Here you go Buf,
3 Q. Who’s Mildred French?
4 A. I don’t know.
5 Q. You don’t know a Mildred French?
6 A. No.
7 Q. I’m sorry?
8 A. No.
9 Q. No. Isn’t it true that you were arrested for
10 grabbing her breasts as she got out of the
11 shower? It was a sexual assault?
12 A. Yeah.
13 Q. Do you realize your under oath?
14 A. I realize that.
15 Q. You didn’t have to go to counseling for it?
16 A. We went to counseling over something, but it
17 wasn’t what you just said.
18 Q. What did you go to counseling over?
19 A. I don’t remember.
20 Q. When did you go to counseling?
21 A. I don’t -- 30 years ago.
4 Okay. And it’s your testimony
5 that you’ve never heard of a Mildred French?
6 A. Right. I don’t know her.
7 Q. Do you know a place called the Charter House?
8 A. That doesn’t ring a bell.
9 Q. Did you ever live at the Charter House?
10 A. No. What’s that?
11 Q. Were you ever charged with sexual assault at
12 22, when you were 22, 23, 24, that age?
13 A. No.
14 Q. No?
15 A. No, I don’t think so.
16 Q. Did you have to go to counsel -- court
17 ordered counseling when you were early twenties,
18 Mr. Hobbs?
19 A. Huh?
20 Q. Did you have to go to counseling in your
21 twenties as a result of any sort of assault?
22 A. Yeah. We had something happen back then. I
23 forget what it was.
24 Q. What happened?
25 A. I don’t remember
1 Q. Do you recall --
2 A. 30 years ago.
3 Q. Something happened. Criminal justice system
4 get involved?
5 A. I don’t remember.
6 Q. You don’t remember?
7 A. No.
8 Q. But you know you had to go to some sort of
9 counseling?
10 A. I think.
11 Q. Yeah. You never told Ms. Mildred French that
12 you killed her cat?
13 A. No.
_______________
8 Q (By Ms. Davis) Let me show you what
9 I've marked as Deposition Exhibit No. 29. This
10 is a declaration of Mildred French. Do you
11 recall at your last deposition we asked you
12 about Mildred French and you did not recall who
13 she was? Do you remember that testimony?
14 A Correct.
15 Q Let me give you just a minute to go
16 through Deposition Exhibit No. 29, the
17 declaration of Mildred French.
18 (Brief pause.)
19 A All right.
20 Q Have you read it?
21 A No. I'm not going to.
22 Q Why not?
23 A It doesn't mean nothing to me.
24 Q Why doesn't it mean anything to you?
1 A It just don't.
2 Q Mildred French was a neighbor of yours
3 back in the '80s, wasn't she?
4 A I don't remember.
5 Q Well, if you would read the Deposition
6 Exhibit No. 29, it might refresh your
7 recollection.
8 A Okay.
9 Q Are you refusing to read Deposition
10 Exhibit No. 29?
11 A It just don't mean nothing to me.
12 Probably just 30 years ago.
13 Q Well, I think some of the events that
14 happened 30 years ago or almost 30 years ago may
15 be relevant. So let's walk through what she
16 says. Beginning with Paragraph No. 3:
17 "In 1982, I was a neighbor of Terry
18 Hobbs in Hot Springs, Arkansas. I
19 lived in a two-story duplex, next
20 door to Terry Hobbs, his wife and
21 their child. On different
22 occasions in the mornings, I
23 caught Terry standing outside
24 looking at me in my window."
1 Did you ever look in at Ms. French in
2 her window?
3 A No.
4 Q Do you recall now that she was your
5 neighbor?
6 A Some old woman was.
7 Q Some old woman was. Could it have
8 been Mildred French?
9 A I don't know her name.
10 Q How old was this old woman that lived
11 next door to you?
12 A I don't know.
13 Q Fifties?
14 A I don't know.
15 Q How old were you in 1982?
16 A I'm not sure.
17 Q Can you add that up for me?
18 A I was born in '58.
19 Q In your twenties.
20 A Okay.
21 Q Paragraph No. 4:
22 "On one occasion I heard a baby
23 crying and sounds that indicated
24 to me that Terry Hobbs was beating
1 his wife and/or his child. I ran
2 next door to Terry's unit and rang
3 the outside bell to Terry Hobbs'
4 residence. After a moment, Terry
5 opened the door and asked me, with
6 disgust in his voice, 'What do you
7 want?' I told him that if he
8 touched his wife or his baby
9 again, I would call the police."
10 Do you remember that event?
11 A No, I do not.
12 Q Did you ever beat your wife or child
13 back in the '80s?
14 A No.
15 Q That was a different wife than Pam;
16 correct?
17 A Correct.
18 Q That was xxxxx. What was her last
19 name?
20 A xxxxx.
21 Q And what was the child's name?
22 A xxxxx.
23 Q Your son?
24 A My son.
1 Q And do you recall Ms. French or this
2 old lady neighbor knocking on your door and
3 telling you that if you beat your wife or child
4 again, she would call the police?
5 A No, ma'am. That never happened.
6 Q Are you accusing Ms. French of lying
7 in Paragraph 4?
