. (Nods head affirmatively). 15 Q. Would you from time to time live with him or he 16 with you, or how was the relationship after the divorce? 17 A. I moved out -- let me think. Did I move out 18 before the divorce or after? I honestly can't remember, 19 everything was so chaotic. Wait a minute. I moved out. That 20 was the about the end of it, with the house being tore up and 21 all that and trying. And, let's see. If '84 my divorce was 22 final, I moved out before the weather got bad. I moved out -- 23 I guess I moved out -- well, Autumn Run Apartments on 24 Bardstown Road would have my lease. I don't really remember 25 with everything, but I moved in those apartments, and we 50 1 didn't live together at all. And I think I lived there either 2 a year or eighteen months separate, by myself. I lived there 3 by myself. 4 Q. So if you moved out in about '84 -- 5 A. It was still decent to move, before cold weather 6 come. I think it was the end of summer. 7 Q. All right. Did you ever move back into Nottoway 8 and live with him for any -- 9 A. I moved in Nottoway. He bought the house in 10 summer of '85. We moved in that house in August of '85, the 11 following year. 12 Q. All right. And you weren't married but you 13 lived with him? 14 A. I would have never married him again. 15 Q. But did you live with him there at his house on 16 Nottoway? 17 A. Yes, sir. He asked me to go back. We dated, 18 and I agreed to go back to living with him. 19 Q. You mentioned that you wouldn't marry him again 20 but that you did agree to be friends and to go back dating him 21 and even living with him. Was it a love relationship or what 22 was the reason that you did this? 23 A. When I first met him he was a wonderful type of 24 person: happy, loved work, loved people, did charity work, 25 couldn't have met a nicer person. Three or four years later, 51 1 you know, he started changing. But like I've said in my 2 deposition, you wouldn't leave a person that was in a 3 wheelchair. Mental illness is as cruel as physical illness. 4 I never leave nothing till I have to and then I don't totally 5 leave it. That's what's got me in a lot of trouble in my 6 life. I never chose to ever -- I'm surprised I'm remarried 7 now. I said I'd never remarry after the end of my first 8 marriage, but I don't want my children to grow up in a house 9 where you say we live together and I don't want my future 10 grandchildren someday to say -- I don't think society -- I 11 don't disagree with living together, but that's not what I 12 want to teach my children and my grandchildren of the future. 13 So our relationship was, I thought I could make 14 a difference. I thought I could help him get well. I thought 15 I could see that he took his medicine. I thought I could make 16 him love living again. I was a dear friend with him. I 17 thought I could fill the gaps in, if that makes sense. It 18 wouldn't matter if it was mental ilness; it wouldn't matter if 19 it was physical illness; it wouldn't matter what it was. When 20 you marry somebody you make those vows, in sickness and in 21 health, you know. 22 Q. Now, after you moved back in with him in '85, he 23 had a house there on Nottoway; correct? 24 A. He bought the house asking me if I would go back 25 to living with him. He would help me get a home; he would 52 1 help me get a better car. And I remember him coming to my 2 apartment saying, "Brenda, if you'll go back to dating me I 3 will help you get a better car." He said, "And I will get us 4 a decent home to live in." He didn't like me living in 5 apartments, and my car -- he always hated to see as a single 6 parent -- by then I had changed custody of my children. I had 7 relinquished custody to my ex-husband. We have primary and 8 secondary custody to where then I did not move my children 9 back in it, I went by myself and I had visitation of my 10 children. 11 Q. When he was living there on Nottoway, did you 12 begin to hear him talk about work and Standard Gravure and 13 what he thought about work in the mid to late '80s? 14 A. He was still happy with work. He enjoyed 15 working. You know, I think he was an excellent employee. I 16 used to meet him downtown at night because he'd just punch in 17 as I just punched out, and I'd park my car and go to dinner 18 with him at S & H Bar. I'd go down there and sit on the reels 19 and he'd sneak me in so I could see him, because we worked 20 total different shifts. And I'd be scared walking back out by 21 The Jam Factory, but I wanted to see him so bad I'd go. So he 22 was still happy and, like I say, I think the deterioration 23 started in '87. 