CEOInterviews.AIPart 1 of 3, Deposition of Michelle Brannon: Per Apostle David E Taylor “Axe Michelle”

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Nick Helslander0:14

So are we on? We are now on the record. This is the videotape deposition of Michelle Devore. Today's date is March 12, 2015. The time is now 9:20 a.m. My name is Nick Helslander, I'm the video technician. This deposition is being taken at 1200 North Telegraph Road in Pontiac, Michigan 48341, in the case of Deborah and Ginger versus Ricky Allen Frazier, case number 2010-773-215-DM, in the Circuit Court for the County of Oakland, Family Division. For the attorneys, please briefly identify themselves for the record.

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Unknown0:54

Good morning, Maui and good morning, for Deborah Frazier.

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Richard B. Pauling Jr.1:01

Richard B. Pauling Jr. appearing on behalf of Joshua Media Ministries and Miss Brannon.

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Callie Nornay1:06

Callie Nornay appearing on behalf of Rick Frazier. Gregory Tuma also appearing.

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Interviewer1:12

Would the court reporter please swear the witness?

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Court Reporter1:16

Do you swear to tell the truth, the whole truth, and nothing but the truth?

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Michelle Devore1:18

I do.

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Interviewer1:20

Thank you. I've just got a couple preliminary matters. Number one, I'm going to object to this matter being taken by videotape. And number two, it's my understanding Mr. Tuma hasn't filed an appearance, and I'm going to object to his presence. But I'm going to let you proceed at this time with your questions, with those objections on the record.

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Michelle Devore1:37

So those objections were that it was being taken by videotape and that Mr. Tuma was present because he's not an attorney of record. Did you notify us of any objection to the videotape? No. Okay, should proceed.

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Interviewer1:59

We had sent and served your clients through you with a subpoena duces tecum as a follow-up to things that had not been presented pursuant to court order or prior subpoena. And you've brought some things in today. I'm going to go through the list and ask you to hand me what you think satisfies the requirement of the addendum to the subpoena. The first is 2014 bank statements, including but not limited to the Bank of America account ending 2449.

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Richard B. Pauling Jr.2:37

I can't answer questions. You'd have to ask the witness.

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Michelle Devore2:42

Well, you just put these in front of me, so they're self-explanatory what those are.

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Interviewer2:48

Okay, then I'll just... You've said you've brought some and some you didn't, so I'd like someone to identify what you're handing me, and you're indicating you would prefer the witness to do it. Okay, I'm asking for December 2014 bank statements, Bank of America ending 2449.

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Michelle Devore3:04

Okay. This is from the... No, we don't. It's not listed here, but we do have it. It was issued to Mr. Potts by mistake.

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Interviewer3:17

So how did it happen that they went to Mr. Potts?

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Michelle Devore3:22

JMI has two attorneys: Pastor Taylor's attorney, Mr. Potts, and JMI's attorney. Our bookkeeper sent the bank statements to Mr. Potts instead of Mr. Pauling by mistake.

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Interviewer3:42

Do you have any idea of the time frame that happened?

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Michelle Devore3:44

It would have been the first time that they were requested prior to the court. I think maybe about three weeks ago.

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Interviewer3:48

Okay.

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Michelle Devore3:50

So we are trying to get them from Mr. Potts right now. I already talked to him; I called him at home early this morning when I found out.

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Interviewer4:01

Okay. So it's David Potts. The next one is January 2015 bank statements, including but not limited to Bank of America account ending 2449. Is that the same? Would that be the same for January 2015?

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Michelle Devore4:18

It would have been with... No, I mean we could get those. I don't want to say that those were the ones that were sent to Potts. It depends on the time that you had sent that request, because there were two requests, and that seems to be updated since the previous one.

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Interviewer4:40

No, this we just sent earlier in the week to make sure we got what we needed. This goes back after the original time we set your deposition.

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Michelle Devore4:54

Okay, so honestly I don't have it. You don't have it? So we are trying to get it.

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Interviewer4:57

You can get it.

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Michelle Devore4:59

I cannot get it. I don't have access to the accounts. But I could request that.

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Interviewer5:03

Who would? Our bookkeeper.

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Michelle Devore5:07

Who's the bookkeeper? Ashley Ware.

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Interviewer5:11

Spell it.

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Michelle Devore5:13

S-H-L-E-W-L-E-W-L-E-W-A-I'm sorry, L-U-Y. I'm just going to say W-A-R-E.

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Interviewer5:24

Okay. She's your bookkeeper. And where is she housed for bookkeeping purposes?

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Michelle Devore5:30

She works out of Missouri. We're out of Missouri, St. Louis.

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Interviewer5:36

No, I understand. I mean, what building? The same building that you guys have on record: 5209 Trail Oaks Drive.

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Michelle Devore5:42

5209 Trail Oaks Drive.

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Interviewer5:48

And what do they refer to that building as?

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Michelle Devore5:53

JMI. But there's the residential... No, it's not called residence. The other one is the residential. That's correct.

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Interviewer5:59

Let her finish the question before you answer. Okay. The large house. But does this house on Trail Oaks have a name that you refer to it as?