8 A I'm not accusing nobody. I'm just
9 saying that never happened.
10 Q That's -- that's a lie then. If she
11 swore under oath that that occurred, your
12 testimony is that she's lying?
13 A Yes.
14 Q Let me direct your attention to
15 Paragraph 5:
16 "A few months later, I worked
17 outside in my yard. I went inside
18 my home to take a shower and get
19 cleaned up. I specifically
20 remember that I locked all of the
21 screen doors when I came inside.
22 I went upstairs and took a shower.
23 While I was in the shower, I did
24 not hear anything unusual."
1 Continuing to Paragraph 6.
2 "When I got out of the shower, I
3 reached to put my hand on my
4 housecoat; and at that moment,
5 Terry Hobbs, who had broken in and
6 somehow gotten upstairs into my
7 bathroom, physically grabbed me
8 from behind and gabbed my breast.
9 I screamed at Terry loudly, 'What
10 are you doing in my house?' and
11 screamed, 'get out.' I kept
12 repeating loudly, 'get out,' and
13 Terry hissed, 'shhh' at me.
14 However, I kept yelling for Terry
15 to get out, and ultimately Terry
16 ran out of my home and ran
17 downstairs into his unit. The
18 bathroom window over my tub was
19 partially opened and my yelling
20 could be heard outside. I recall
21 a man was outside across the
22 street working in his yard. I
23 believe that Terry intended to
24 further molest and/or harm me
1 because his actions and demeanor
2 indicated that was his goal, but I
3 believe my continued yelling and
4 screaming alarmed him and caused
5 him to run off. At the time, I
6 was afraid that Terry would rape,
7 harm or even kill me."
8 I would say, "have I read that
9 correctly," but you're refusing to follow along
10 with me in the declaration. Is that correct?
11 A Correct.
12 Q Now, did you break into Mildred
13 French's house?
14 A No.
15 Q Did you break into the unit next door
16 to you in Hot Springs that was occupied by some
17 old lady?
18 A No.
19 Q Did you ever go into the bathroom of
20 Mildred French while she was taking a shower?
21 A No.
22 Q Did you ever go into the bathroom of
23 some old lady that lived next door to you in Hot
24 springs, Arkansas and grab her?
1 A No.
2 Q Did you grab Ms. French's breast?
3 A No.
4 Q Did you ever grab some old lady's
5 breast, the one that was living next to you in
6 the unit?
7 A No.
8 Q Is it your testimony that everything
9 stated in Paragraph 6 is a lie?
10 A Yeah.
11 Q Can you think of any reason that an
12 81-year-old woman -- that's old Ms. French is
13 now. Did you know that?
14 A No.
15 Q Can you think of any reason that an
16 81-year-old woman would be willing to swear
17 under oath to these allegations about you if
18 they weren't true?
19 A No, I don't.
20 Q Do you recall when you lived in the
21 duplex unit in 1982, next door to some old
22 woman, that the police were called and you were
23 arrested?
24 A I wasn't arrested.
1 Q The police were called, weren't they?
2 A Well, we talked about something.
3 Q What is your recollection of those
4 events that Ms. French ---
5 A I don't have ---
6 Q Let me finish my question. What is
7 your recollection of the reason that the police
8 were called and those events that Ms. French
9 remembers so clearly?
10 A I don't have any.
11 Q You have no idea what the police were
12 called for?
13 A No, I don't remember.
14 (Whereupon, Exhibit No. 30
15 was marked to the testimony
16 of the witness.)
17 Q (By Ms. Davis) Let me show you what
18 I'm marking as Deposition Exhibit No. 30, which
19 is a copy of the police report from 1982
20 regarding you and Ms. French. I'll give you a
21 minute to look through that.
22 (Brief pause.)
23 Q Have you had a chance to go through
24 that?
1 A Yeah, I'm going to.
2 Q Okay.
3 (Brief pause.)
4 Q Does Deposition Exhibit No. 30 refresh
5 your recollection that the police came out to
6 talk to you about criminal trespass and assault
7 and breaking and entering ---
8 A I didn't really read it.
9 Q --- at Mildred French's house?
10 A Didn't (unintelligible).
11 Q Is it your ---
12 COURT REPORTER: I can't -- I
13 can't hear the answer.
14 A Didn't really read it.
15 Q (By Ms. Davis) Okay. Are you
16 refusing to read Deposition Exhibit No. 30, the
17 police report related to your attack of
18 Ms. French?
19 A I didn't attack nobody.
20 Q Is it correct that you're refusing to
21 read Exhibit 30?
22 A Correct.
23 Q Why is that?
24 A It don't mean nothing to me.
1 Q You say it doesn't mean anything to
2 you; and yet, this case revolves around your
3 complaint that your reputation has been damaged;
4 correct, sir?
5 A This was 30 years -- whatever happened
6 here 30 years ago.
7 MS. DAVIS: I will object to the
8 answer as nonresponsive.
9 Q (By Ms. Davis) This case revolves
10 around your allege -- allegations that your
11 reputation has been damaged by Ms. Pasdar;
12 correct?
13 A Correct.
14 Q And I want to talk about your
15 reputation and your concern for your reputation.