24 Q. What happened then with regard to his attitude 25 toward work? 53 1 A. He made me help him write letters of different 2 men. The morning that it happened I didn't ask for a search 3 warrant, I just let them go through the house and, you know, 4 there was nothing to hide and, you know, go through everything 5 and take their time. And he couldn't see real well, you know. 6 I would drive him to jail to visit his son downtown, and I 7 would help him write because his eyesight never was real good. 8 So he would start -- he first asked for help from Pat Lampton, 9 which was the company doctor, and I went with him to I think 10 two of those sessions. 11 Q. Now, this is Pat Lampton? 12 A. I think he was Standard Gravure's doctor or 13 sociologist or somebody. I don't really know. I went with 14 him twice. He started asking them to take him off of the 15 folder, to not run the reel or whatever that means. I'd just 16 meet him for dinner and sit there. He started calling human 17 resources asking for help, and his biggest thing he wanted was 18 to be taken off of a less-stressful job so he could continue 19 to work. That's what he would come home saying to me at 20 Nottoway. And he'd get off -- he'd go in at five or go in at 21 one or two or if he worked a double. And the agitation 22 started, I can remember him saying, you know, "Men will come 23 in drinking and men will come in worse off than me and they'll 24 give them a lighter load." And I can remember him saying, 25 "You know, I've been a good employee and I" -- and you can 54 1 tease people, you might say, you know, just quote -- I'm 2 saying this myself. You might walk up to somebody and tell 3 them they're fat and you might walk up to somebody and say you 4 drive an old car and you start making fun of them. I guess 5 the kind of thing is to not make fun of people. But I can 6 remember walking in the plant and some of them would make fun 7 of him. And they'd say vulgarities to me. My father is 8 self-employed; my ex-husband's a doctor. I'm not used to 9 factory lingo, so it would shock me sometimes as a lady. And 10 we'd go in and eat dinner and I'd never think anything about 11 it, and he'd come home and -- saying things that he was 12 called. He'd say, "They put me back up on the reel. I've 13 asked not to be up there as long." 14 So beyond that, that's the best way I can answer 15 that. I helped him write letters. I talked to the social 16 worker when he went on disability. I helped him write the 17 letters. I think writing helped him vent angers. Those 18 letters that were found, that was in my handwriting because he 19 couldn't write real well. And I guess they always say when 20 you're angry, write, it helps you. I don't know. 21 Q. You mentioned Pat Lampton a moment ago. What 22 sorts of things when you were in the meetings would he tell 23 Pat Lampton? 24 A. I didn't -- I guess I sat there. I didn't stay. 25 I'd get up a few times and let them talk because I think 55 1 that's a privacy thing. I'm not the kind of person that butts 2 into other people's business. I think Joe was trying to tell 3 him how he was being treated at work. I think he was trying 4 to vent some of his anger. I think with handicapped people, I 5 guess Joe lived in the illusion of thinking because he was 6 handicapped that that made a difference. You know, in society 7 we're building ramps. In society we're changing it for 8 handicapped, but I guess society don't realize mental illness 9 is as great a handicap as a physical illness. 10 So as he pleaded for help that he was an ill man 11 and he asked for less, it wasn't given to him. And as he 12 deteriorated, you know, he would write and he would ask, and 13 he went every avenue. Joe was an intelligent man. He took 14 his medicine like he should; he went to doctors like he 15 should; he went to work like he should; he was a wonderful 16 ex-husband. He was a husband and ex-husband for me. I don't 17 know any more he could have really did. 18 Q. Did he ever get relief at Standard Gravure? 19 A. He never was happy from about '86 on. '87, you 20 know, it progressively got worse. 21 Q. Let me show you a document that's been marked as 22 Defendant's Exhibit 289. 