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Michelle Devore6:11

JMMI.

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Interviewer6:14

Okay. It's in a residential center, a residential kind of subdivision, isn't it?

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Michelle Devore6:19

That's correct.

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Interviewer6:21

Does she live there?

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Michelle Devore6:22

She does not.

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Interviewer6:24

Does anyone live there?

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Michelle Devore6:26

There are people that live there, that spend the night and live there daily. That's correct.

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Interviewer6:30

And who is that?

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Michelle Devore6:36

Staff.

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Interviewer6:37

In their names, please.

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Michelle Devore6:44

Is that necessary? Yeah. Angel Jones.

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Interviewer6:52

Angel Jones. And who is she?

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Michelle Devore6:56

She's on staff. She's a volunteer, a paid staffer? No. But she resides there.

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Interviewer7:03

Okay. And who else?

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Michelle Devore7:06

Bashira. How spelled? B-A-S-H-I-R-A. H-O-Q-Q-E. It might be the only word that has no U and two Q's.

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Interviewer7:28

So she's on staff?

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Michelle Devore7:30

She is.

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Interviewer7:31

And is she paid?

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Michelle Devore7:33

She's not.

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Interviewer7:34

Then who else?

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Michelle Devore7:36

And that's it. Really. Marcia was living there. Marcia no longer lives there.

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Interviewer7:41

What's Marcia's last name?

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Michelle Devore7:43

McDonald. Is she still on staff? She's volunteer staff, but she resides elsewhere.

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Interviewer7:51

Are Angel and Bashira related?

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Michelle Devore7:59

They are.

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Interviewer8:01

How are they related?

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Michelle Devore8:02

They're sisters.

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Interviewer8:04

And what generally are their duties?

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Michelle Devore8:08

Bashira handles opening mail. She does like answers phones, she's a basic receptionist.

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Interviewer8:20

Did you say Angel did that?

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Michelle Devore8:22

No. What does Angel do? Angel does usually product orders, any type of product orders that come in, and any type of ordering new product, getting the new covers and things like that done.

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Interviewer8:34

Okay. So they live there and operate that business, your JMI business, out of there.

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Michelle Devore8:42

Yes.

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Interviewer8:47

Does Deborah Frazier ever go to that building?

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Michelle Devore8:51

She does.

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Interviewer8:53

And for what purpose?

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Michelle Devore8:55

She comes down there to answer phones, just be a part of the volunteer part. We get a lot of prayer requests that come in and people that ask for prayer, and Deb will answer the phone and pray for people.

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Interviewer9:15

Okay. So we'll go back to that. But is it fair to say that when Ms. Frazier goes there, that that's where she goes to St. Louis? That's where she would go to work?

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Michelle Devore9:27

She does, yes.

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Interviewer9:31

Any other location that she would go to work?

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Michelle Devore9:33

She doesn't, unless it's to the Northeast headquarters in Taylor.

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Interviewer9:42

All right. We'll get back to that. Back to the documents. The third thing on the addendum is any and all documentation evidencing JMMI deposit information that reflects all donations made by Deborah Frazier from April 1, 2014 to the present, including but not limited to the following deposits made into JMMI Bank of America account ending 2449: the $5,000 deposit made on July 14, 2014; the second $5,000 deposit made on the same date; the $8,120 deposit made on October 6, 2014; the $7,548 deposit made on October 6, 2014; and the $6,943 deposit made on the same date; or any and all deposits where Deborah Frazier donated money to the Rosh Hashanah offerings; the deposit made on around December 10th that reflects $1,000 to the Crusade donation as indicated on the giving statements that were produced by JMMI. So it's basically documentation that you have of donations that Deborah made. So do you have those documents?

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Michelle Devore11:10

Whatever documentation... I know that we supplied in the bank statements prior that showed the wire transfers that were done, any wire transfers that were done, any deposits that we had record of. So any additional like bank statements and things like that, or copies of the checks? No, well, we asked you to bring those specifically so that you could testify from them today. I understand. I do not have access to that bank account myself. I'm not the one that has access. Isn't that in the information we've already turned over? It is, yes. I don't believe it is completely, though. Well, some of the items, there is no information to show that it was specifically donations made by Ms. Frazier, which is part of the problem. There's no way necessarily knowing.

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Interviewer11:55

Don't answer. How do you keep record of donations if somebody gave a donation?

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Michelle Devore12:03

If they put their information down on the offering envelope, we keep record of that. And that was supplied to you guys: a list of donors that you guys had requested or asked for. We submitted that to you. If we did not, if they did not complete an offering envelope, then I do not have that information.

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Interviewer12:24

You don't take what's on the check if they have a check?

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Michelle Devore12:26

Yeah, if they wrote a check. If there's cash in there and they put it on an offering envelope that was them, it's recorded, and you would have been supplied that on that donor list.

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Interviewer12:44

All right. We'll get back to that. All paperwork regarding Deborah Frazier's financial pledge made during the June crusades. Do you have that?

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Michelle Devore12:59

Her pledge made? Yes. That's what it's noted on your documents. I don't have a pledge made. What I have is whatever was supplied to you guys in terms of what she gave: the list of donor information that she submitted and the copy of the bank statements.

