STATE OF MICHIGAN IN THE CIRCUIT COURT FOR THE COUNTY OF OAKLAND FAMILY DIVISION DEBORAH ANN FRAZIER, Plaintiff, Hon. Karen McDonald Case No: 2010-773215-DM vs. RICKY ALAN FRAZIER, Defendant. / VIDEOTAPED DEPOSITION OF DAVID E. TAYLOR, A/K/A THE APOSTLE Taken by the Defendant at law offices of Colleen V. Ronayne, located at 2055 Orchard Lake Road, Sylvan Lake, Michigan 48320, on Tuesday, February 10, 2015, commencing at 10:00 a.m. APPEARANCES: For the Defendant: COLLEEN V. RONAYNE (P33560) 2055 Orchard Lake Road Sylvan Lake, Michigan 48320 (248) 334-9938 For the Defendant: GREGORY M. YATOOMA (P68818) Corporate Counsel 1605 S. Telegraph Road Bloomfield Hills, Michigan 48302 (248) 459-8832 For Third-Party DAVID W. POTTS (P19043) Witness: 21 E. Long Lake Road, Suite 250 Bloomfield Hills, Michigan 48304 2 (Pages 2 to 5) Page 2 Page 4 1 APPEARANCES (Continued): 1 Sylvan Lake, Michigan 2 Also Present: Rick Frazier 2 Tuesday, February 10, 2015 - 10:41 a.m. 3 VIDEOGRAPHER: VIDEO ENTERPRISES, INC. 3 * * * * * 4 RECORDED BY: REGENCY COURT REPORTING 4 VIDEOGRAPHER: We are now on the 3133 Union Lake Road, Ste. A 5 record. This is the videotaped deposition of David 5 Commerce Township, MI 48382 6 E. Taylor, a/k/a The Apostle. Today’s date is (248) 360-2145 7 February, 10th, 2015. The time is now 10:41 a.m. My 6 8 name is Nick Houselander, I’m the video technician. 7 9 This deposition is being taken at 2055 8 9 10 Orchard Lake Road, Sylvan Lake, Michigan, 48320 in 10 11 the case of Deborah Ann Frazier v. Ricky Alan 11 12 Frazier, Case No: 2010-773215-DM in the Oakland 12 13 County Family Division. Could the attorneys please 13 14 briefly identify themselves for the record. 14 15 MS. RONAYNE: Go ahead. 15 16 MR. POTTS: Sure. I’m Dave Potts, I 16 17 represent the witness, Dave Taylor, and these are my 17 18 own clients. 18 19 MS. RONAYNE: Colleen Ronayne 19 20 appearing on behalf of Rick Frazier who is to my 20 21 left. 21 22 MR. YATOOMA: Gregory Yatooma, also 22 23 23 representing Rick Frazier. 24 24 VIDEOGRAPHER: Can the court reporter 25 25 please swear in the witness. Page 3 Page 5 1 TABLE OF CONTENTS 1 COURT REPORTER: Could I have you 2 WITNESS: PAGE 2 raise your right hand, sir. Do you solemnly swear or 3 DAVID E. TAYLOR 3 affirm to tell the truth, the whole truth and nothing 4 Direct Examination by Ms. Ronayne 7 4 but the truth, so help you God? 5 5 MR. TAYLOR: Yes. 6 6 COURT REPORTER: Thank you. 7 7 MR. POTTS: I have a preliminary 8 EXHIBITS: 8 matter. 9 Deposition Exhibit Number Three 220 9 MS. RONAYNE: Sure. 10 Deposition Exhibit Number Four 228 10 MR. POTTS: If I could just make a 11 11 statement. The Court rendered an opinion and order 12 12 regarding a motion dealing with the question of 13 13 privilege that was raised during the November 12th 14 14 deposition. The Court entered an order on January 15 15 28th requiring that the matter be held in the 16 16 courthouse. Pursuant to agreement of counsel and 17 17 pursuant to notice, the deposition is being held in 18 18 Plaintiff’s counsel’s office, certainly with my 19 19 permission and with my concurrence. But just so that 20 20 the record is correct, this is an agreed upon 21 21 relocation of the venue and we’ve -- we’ve done this 22 22 by consent. 23 23 MS. RONAYNE: That is correct, 24 24 although if we run into a problem I reserve the right 25 25 to have it relocated to the courthouse. Do you 3 (Pages 6 to 9) Page 6 Page 8 1 understand? You’re in agreement with that? 1 Q And who’s your son? 2 MR. POTTS: Yes. 2 A Joshua Taylor. 3 MS. RONAYNE: Okay. And that we’ve 3 Q And what’s his date of birth? 4 agreed that we are going to rather liberally just get 4 A The 12th, the 21st, and it’s 2000. 5 this deposition done, and I understand that we’re 5 Q And -- 6 going to adhere to the opinion which may be on a 6 A I mean, 1999. I’m sorry. 7 question by question basis when it comes to spiritual 7 Q And who is his mother? 