23 MR. SMITH: Can we approach the bench, Your 24 Honor? 25 JUDGE POTTER: Uh-huh. 56 1 (BENCH DISCUSSION) 2 MR. SMITH: These are apparently forms from the 3 Department of Labor that would be hearsay to these Plaintiffs. 4 There's no connecting this Witness to these forms. 5 JUDGE POTTER: She's going to say she filled 6 them out for him; right? 7 MR. STOPHER: Right. 8 JUDGE POTTER: Okay. Objection is overruled. 9 (BENCH DISCUSSION CONCLUDED) 10 Q. Ms. Camp, can you help us identify this 11 document? It's a multipage document. Have you had a chance 12 to briefly look through it? 13 A. It's my handwriting. It's my handwriting on the 14 second page. It's just like I told you, I'd help him write 15 things. It's my handwriting on the third page. Yeah, it's 16 when he was beginning to file complaints. 17 MR. STOPHER: Your Honor, we move the admission 18 of Defendant's Exhibit 289 and ask that it be published to the 19 jury. 20 JUDGE POTTER: Well, I mean, be admitted. 21 SHERIFF CECIL: (Hands document to jurors). 22 MR. SMITH: Can we approach the bench again, 23 Your Honor? 24 (BENCH DISCUSSION) 25 MR. SMITH: How is the fact that this woman 57 1 filled this out get over the hearsay objection to these 2 Plaintiffs? 3 JUDGE POTTER: I really thought Mr. Stopher was 4 going to ask this lady what this thing was, not just if it's 5 her handwriting. 6 MR. STOPHER: I'm going to ask her now what it 7 is and how it came into being. 8 MR. SMITH: It's still hearsay, Your Honor, to 9 the Plaintiffs. 10 MR. STOPHER: This is this man's thoughts that 11 were written down. 12 JUDGE POTTER: I think it's been introduced to 13 show acts he took and things he did and things he said about 14 himself and to show his condition and state of mind. You're 15 right, it is hearsay, but I think it comes in under the 16 exception. We've testified about him saying various things; 17 that he's going to kill somebody or do something like that, so 18 I think this is in that category. 19 (BENCH DISCUSSION CONCLUDED) 20 Q. Ms. Camp, you indicated just a moment ago that 21 some or -- some of this document is in your handwriting. Did 22 I understand correctly? 23 A. Yes, sir. 24 Q. How is it that your handwriting is on this 25 document? 58 1 A. Joe would ask me to write for him because he 2 didn't spell real well and he didn't like to be embarrassed on 3 things. He'd want me to spell for him and he would want me to 4 write it because he felt my penmanship was better than his. 5 Q. Are these his statements and words or are they 6 yours? 7 A. He would read it to me -- he would talk to me 8 and I would write it. And I can't do shorthand or anything 9 like that, so he would talk to me and I would write what he's 10 telling me, and I'd go back and rewrite it for him. 11 Q. Ms. Camp, would you take a look at the -- I 12 believe it's the third page. Is that your handwriting on that 13 page and on the following page? 14 A. Yes, sir. 15 Q. I apologize to you and to everyone else for the 16 quality of this copy. It is difficult to read. It is the 17 best that we have been able to do with what's available. Let 18 me ask you, if I attempt to read it, would you correct me if I 19 misread anything or if you have a question about it? 20 A. If I can remember it, too, it's been... 21 Q. All right. Let me begin there on the line. 22 First of all, let me back up. Apparently the date of this 23 document, I believe if you look at the page that's numbered at 24 the bottom right-hand corner, Wesbecker Estate 030470, and 25 it's the next-to-last page, it looks like his signature is on 59 1 there. 2 A. That's his handwriting. 3 Q. And then it appears to me that the date is 4 10-2-87, October 2, 1987, out beside his name? 5 A. (Nods head affirmatively). 6 Q. Does that appear -- 7 A. Correct. 8 Q. All right. Now, let's go back to Page 3, if we 9 can, and let me read this and, Ms. Camp, if I get anything 10 wrong, would you please stop me and interrupt me? 11 A. Yeah. 12 Q. It says, "I am a manic depressive and have been 13 about ten years. My company makes me man in charge or second 14 man. I have asked them to take me off because of my illness. 15 They" -- 16 A. They won't. 17 Q. It looks like, "They would laugh" -- 18 A. Yeah. They would -- yeah. They would laugh. 19 Q. -- "and make fun of me. They tell me I can do 20 it and don't want to hear it." Does that appear accurate to 21 you? 22 A. Correct. 