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Interviewer1:00:10

Go ahead and answer the question if you can. I couldn't tell you. I have no idea who she would have told.

Do you have any knowledge if she and Mr. Taylor spoke about them?

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Michelle Devore1:00:23

I wouldn't have. I would guess not.

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Interviewer1:00:28

Why would you guess not?

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Michelle Devore1:00:28

Because Mr. Taylor just doesn't give himself, you know, he doesn't have that time. And to my knowledge, they don't speak like that.

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Interviewer1:00:45

Did Mrs. Frazier ever tell you that she has seen Jesus face to face?

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Michelle Devore1:00:51

She has not.

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Interviewer1:00:51

That's one of the tenets of Jeremiah's ministry, is it not?

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Michelle Devore1:00:51

That is correct.

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Interviewer1:00:59

Have you seen Jesus face to face in a dream?

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Michelle Devore1:00:59

Yes, but in a dream. In the corporal sense of being in now, so you consider in a dream to be also face to face? Absolutely.

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Interviewer1:01:13

Is it once?

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Michelle Devore1:01:13

I've had several of them. Several of the Lord coming to me and answering. Would you like me to tell them? I just want you to know if it's God the Father, God the Son, the Holy Spirit. I've had dreams of Jesus coming to me. I've had dreams where I've audibly heard the Father talk to me in a dream. I've never seen him.

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Interviewer1:01:44

Has Mr. Taylor ever told you about his face-to-face meetings with the Lord?

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Michelle Devore1:01:51

Whatever conversation that Mr. Taylor and I have, he's my spiritual father, he's my pastor, and I believe that would be protected under the pendant.

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Interviewer1:01:58

I'm asking about him telling you, not you telling him things. He has disclosed to you.

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Michelle Devore1:02:05

Again, whatever we've discussed personally has been, you know, if I've talked to him about it or he's relating...

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Interviewer1:02:12

I'm not asking what you've discussed. I'm just asking what he has said to you, not what you said to him.

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Counsel1:02:17

Counsel, I'm going to object to the question because she's absolutely right. If there is a conversation in which Pastor Taylor talks to her in conjunction with a give and take, those are privileged communication.

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Interviewer1:02:37

Okay. It's also, by the way, it's also irrelevant and material what their conversations between Pastor Taylor...

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Counsel1:02:49

I don't agree with you, but I'm going to move on.

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Interviewer1:02:49

Where does Mrs. Frazier stay when she comes to St. Louis?

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Michelle Devore1:02:54

She has stayed at... mentioned she has stayed at a... what do you call it? It's not a hotel per se, like an in-home suite type thing. Town suite or something like that.

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Interviewer1:03:07

Say that again.

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Michelle Devore1:03:07

She stayed at like an in... where there's long-term stay. Executive suites or something like that. I don't know the exact name. And she's also stayed at the Trail Oaks on occasion when she is working for the ministry in some capacity.

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Interviewer1:03:26

When she's in St. Louis, where would that be?

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Michelle Devore1:03:32

She would work at the 5209 Trail Oaks.

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Interviewer1:03:44

You talked a little bit about what she does when she's at the offices in Missouri. So she answers the phone?

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Michelle Devore1:03:50

She does.

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Interviewer1:03:57

And what else?

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Michelle Devore1:03:57

She's mailed letters, done mailings, stuffed envelopes, clerical. Anything of a religious nature. I know that she's prayed for people as I stated earlier.

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Interviewer1:04:25

Is that somebody that has called in?

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Michelle Devore1:04:25

That is correct.

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Interviewer1:04:33

So what would you say the property at 5209 Trail Oaks in Blackjack, Missouri, what is that primarily used for?

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Michelle Devore1:04:40

We have people who live there, as I stated before, and we do business from that area out of it.

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Interviewer1:04:57

Do they pay rent?

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Michelle Devore1:04:57

Yes.

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Interviewer1:04:57

Are there people that come and go from that? Because it's a residence, isn't it?

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Michelle Devore1:04:57

It's a residence, but they're people that come and will help out, and volunteers come out and do mailings, or if we have big mailings or whatever, they'll come out.

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Interviewer1:05:09

So people would come and go to that address?

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Michelle Devore1:05:09

Yes.

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Interviewer1:05:16

You don't have any problem with the neighborhood objecting to a business being run out of it?

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Michelle Devore1:05:16

Well, it's a ministry being run out of it. It's not a business per se.

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Interviewer1:05:23

But it's still not zoned for that purpose, is it?

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Counsel1:05:23

Objection. Form, foundation, qualification.

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Interviewer1:05:30

Go ahead and answer the question if you can.

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Michelle Devore1:05:30

I wouldn't know. But is anybody complaining about it? I wouldn't know.

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Interviewer1:05:36

Okay. Who do you think would know?

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Michelle Devore1:05:36

I wouldn't know. I'm not sure.

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Interviewer1:05:43

Okay. And I asked you this before. You don't have any name that you refer to 5209?