16 And when I look at Deposition Exhibit No. 29 and
17 Deposition Exhibit 30, which involve allegations
18 of you attacking and sexually molesting a woman,
19 that strikes me as something that relates to
20 your reputation. Do you disagree?
21 A It never happened. Allegations.
22 Q I'm -- I'm confused now. My
23 understanding was ---
24 A You said I molested and sexually -- I
1 ain't never did that in my life.
2 Q Here is my confusion. I thought you
3 had testified previously that something happened
4 back in 1982 but you didn't recall what it was.
5 A Right. And it wasn't nothing like
6 that.
7 Q Is it possible that ---
8 A No.
9 Q --- Ms. French is telling the truth?
10 A No. If she said I molested her or
11 whatever you just said, no, that never happened.
12 Q Why are you refusing to look through
13 the report to see exactly what did happen?
14 A That's 30 years ago. I don't care
15 what happened 30 years ago.
16 Q You don't care what your reputation
17 was 30 years ago?
18 A I didn't have a bad one.
19 Q You're not suggesting that the police
20 are lying with regard to their report, are you?
21 A I don't know. I ain't read it.
22 Q And refuse to?
23 A (Witness nods head.)
24 Q Let's continue on with Ms. French's
1 declaration. Paragraph 7:
2 "I called the police to report
3 Terry's break-in and attack. I
4 believe the police filed an
5 incident report on the matter."
6 Paragraph 8:
7 "I also went that day to Terry's
8 mother-in-law who lived nearby and
9 told her all what Terry had done,
10 that he had broken into my home
11 and had assaulted me in my
12 bathroom. I told the
13 mother-in-law that Terry was a
14 very sick man and that he required
15 counselling immediately. The
16 mother-in-law told me that her
17 family was not in favor of sending
18 Terry to counselling. She was a
19 member of some sort of Pentecostal
20 church. I told her then that I
21 would pursue the matter with the
22 police."
23 Do you have any recollection of
24 Ms. French or the old woman that lived next door
1 to you in the duplex in Hot Springs having a
2 discussion with your mother-in-law about you
3 attacking her?
4 A No, I don't.
5 Q Paragraph 9:
6 "That night, after I told my
7 landlord about the attack, my
8 landlord set up a meeting in which
9 both Hobbs and I sat down
10 face-to-face in front of the
11 landlord. Terry's father-in-law
12 was also there. I said to Terry,
13 'Tell them what you did to me.'
14 Terry said, 'I didn't do nothing.'
15 After I articulated what Hobbs had
16 done to me, Terry looked at me
17 square in the eye and said calmly,
18 'It never happened.' He was cool
19 and collected as he told me it
20 never happened. If you had not
21 known for certain Terry was lying,
22 you would not have been able to
23 tell by his demeanor that he was
24 lying. I was sickened and
1 frightened by Terry's ability to
2 deny his horrific and perverted
3 actions and seemed so calm in
4 doing so. I looked at Terry and
5 told him, 'You are a liar and you
6 are sick.'"
7 Paragraph 10:
8 "Terry looked back at me with cold,
9 dead eyes and said, 'Yeah, I'm
10 sick."
11 Here is my question to you: Do you
12 recall having a meeting with your neighbor and
13 the landlord regarding Ms. French's or the old
14 lady's allegations?
15 A No, I don't.
16 Q Are you testifying that that meeting
17 never took place or are you testifying that it's
18 possible it did, you just don't remember?
19 A I don't recall that meeting.
20 Q Is it possible it occurred?
21 A It's possible it didn't because I
22 don't remember that.
23 Q But it's possible it did?
24 A I didn't say that.
1 Q It's not possible it occurred?
2 A Right.
3 Q There was no such meeting?
4 A Not to my knowledge.
5 Q And again, can you think of any reason
6 that Ms. French would make up and swear to a
7 meeting like she describes in Paragraph 9 and
8 10?
9 A You would have to ask Ms. French.
10 Q I did, and she's testifying in her
11 declaration. Let me direct your attention to
12 Paragraph 11:
13 "The landlord kicked Terry and his
14 family out of Terry's unit as a
15 result of his attack."
16 Were you kicked out of the duplex unit
17 you shared next door to an old lady in Hot
18 Springs, Arkansas?
19 A No, ma'am.
20 Q So that's a lie too?
21 A Correct.
22 Q Do you recall the name of your
23 landlord?
24 A No.
1 Q Paragraph 12:
2 "I appeared in court to press
3 charges against Terry Hobbs.
4 Though I do not remember the
5 specifics, I do recall that at the
6 hearing Terry was ordered to go to
7 counselling and the matter was
8 resolved in that manner. I do not
9 know if Terry went to counselling,
10 but he was supposed to go to
11 counselling at a facility located
12 on 7th Street in Hot Springs."
13 You've previously testified that you
14 were ordered to go to counselling; correct?
15 A Probably.
16 Q You just don't recall why?
17 A Right.
18 Q But you're sure it wasn't because you
19 had attacked your neighbor?
20 A Right.
21 Q And you're sure it wasn't because you
22 sexually molested an old woman?
23 A I never done that.