23 Q. "My treatment has been under the care of five 24 different doctors. I have tried --" 25 A. Suicide. 60 1 Q. "-- suicide. My -- on my life -- may times or 2 many times"? 3 A. Many times. 4 Q. "My company has a Doctor, Doctor T. Patrick 5 Lampton. I have been to him for this problem. He refers me 6 to Doctor Moore. Doctor Moore called Donald Cox. They 7 discussed my problem," and it looks like letter to the -- 8 A. He wanted Pat Lampton to promise he would not 9 take it to the foremans when he's conversing with me and I'm 10 writing this for him. He wanted -- he felt like he had been 11 betrayed because he wanted Pat Lampton to not divulge 12 confidentially what he talked about. And he felt like since 13 it was Pat Lampton that he told, that he went and told the 14 foremans, and then Joe thought they made it even harder on 15 him. 16 Q. "They still put me on the folder after the call, 17 and the letter" -- his last name now or how? 18 A. I can't... And the letter has last name. I 19 don't know what he meant by that, either, now this many years 20 later. 21 Q. All right. "Another letter had to be written. 22 Donald Cox said that he can put me in charge of a press 23 without the folder. If I can't do it, he will fire me. Close 24 has to do this -- no one else has to do this." Is that right? 25 A. (Nods head affirmatively). 61 1 Q. "They should treat me the same as anyone else, 2 not any better or any worse. I take Lithobid, 300 milligrams. 3 I take 600 milligrams in morning, 600 milligrams in evening." 4 Can't read the rest of those. And then it appears there's a 5 list of doctors here and company doctor, Pat Lampton; Human 6 Relations Commission, Dan Mattingly. Manic depressive 7 self-help group, Our Lady of Peace self-help group, and then 8 signed by him on 10-2 or perhaps 10-7-87; correct? 9 A. Correct. 10 Q. Let me show you another document that's been 11 marked as Defendant's Exhibit 259. Can you help us identify 12 this document, Ms. Camp? 13 A. Let me read it a minute. I can't remember who 14 Ms. Sweat was. Wait a minute. Maybe something in here will 15 help me. He called OSHA, occupational safety on toluene. I 16 don't know if this woman is associated with that or I don't 17 know -- she may be -- '88. I don't know -- wait a minute. 18 (Reviews document) This may be the woman -- this may be the 19 woman as he was coming to the conclusion he would be disabled. 20 This could be what he had me write him -- at the bottom I've 21 got address, phone, signed. This was either the woman with 22 human resources or this was either the woman with Social 23 Security when he went on -- when he ended up not working 24 anymore and went on Social Security disability. I mean, 25 that's to my best knowledge. 62 1 Q. All right. Is this your handwriting again? 2 A. This is my handwriting, also. 3 MR. STOPHER: Your Honor, we move the admission 4 of Defendant's Exhibit 259 and ask that it be published to the 5 jury. 6 JUDGE POTTER: Be admitted. 7 SHERIFF CECIL: (Hands document to jurors). 8 Q. Ms. Camp, let me attempt to read this and, again 9 -- and this one is clearer, I will agree, but if I misstate 10 anything or misread anything, you correct me. Was the 11 procedure on this the same, are these his words and you're 12 doing the writing? 13 A. Yes, sir. 14 Q. All right. It's apparently dated May 31, 1988. 15 A. (Nods head affirmatively). 16 Q. It says, "Dear Ms. Sweat: This letter so in 17 regard to the phone call I made to you" -- or, is in regard to 18 the phone call I made to you. "I work for Standard Gravure. 19 I am a manic depressive. My company makes me work the folder; 20 I am not able to because of my handicap. I tried to talk to 21 company doctor, Pat Lampton. He didn't help because he told 22 the company everything we talked about. I filed a complaint 23 with the federal government May 13, 1987. The woman I talked 24 to, Ms. Robertson, she referred me to human resources. Dan 25 Mattingly is the man I talked to. He told me to file with USA 63 1 Labor Department. They turned me down first time. They said 2 Standard Gravure didn't have a federal contract. We did have 3 one with Army Air Force Book. Ms. Kirby said I didn't file it 4 at that time. I found a copy with the federal government. I 5 refiled because I found the papers. Ms. Kirby said I have to 6 have the contract number for Army Air Force work." Is that 7 the way this appears to you? 8 A. Yes, sir. 9 Q. Let me show you a document that is dated in 10 August of 1989, Exhibit -- Defendant's Exhibit 265. Ms. Camp, 11 do you recognize this document? 