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Michelle Devore1:05:49

It's JMMI. I mean, we call it JMM. It's a place that we do business.

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Interviewer1:05:56

Ministry House? Is that what you call it?

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Michelle Devore1:05:56

It's been called JMMI typically is what I reference as JMMI. But I've heard others call it Ministry House. And then the other one is the Residential Center, and that's where Mr. Taylor lives.

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Interviewer1:06:09

Mr. Taylor does not live there. Who lives there?

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Michelle Devore1:06:09

Nobody lives there. It is vacant most of the time.

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Interviewer1:06:24

I'm going to show you the lease for 5209 Trail Oaks Drive in Blackjack. And I'm going to ask you to identify this. This is Exhibit Number 7, and it's a residential lease for 5209 Trail Oaks Drive, Blackjack, Missouri 63033. And who signed it?

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Michelle Devore1:07:48

It looks like Bashira.

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Interviewer1:07:53

Whose handwriting is that?

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Michelle Devore1:07:53

Bashira's. And myself. And I'm not Angel, but I can't read their handwriting, so I don't know.

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Interviewer1:08:00

We don't know who would have signed this?

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Michelle Devore1:08:00

I don't know their signature. The handwriting is not familiar to me. But I know Bashira signed it. I signed it.

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Interviewer1:08:15

Would that be La Marcia McDonald maybe?

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Michelle Devore1:08:15

So the three of you signed a lease? About Angel? Well, yeah. Oh, yeah, no, it would have been myself, Marcia, and Bashira.

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Interviewer1:08:26

Is that Angel? No, she's not the landlord. It's that Ikea.

And this lease expired in July of 2014. Okay. Have you renewed it?

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Michelle Devore1:08:56

We are month to month, so I haven't received a renewal.

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Interviewer1:09:06

Who pays the rent?

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Michelle Devore1:09:06

JMI issues the rent, but the staff all come together. Those, you know, and Bashira and Angel and Marcia and I help as well. And we all help pay.

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Interviewer1:09:21

Is that through donations?

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Michelle Devore1:09:21

No. We have everybody has their own type of income.

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Interviewer1:09:28

So when you say you all come together, but JMI pays it, how does that happen?

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Michelle Devore1:09:34

We give the money to Ashley to make the deposit into one account, into our main account. I believe it's... what are the four numbers? I believe it's 2449.

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Interviewer1:09:47

So now you're month to month here we are. And who is... I'm going to butcher this name... Aguio? Landlord. Who do you know who he is?

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Michelle Devore1:09:59

I mean, I've met him.

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Interviewer1:10:06

Do you have a relationship with him business or otherwise?

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Michelle Devore1:10:06

I do not personally.

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Interviewer1:10:16

Does JMI have an office in St. Louis in the city itself?

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Michelle Devore1:10:23

No.

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Interviewer1:10:23

Do they have any offices in Missouri?

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Michelle Devore1:10:31

Well, other than the Ministry Center or the JMI, that would be the only one.

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Interviewer1:10:36

Okay. I'm going to show you Exhibit 7 and ask you to read that name.

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Michelle Devore1:10:42

Adrian Linton.

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Interviewer1:10:42

And who was that?

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Michelle Devore1:10:42

She used to live there. She no longer does. She was a volunteer staff member.

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Interviewer1:10:59

Is she still a volunteer?

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Michelle Devore1:10:59

She is.

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Interviewer1:11:06

What was your salary with JMI?

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Michelle Devore1:11:06

$70,000 per year.

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Interviewer1:11:12

And when did you start receiving that?

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Michelle Devore1:11:18

April of 2013, I believe. And then it stopped January 2015.

I

Interviewer1:11:24

Correct. You have a bookkeeper that you identified as Ashley Ware?

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Michelle Devore1:11:32

Correct.

I

Interviewer1:11:32

Is there any other bookkeeper?

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Michelle Devore1:11:32

No.

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Interviewer1:11:39

Do you supervise Ashley?

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Michelle Devore1:11:39

I oversee Ashley.

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Interviewer1:11:39

You primarily supervise everybody there, don't you?

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Michelle Devore1:11:39

Correct.

I

Interviewer1:11:45

Okay. Who are the check signers?

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Michelle Devore1:11:45

La Marcia McDonald, Pastor Taylor. Taylor's also a check signer, but he rarely signs checks.

I

Interviewer1:11:52

And who else?

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Michelle Devore1:11:52

La Marcia. You don't sign checks?

I

Interviewer1:11:59

No, I don't.

M

Michelle Devore1:11:59

You are Laura. Marcia is the only person that has check signing authority?

I

Interviewer1:12:04

That is correct.

Okay. Who was authorized to make charges to JMI debit or credit accounts?

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Michelle Devore1:12:11

Charge, you know, credit card? That would be Marcia, Pastor Taylor, myself, Joseph Bush.

I

Interviewer1:12:23

Who's Joseph Bush?

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Michelle Devore1:12:23

He's a pastor.

I

Interviewer1:12:32

A pastor where?

M

Michelle Devore1:12:32

For JMI. Where does he reside? He resides in Taylor, Michigan.

I

Interviewer1:12:39

The pastor of which church?