8 matters, but in a cooperative way, and if necessary 8 A Tabitha Taylor. 9 we’ll seek the guidance of the Court. 9 Q Now, you have older children; is that right? 10 MR. POTTS: Yes. It’s my intention 10 A No. 11 to try and live within the scope of the opinion. I 11 Q You live with -- 12 read it. We’ve had an opportunity to discuss it. 12 A Oh, yeah. Oh, yeah, my daughter Destiny Taylor. 13 It’s clear that the Court’s trying to give us some 13 Q And her mother is Tabitha? 14 direction and guidance but it may be that on a case 14 A Mm-hmm. 15 to case basis we’ll have to see where we go. But 15 Q You have to answer yes or no. 16 it’s my intention to be more cooperative than less, 16 A Yes, mm-hmm. 17 and to try to reason as expansively but as narrowly 17 Q Okay. So you’ve had full custody of Joshua? 18 as I can, that makes a quandary, but -- 18 A We have joint -- well, I think they give her the -- 19 MS. RONAYNE: Okay. 19 what -- what do the courts say if you got them -- 20 MR. POTTS: -- I think we know each 20 custodial custody where -- I don’t know the 21 other well enough that we’re not going to -- 21 terminology for it, but I know that I have -- she 22 MS. RONAYNE: Okay. 22 keeps them half of the week and then I keep them. 23 MR. POTTS: -- fight when we don’t 23 Q When you say “them,” who are you referring to? 24 have to have one. 24 A Joshua and Destiny. 25 MS. RONAYNE: Exactly. Okay. 25 Q Is Destiny an adult? Page 7 Page 9 1 Mr. Taylor, you were here for a 1 A Yeah. Now, she is -- she just turned 18 this coming 2 deposition -- what was the date of -- 2 January. 3 MR. POTTS: The 12th. 3 Q Okay. So is Tabitha Taylor the primary custodian -- 4 MS. RONAYNE: What was it? 4 A Yes. 5 MR. POTTS: November 12th. 5 Q -- of the children? 6 MS. RONAYNE: -- November 12th. 6 A Is that the terminology? 7 THE WITNESS: Mm-hmm. Sure. 7 Q No, I’m supplying some. I don’t know what it -- 8 MS. RONAYNE: And we ran out of time 8 A Yeah. 9 and rescheduled it for today, ultimately through 9 Q -- where you got divorced and what language they use. 10 court order, and I’d like to clear up a couple of the 10 A Yeah, that’s right. 11 things that you said at the November 12th deposition. 11 Q But you believe you have 50/50 parenting time? 12 THE WITNESS: Okay. 12 A Yes. 13 MS. RONAYNE: Okay. 13 Q And you pay support? 14 DAVID E. TAYLOR 14 A Yes, mm-hmm. 15 SWORN AS WITNESS, TESTIFIED AS FOLLOWS: 15 Q How much do you pay? 16 DIRECT EXAMINATION 16 A Seven fifty a month. 17 BY MS. RONAYNE: 17 Q A month? 18 Q Who lives with you at 2008 Victory Lane? 18 A Mm-hmm. 19 A No one. 19 Q Okay. You indicated that when you’re in St. Louis 20 Q No one lives with you there? 20 you sleep at two houses, two different places. One 21 A No. Other than my son. 21 is the Victory Lane that you rent, that’s a rental? 22 Q Well, I mean, he counts. 22 A Mm-hmm. 23 A Okay. Yeah. 23 Q You have to answer yes. 24 Q Whoever the human being is. 24 A Yes, mm-hmm. 25 A Yes, my son. 25 Q Okay. And one was where JMMI rents at -- I’m not 4 (Pages 10 to 13) Page 10 Page 12 1 sure how to pronounce the name of the street -- 1 Q You’ve had barbeques and pool parties at that house? 2 Timpaige? 2 A Yes, mm-hmm, for the ministry. 3 A Yeah. Timpaige. 3 Q For staff? 4 Q Timpaige? 4 A Yeah, for staff. 5 A Mm-hmm. 5 Q Do you consider Debbie Frazier staff? 6 Q How much time do you spend at one versus the other? 6 A Yes, she has been on the staff, and I’m for sure. 7 A I’m not sure. I know that we just, you know, the 7 Q What is her title? 8 ministry just acquired that ministry residence now a 8 A There’s no title, we don’t keep titles. 9 little over a year, and so we were preparing things 9 Q She doesn’t have a -- any kind of reference to what 10 over there so I spent more time this past little year 10 her -- well, what’s her job description? 11 of helping that, but the majority of my time usually 11 A She’s basically a volunteer staff like most of the 12 is at the apartment which is my main residence.