12 A. Yes, sir. 13 Q. Is this also in your handwriting? 14 A. Yes, sir. 15 Q. And is it also an item that was written pursuant 16 to the words of Joe Wesbecker but you wrote it down? 17 A. Yes, sir. 18 MR. STOPHER: Your Honor, we move the admission 19 of Defendant's Exhibit 265 and ask that it be published to the 20 jury. 21 JUDGE POTTER: Be admitted. 22 SHERIFF CECIL: (Hands document to jurors). 23 Q. Ms. Camp, this document has a date up at the top 24 of 8-9-88, August 9, 1988. Is that in your handwriting? 25 A. Yes, sir. 64 1 Q. Is that the date on which this document was 2 written? 3 A. I always date everything I do. 4 Q. All right. So the date would be accurate as to 5 when it was written? 6 A. Yes. 7 Q. Let me again try to read this and let me ask you 8 to do two things with regard to this document. If you -- if I 9 misread anything, any of the words written here, would you 10 please correct me? And the second request I have of you is, 11 is that if you remember anything that he told you about any of 12 the things that are written down here that go beyond what's 13 actually written here, would you tell us what additionally you 14 remember? 15 A. (Nods head affirmatively). 16 Q. Fair enough? 17 A. Yes, sir. 18 Q. So two requests. It begins, Sitzler? 19 A. Sitzler. 20 Q. Do you know who that is? 21 A. Yes. They were dear friends, him and his wife. 22 Q. It says, "Emotion problems. Sick. He lost 23 control with Steve Lynch and I present." Can you tell us 24 generally what this was supposed to be? 25 A. The only -- Joe was beginning to look at other 65 1 people that were either dear friends with him or he was 2 looking at other people that were having coping problems at 3 work. He was writing down -- he was studying how they handle 4 their problems to cope and continue to work. He was also 5 writing down friends that he had at work in hopes that they 6 would help him. He was also studying if they had an illness, 7 he was checking their work schedule to see if they were being 8 put on the folder or if they left work early, did they get in 9 trouble. He was beginning to study people he worked with. 10 Q. The second name is Charlie Miller. "Said to 11 Sitzler he had --" 12 MR. SMITH: Tell. 13 Q. "Said to tell Sitzler he had hand --" 14 A. -itis. I guess that's old terminology when 15 somebody's hand shakes. My father used that phrase back years 16 ago. I guess I interpret handitis -- I guess Joe meant 17 shaking bad. I don't know if you asked a doctor what that 18 word would mean. 19 Q. Next one says, "Richard -- 20 A. Smoss. 21 Q. -- Smoss. When wife died, Sitzler while on job 22 went to funeral home"? 23 A. We went to the funeral home. I was present with 24 him. He lost his wife. And I met him at the funeral home 25 because they were dear friends, also, meaning we would go out 66 1 with them socially, Sitzler and his wife. Smoss, or however 2 you said his last name, his wife died and we went to the 3 funeral home. Joe went back to work and checked his work 4 record and found out that Smoss was still on the pay clock and 5 he left the company plant and went to his wife's -- this is 6 all hearsay. I'm not there. I'm just remembering what Joe 7 was saying as he wrote these things, and he said that the 8 company was -- evidently I guess they punched in and out. So 9 he was upset something about his scheduling when his wife 10 passed away is what he was upset over here. 11 Q. Joe was upset over somebody -- 12 A. He thought he got very good treatment or 13 something when his wife passed away. I went to the funeral 14 home when she passed away. 15 Q. It says next, "Sitzler is assistant foreman"? 16 A. I don't know what he meant unless they changed 17 his title. See, I don't know. He asked me to write and he -- 18 I wrote what he's asking me to write. I know sometimes what 19 some of this meant. 20 Q. "Jimmy Popham and Donald Cox. Foremen Area Two. 21 I work 90 percent of time in Area Two. Noise and fumes. 22 Poplin was the first one to tell me I had emotion problems. I 23 got" -- something. 