M

Michelle Devore1:12:39

Well, he's a pastor under Apostle Taylor for JMI and for... what's the church that operates out of the Taylor building? KFC? Kingdom Family.

I

Interviewer1:12:48

Right. Is he a pastor there?

M

Michelle Devore1:12:48

He has a pastor there, but what I'm referencing is the pastor under Joshua Media Ministries. Okay, so he can use credit cards and debit cards for Joshua Media Ministry?

I

Interviewer1:13:02

You could use the debit card. We don't have a credit card.

Who else?

M

Michelle Devore1:13:17

Angel Jones. And that's pretty much it.

I

Interviewer1:13:24

Does Deborah Frazier have one?

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Michelle Devore1:13:24

She does not.

I

Interviewer1:13:31

And who monitors the debits taken from the account?

M

Michelle Devore1:13:31

That's monitored through Ashley and myself.

I

Interviewer1:13:52

Are there any restrictions or guidelines as to what charges or debits people can use?

M

Michelle Devore1:13:57

We do have restrictions in place now, yes.

I

Interviewer1:14:02

When did you start those?

M

Michelle Devore1:14:02

We started... well, we've always had restrictions as to what people can do and what they could charge, but we've become even stricter with our guidelines recently.

I

Interviewer1:14:13

When is recently?

M

Michelle Devore1:14:18

Recent as two weeks ago.

I

Interviewer1:14:23

What were they before?

M

Michelle Devore1:14:23

They would submit a request that they need to pay for something or they need something and had to have a business reason, and they would submit a paper request.

I

Interviewer1:14:36

No, it would depend. Sometimes they would call in. So they were going to Popeye's Chicken. Would they call in and ask for permission?

M

Michelle Devore1:14:41

They can call in if they were meeting with a pastor, another pastor, or whatever the case may be. Say, 'I'm going to be meeting with this pastor. I need to, you know, to go. We're having lunch and this is what, you know, where we're going or whatever.' We'd say, 'Yes, that's... you know, we have the money in the account. Go ahead and do that.'

I

Interviewer1:14:58

So each and every time somebody accessed the account with a debit card?

M

Michelle Devore1:15:03

That is correct. They asked for permission.

I

Interviewer1:15:08

Yes. And what are the restrictions now that are different?

M

Michelle Devore1:15:08

Well, the restrictions now are based on the guidelines that our tax attorney had put in place.

I

Interviewer1:15:22

Do all these people still have debit cards?

M

Michelle Devore1:15:22

They do not. They never did. They had access to use the debit card, but they didn't have an individual debit card to use. We had a Joshua Media Ministry debit card. One... well, we had one up here and then one down there, and Pastor Taylor had one. So three. So if somebody wanted to use it to buy food, they would have to physically go get the card from someone.

I

Interviewer1:15:44

Which is why I said we have a card up here in Northeast, which Joseph Bush, Pastor Bush, has access to. And then the people down in St. Louis, which is myself, Angel, and then Pastor Taylor obviously because he travels.

So who carries the card from St. Louis?

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Michelle Devore1:15:57

We keep it in a general location there in a lockbox in Taylor... I mean, in St. Louis at the Trail Oaks.

I

Interviewer1:16:10

Has there been discussion about JMI giving Deborah Frazier a debit card?

M

Michelle Devore1:16:23

No.

I

Interviewer1:16:23

Why not?

M

Michelle Devore1:16:30

She would have no reason to have one.

I

Interviewer1:16:36

Mr. Taylor testified at his deposition that you told him that Deborah Frazier had helped with the attorney fees for JMMI.

C

Counsel1:16:50

Objection. Form, foundation. Also an improper method of cross-examining, but you can go ahead and answer the question if you can.

M

Michelle Devore1:16:55

I honestly wouldn't know. I don't know what was discussed at the previous deposition.

I

Interviewer1:17:02

I'm telling you that Pastor Taylor testified that you advised him that Deborah Frazier had assisted with the attorney fees for JMI. So I'm asking you to explain that. What she assisted with and how that occurred.

C

Counsel1:17:19

Same objection. Go ahead. Answer the question.

M

Michelle Devore1:17:25

I honestly don't recall.

I

Interviewer1:17:31

You don't recall that?

M

Michelle Devore1:17:31

I don't recall that.

I

Interviewer1:17:38

You talk about the conversation?

M

Michelle Devore1:17:38

No, I mean, I don't recall what he was referring to.

I

Interviewer1:17:44

Okay. Did you have a conversation with Deborah Frazier about the attorney fees?

M

Michelle Devore1:17:44

Not that I recall, no.

I

Interviewer1:17:49

Page 240. I'm going to read this into the record. On page 238 from the deposition of February 10th, I'm inquiring of Mr. Taylor as to whether Deborah Frazier paid his attorney fees, and Mr. Taylor responds, 'Yes, I found out.' Question: 'Yes, you found out that in the amount of $7,500?' Answer: 'I don't know if exactly how much it was.' Question: 'Well, there's August 2014. There was a $7,500 deposit, and then in September of... actually, I have... I was talking about my eyes. I couldn't read, but then I corrected and say on the same day, their income $7,500 and out goes $7,500. Frazier versus Frazier retain a retainer fee for Hertz Schram.' So is your understanding, and this is JMMI's documents, that Deborah Frazier gave the $7,500 on your behalf?' Answer: 'Not that I know of, no.' Question: 'Well, what did you find out later?' Answer: 'I found out that she paid for some legal fees for me to have an attorney. So that's all the details I know.' Question: 'Would that be the Hertz Schram people or some other lawsuit?' Answer: 'I don't know. I'm not sure.' Question: 'Well, is there some other lawsuit that you're involved in?' Answer: 'No, not that I know of, no.' Question: 'So is it your understanding that Deborah Frazier paid your legal fees to Hertz Schram? Is that involved in and out of JMI?' Answer: 'I understand. I don't know who it was given to. I just heard that it happened. So you probably want to ask Michelle that question.' Question: 'Did you hear this?' Answer: 'I can't remember. I don't know exactly.' Question: 'Who did you hear it from?' Answer: 'Michelle shared it with me.' Question: 'So Michelle told you that Deborah Frazier paid your legal fees?' Answer: 'Yes.'

So can you tell me about that exchange you had with Mr. Taylor regarding Deborah Frazier paying your attorney fees?

M

Michelle Devore1:20:42

I honestly do not remember Deborah Frazier saying that she was going to pay or that she paid the attorney fees. I do recall the conversation that Pastor Taylor is referring to in terms of him saying, you know, we need to pay these attorney fees. We need to get these attorney fees paid for. But I do not recall...

I

Interviewer1:21:05

You don't recall what?

M

Michelle Devore1:21:05

I don't recall Deborah Frazier paying our attorney fees.

I

Interviewer1:21:11

Do you recall Deborah Frazier making a donation on or around the time that you had to pay your attorney fees?

M

Michelle Devore1:21:17

No. I do recall a conversation that I had with Deborah Frazier in speaking with her about the attorney fees from Hertz Schram. And in my frustration, I had mentioned that to her. You know, she had asked, 'Did you get the attorney?' because she had also wanted to get an attorney or got an attorney from Hertz Schram. I can't remember his name. Anyway, she said... I told her I was frustrated. I said, 'This doesn't even have anything to do with us, you know. They're asking for attorney.' But she never told me, 'Okay, I'm going to go and take care of your attorney fees.' No. And I did discuss that with Pastor Taylor that she had paid something? No. I discussed with him that I had talked to Deborah about our attorney fees and that I was frustrated about that we had to pay the attorney fees.

I

Interviewer1:22:14

All right. His testimony is that you told him that she was contributing in some manner to the payment.

M

Michelle Devore1:22:20

If he said that, then that's the truth. If he said that, then he's absolutely correct. I just don't recall. I don't remember.

I

Interviewer1:22:28

All right. So do you believe then, based on what I just read to you, that Deborah Frazier in some way contributed to the payment of the attorney fees for Hertz Schram?

M

Michelle Devore1:22:39

If I discussed it with Pastor Taylor and he said that she... that I said that to him, yes. But the $7,500 that you guys are referring to in that, I do not know where that came from. No.

I

Interviewer1:22:48

Okay. But you do acknowledge that Deborah Frazier in some manner contributed to the payment of attorneys?

M

Michelle Devore1:22:53

What I acknowledge is that if Pastor Taylor said that that happened, that conversation happened with you and that is with he and I. And if he said that I told him that the attorney fees that Deborah was contributing in some way to the attorney fees, if he said that, then that conversation did happen.

I

Interviewer1:23:11

And would you be lying to Mr. Taylor at that point?

M

Michelle Devore1:23:17

I don't lie.

I

Interviewer1:23:17

Okay. So you're saying you don't recall that conversation?

M

Michelle Devore1:23:17

I do not recall the specifics of that conversation.

I

Interviewer1:23:23

Do you recall being upset about getting a bill or having to pay $7,500 as a third-party witness to issue a subpoena duces tecum and supply all these documentation for a party that we're not directly involved in?

M

Michelle Devore1:23:30

Yes. So this was an offshoot of Deborah Frazier's problems that resulted in you, after hiring you, having to hire an attorney?

I

Interviewer1:23:48

Correct.

Okay. And so if Mr. Taylor says the two of you had that conversation and that you represented Deborah Frazier paid some of your attorney fees, saying that that would have been a truthful statement?

M

Michelle Devore1:23:59

Absolutely. If he said it, that's true.

I

Interviewer1:23:59

Okay. But you're saying you don't have any recollection of how that occurred?

M

Michelle Devore1:24:05

I do not know.

I

Interviewer1:24:20

I'm going to answer to... eight nine... that goes later. Okay. Hold on to that. I'm looking for... I don't know if you took it back. The document you brought about the $7,500.

Okay. I am going to ask you to identify Exhibit Number 8. Show it to me too.

M

Michelle Devore1:25:56

That's JMMI's ledger sheets, correct, provided by JMMI to Mr. Frazier's counsel pursuant to discovery requests.