24 A. Mental sick. 25 Q. "Mental sick. Poplin and Cox was there." Do 67 1 you remember anything further about that? 2 A. He would just come home saying he didn't need to 3 be told he was mentally sick, he was already going to the 4 doctor, you know, and he would get upset when people at work 5 would yell things at him and trying to diagnose him when he 6 was already taking his medicine. He would come home saying 7 that, you know. Beyond that, I don't know, you know. 8 Q. "Donald Cox told Lucas what happened in office"? 9 A. I don't know what that refers to. 10 Q. "Poplin told me he had a forearm infection. He 11 went to company dermatologist. He showed me his arm. He also 12 went to dermatologist in Bransburg"? 13 A. It might have been Brandenburg. I don't know. 14 I might have spelled it... 15 Q. All right. "He wanted it on his medical records 16 because he didn't believe company about chemicals"? 17 A. That would have been toluene when he was working 18 with OSHA because he believed the fumes also hurt his mental 19 illness. 20 Q. How did he state that to you? 21 A. He would just talk about all the chemicals and I 22 can't talk -- I'm not used to factory work. He would talk 23 about the chemicals. He would talk about he thought that 24 deteriorated him mentally. Beyond that, I don't know, you 25 know. 68 1 Q. Next it says, "Donald Cox lost an adopted son on 2 vacation. He got upset with everybody at work. He couldn't 3 make decisions about Cheatham. Waited till Kay Back returned 4 from vacation." Then it says Charlie Miller and then there's 5 an arrow that says, "He told me I couldn't pace, I had to sit 6 still." Did I read that correctly? 7 A. Well, Joe -- Joe would pace. That's why 8 sometimes we didn't sleep together. He would pace back and 9 forth. Knock, knock, knock, knock, he would tap. Knock, 10 knock, knock. That might go on all night long till you're, 11 like, I can't take no more of it. You know, you're trying to 12 watch a movie. (Indicates) If I did this for the next six 13 hours, could anybody stay with me? That's how severe it was. 14 You couldn't eat. Your silverware vibrated on the table. 15 You'd be like -- instead of me raising my voice to him, we 16 probably had four arguments, out of respect for the man I 17 would just excuse myself. He would vibrate in bed like that 18 and I'd have to get up and go to two jobs, and I'd be like 19 this. And I never made fun of him, ever. So that's what the 20 pacing means, you know, it was unreal. 21 Q. Was the pacing in that sort of movement with 22 hands or feet, did it occur before August 9, 1988? 23 A. (Nods head affirmatively). 24 Q. Was that a yes? 25 A. Yes, sir. It occurred a lot. 69 1 Q. How many months or years had it been going on? 2 A. Well, he was on so many different medicines, you 3 know, as I guess medicines would get in his system. Lithium 4 was the kindest or Lithobid or however you say it. When he 5 was introduced to different medicines, you know, he -- you 6 know, just sometimes he was nervous, sometimes he was upset. 7 So I don't know if you attribute it to the medicine. I don't 8 know if you attribute it to being nervous. 9 Joe was a workaholic. He would work the 10 doubles. I would say, "Don't work the doubles." He'd work 11 the doubles anyway. I'd get a telephone call at my job. 12 "Brenda, I'm working." I'd say, "Joe, you don't need to work 13 another shift." But he did what he wanted in life. You 14 didn't tell him what to do. You know, after you work 16 15 hours, how does anybody feel? You take a bath, you eat, you 16 go to sleep for three hours. 17 Have you ever walked in that plant? Rrrrrrrrrrrrrr. 18 I'd ask him to give me earplugs when I'd meet him for dinner. 19 You'd come out, your ears are still going Rrrrrrrrrrrrrr as 20 you drive your car home at night. I can't imagine working 21 like that. He worked at another printing thing before, 22 Fawcett and Haynes. I can't imagine in 20 years of my life 23 listening to Rrrrrrrrrrrrrr. No telling what that would do to 24 anyone's nervous system. 25 Q. When he would pace, would that sometimes be in 70 1 the middle of the night? 