I

Interviewer1:26:13

Yes. Exhibit Number 8 looks like it is a general ledger, right?

M

Michelle Devore1:26:22

Yes.

I

Interviewer1:26:22

And I'm going to ask you to read the annotation for August 27, 2014.

M

Michelle Devore1:26:30

It says, 'Source not disclosed yet.' The whole line: 8/27/2014, source not disclosed yet, amount $7,500, and then the balance in that account.

I

Interviewer1:26:51

Correct. And then another arrow for August 27, 2014. If you can read that line across.

M

Michelle Devore1:27:22

It says 8/27/2014, Tram check 6 0 9 6 maybe, retainer fee for Frazier versus Frazier, negative $7,500.

I

Interviewer1:27:37

Okay. Now who would have physically prepared this document?

M

Michelle Devore1:27:44

Ashley.

I

Interviewer1:27:52

And you oversee Ashley, correct?

M

Michelle Devore1:27:52

Correct.

I

Interviewer1:27:52

Okay. So when this says 'source not disclosed yet,' what does that mean to you?

M

Michelle Devore1:27:58

Knowing Ashley, it means that she didn't have the information, but she knew she had to try to get it if she could.

I

Interviewer1:28:10

Would it mean that she was aware that a donation was made but not by whom?

M

Michelle Devore1:28:17

It absolutely does mean that. If she received a deposit in and she checks the accounts every day, then she would have something in there. But as you can see, there was no record as to who deposited that.

I

Interviewer1:28:32

All right. I'm going to ask you to review these exhibits 2-1 and 2-2. And is it accurate that after you paid the $7,500, there was a balance of $18,915 in that account?

M

Michelle Devore1:28:51

That is correct.

I

Interviewer1:28:57

And is that the main account?

M

Michelle Devore1:28:57

This would have been the main account.

I

Interviewer1:29:03

Yes. All right. So Exhibit 2-1, what is your understanding of what that is?

M

Michelle Devore1:29:10

This is a counter credit or counter deposit. This is an out-of-state counter deposit. And this document is an account activity transaction detail.

I

Interviewer1:29:27

And what is 2-2?

M

Michelle Devore1:29:27

Exhibit 2-2 is an expense account activity summary, and it shows check number 6 0... I'm sorry, counter credit of $7,500 and then a check... 8/26/2014, a check for $7,500. But the date on the counter credit shows that's 8/27, and the check stated 8/26.

I

Interviewer1:30:06

And this also shows the counter credit for 8/27. What's this? So you're referring to this round? 2-1 was that? 2-1? I'm sorry, 2-1.

And you don't know who wrote this counter credit for the deposit of the $7,500?

M

Michelle Devore1:30:26

I do not know who wrote that.

I

Interviewer1:30:26

And would it be fair to say that Ashley Ware would have tracked down who the source of this deposit for $7,500 was?

M

Michelle Devore1:30:33

It's not fair to say. No. I asked her, and she didn't know.

I

Interviewer1:30:50

If she physically handled a check that was a deposit or contribution, wouldn't she have marked down who it was from?

M

Michelle Devore1:30:58

If she knew who it was from, she would have. But if she didn't know who wrote it, she wouldn't have. But if you're looking at a check, she didn't look at a check. It looked like it was a counter deposit that she was not aware of. Per Exhibit 2-1, it shows a counter credit by out-of-state counter credit. We're in Missouri. This was done somewhere else.

I

Interviewer1:31:17

So it's your belief that somebody went to the bank and deposited $7,500 in the general account?

M

Michelle Devore1:31:23

That is correct.

I

Interviewer1:31:29

In an out-of-state location?

M

Michelle Devore1:31:29

That is correct.

I

Interviewer1:31:36

And you don't know the source of it?

M

Michelle Devore1:31:36

I do not. And Ashley, from what your conversations with Ashley are, she does not know the source of it.

I

Interviewer1:31:43

That is correct. Wouldn't that be important to know because of tax reasons?

M

Michelle Devore1:31:43

No, not necessarily. If somebody wants to give an anonymous donation, which we get quite often, it's up to them as to whether or not they want to be notified.

I

Interviewer1:31:56

But it's not anonymous if it's a check and there are names on it.

M

Michelle Devore1:31:56

Well, it's not a check. It looked like it was a counter deposit. They could have deposited with cash.

I

Interviewer1:32:11

I think this is marked 'check' on the ticket.

M

Michelle Devore1:32:17

No, it doesn't look like it's smart check. All of those have 'check' next to them. Right, that line is checked. Well, I don't have a copy, and I can't say this is what we received was this, and it could have been... I don't know. I'm not just going to speculate.

I

Interviewer1:32:36

Where did you get this document from?

M

Michelle Devore1:32:36

Ashley. I had her print off anything as related to the per your subpoena addendum to the subpoena. You had asked for anything that we have pertaining to the $7,500, and that's what I asked her to pull whatever she could, and that's what she gave me.

I

Interviewer1:32:56

So the same day or within 24 hours or so that you have to pay $7,500 to Hertz Schram as the retainer, you have to answer... Oh, yes, I'm sorry. You get what you say is an anonymous contribution of $7,500?