2 A. It was all the time. It could be in the middle 3 of a restaurant. People would stare at him and we'd just keep 4 on eating. Sometimes I would sit facing the people so they 5 wouldn't stare at him. 6 Q. And when he would pace like that, how long would 7 these incidents last? 8 A. It might last till he'd wear his shoes off. 9 He'd say, "Brenda, I know I'm getting on your nerves. I'll go 10 outside and take a walk." Joe was a proud-type person. He 11 got with his stomach and had with his eyesight and I'd get 12 scared to be out there by hisself. So I'd drive him a lot of 13 times. He didn't like to drive after dark so I'd go with him. 14 It might last -- the longest I think I ever remember is seven 15 hours you have it. 16 Q. Did this statement here, "Charlie Miller, he 17 told me I couldn't pace. I had to sit still" -- 18 A. He couldn't sit still. It would be like telling 19 an epileptic don't have a seizure; it would be like telling a 20 person in a wheelchair get up and walk. He could not not do 21 it. So that would be like asking me -- that would be asking 22 any human to do something they couldn't help. He would excuse 23 himself if it would start in here. He was enough of a 24 gentleman. He would know. He'd go to the bathroom. He 25 didn't sit through movies. He'd leave in a restaurant because 71 1 he didn't want to upset people around him or people to see 2 him. He had to do it. So... 3 Q. It says, "Assistant foreman 10 or 12 years. One 4 night when he was foreman we were four men heavy from one to 5 nine. He called Chuck Gorman at home, told Chuck if he wanted 6 to lay off he was heavy. Chuck called in to work and talked 7 to McCammick, and Miller subbed for and got out at lunchtime. 8 Let other spots go dark." Does that mean anything to you now? 9 A. You know, as best I understand Joe's type of 10 work, I mean, I know it was crucial that they keep the reels 11 running. I'm not a pressman, but when you're married to 12 somebody or live with someone you begin to understand their 13 type of work. I don't know if that means a reel went down or 14 the paper got clogged. I don't know. And I would sit there 15 with him sometimes. I don't know what that means in their 16 work lingo or talk, but I guess when it went dark -- I don't 17 know. I guess -- my guess would be a reel went down. I don't 18 know. 19 Q. "Jimmy Graham told Charlie Miller if he wasn't 20 going to do anything on one to nine, go home. Charlie Miller 21 went home. Simiters, foreman Area Two. Simiters wrote him up 22 for walking off the job. Charlie Miller came in on next shift 23 five to one. Miller and McQuinn or McKeown talked to Simiters 24 and got him to tidy or tied up." Mean anything to you now? 25 A. Not really. I'm not there. Joe's just asking 72 1 me to write this, so it doesn't mean -- I'm not there. I 2 don't know what -- they're talking work lingo, in other words. 3 I guess my gut instinct would be they dabbled up the 4 paperwork. I don't know. I only could guess. 5 Q. "When I was running north line reel, he made me 6 strip to big stumps while running reel. I put plates on 7 wrong. Before we started up, Ronnie Hickerson, man in charge 8 on Press Two, went to lunch in Poodle Park. Sit down with 9 McQuinn or McKeown, started telling him I wasn't worst a shit, 10 didn't want to work with me anymore. People could hear him at 11 next table. He was chairman of union at that time." Does 12 that mean anything further to you now? 13 A. Just what I've repeated in the past. I mean, he 14 just -- I mean, I don't guess I could say it any more. It's 15 just simply, you know, what he's saying is the way he felt. 16 And I don't know, if I was a mentally ill person I might take 17 what somebody was saying to me more to heart. That's why it's 18 not wise to tease people or it's not wise to make fun of 19 people when you see them in restaurants or anywhere, period, 20 you know. So I guess maybe if he hadn't been mentally ill 21 this would have just went off his back like water off a duck's 22 back. Everybody hurts people's feelings every day sometimes. 23 MR. SMITH: May we approach the bench? 24 (BENCH DISCUSSION) 25 MR. SMITH: Judge, she keeps going on and on. 73 1 MR. STOPHER: It's just hard to control her, 2 though, Judge. I've done the best I can. 3 MR. SMITH: Instruct her not to speculate. 4 MR. STOPHER: She got into it before. I'll try 5 to keep it from happening anymore. 6 (BENCH DISCUSSION CONCLUDED) 7 Q. Ms. Camp, beginning there on the last line on 8 this second page, "The press was having tension problems 9 between press and reel. Ronnie Hickerson turned all automatic 10 shutoffs. We were running both sides. Web went out on CD 11 side. Two ribbons on outside. The cuts jumped off and I put 12 spoil card in, called bindery. Press was still running. Web 13 was out on CD. Freddie Bickner was fil