M

Michelle Devore1:33:20

That is correct.

I

Interviewer1:33:27

And you say that you have no way of knowing who deposited that for you at an out-of-state location?

M

Michelle Devore1:33:32

That is correct.

I

Interviewer1:33:32

And around that time or thereabouts, you had a conversation with Deborah Frazier where you expressed some exasperation about having to pay $7,500 to an attorney to represent JMI with regard to her issues?

M

Michelle Devore1:33:45

That is correct.

I

Interviewer1:33:51

Did you express any displeasure with Deborah Frazier at that time?

M

Michelle Devore1:33:57

I never had displeasure towards her. It was towards the situation.

I

Interviewer1:34:02

Okay. Let's see if we can clip those together.

Okay.

That's it. And if we go off the record for one minute.

We are going off the record. It is 11:23 a.m.

We are back on the record. It is 11:26 a.m.

I am going to ask you to identify what's marked as deposition Exhibit 9-2.

M

Michelle Devore1:36:20

Yes. Exhibit 9-2. It's a deposit and credit bank statement, part of the bank statement off of account ending in 2449 from JMMI.

I

Interviewer1:36:36

Correct. Joshua Media Ministries. Okay. And I'm going to ask you to look at the two dates that are circled as July 14, 2014, and ask you to read that across.

M

Michelle Devore1:36:52

Okay. 7/14/14, counter credit $5,000. And 7/14/14, counter credit $5,000.

I

Interviewer1:37:06

What's your understanding of a counter credit?

M

Michelle Devore1:37:06

As I stated earlier, counter credit is when you would make a credit or deposit over the... you know, at the bank, at the bank in person.

I

Interviewer1:37:19

Yes. Can you tell where that deposit was made?

M

Michelle Devore1:37:29

Can I tell? No. It just says counter credit and then $5,000 and $5,000.

I

Interviewer1:37:42

Okay. I'm going to show you Exhibit 9-1. Ask you to identify that.

M

Michelle Devore1:37:50

Okay. Exhibit 9-1. This is one of the general ledgers that Ashley keeps.

I

Interviewer1:38:02

And there are two circles on that document, and it's around July 12, 2014. You want me to read it across?

M

Michelle Devore1:38:17

Right. Okay. July 12, 2014, source is JMI June Crusade Promise Seed from Deborah Frazier, $5,000. And then 7/12/2014, JMI June Crusade Promise Seed from Deborah Frazier, $5,000.

I

Interviewer1:38:41

All right. So from your understanding of these two documents, would it be accurate that Deborah Frazier donated $10,000 to JMMI ministry on or about July 12, 2014?

M

Michelle Devore1:38:54

That is correct.

I

Interviewer1:39:05

Do you have any idea as to why the donations are listed in two separate line items both on 9-1 and 9-2?

M

Michelle Devore1:39:18

I do not know why, honestly.

I

Interviewer1:39:33

Okay. So you don't know if it was in cash or check?

M

Michelle Devore1:39:33

I do not know if it was in cash or check.

I

Interviewer1:39:38

Is that something Ashley would know?

M

Michelle Devore1:39:38

It's possible, yes.

I

Interviewer1:39:44

Is that something you can ask for and find out?

M

Michelle Devore1:39:44

Yes, I can.

I

Interviewer1:39:54

Is Ashley working and available today?

M

Michelle Devore1:39:54

She is.

I

Interviewer1:40:01

Okay. All right. So then I'm going to show you what was marked as... about that... yes. Okay. I'm sorry. Which she wanted just a note to remember to ask Ashley the question. And you made a note of that?

M

Michelle Devore1:40:14

I have made a note of that and a few others.

I

Interviewer1:40:22

Well, that's the big one so far. I'm also going to show you what is marked not only as Exhibit 1 from February 11, 2015, but today we've marked it for today's purposes as March 12, 2015, and ask you to identify that.

M

Michelle Devore1:40:50

Okay. Exhibit Number 10. This is a for Joshua Media Ministries detailed statement, January 1st, 2014 to December 31, 2014, for Deborah Frazier.

I

Interviewer1:41:02

And can you read line item 6/12/2014?

M

Michelle Devore1:41:11

6/12/2014. It says 'Crusade Donation' $10,000.

I

Interviewer1:41:20

And what does this column say?

M

Michelle Devore1:41:20

It says 'Check Number' and then 'Tax.' And what does 'Tax' mean?

I

Interviewer1:41:36

I have no idea what that means on that report or statement.

C

Counsel1:41:36

Could it mean if you know that they were given the 99s showing the... well, that's what just said. Objection. She said she didn't know. This isn't... this is her statement for her tax return.

I

Interviewer1:41:55

Okay. This is Debbie's. And who would have drafted this document?

M

Michelle Devore1:41:55

Ashley probably.

I

Interviewer1:42:01

Can you ask her what 'Tax' means on this?

M

Michelle Devore1:42:01

Yes, I can.

I

Interviewer1:42:12

So these three documents taken together from your business records would substantiate that Deborah Frazier made a $10,000 contribution in July 2014 to JMI?

M

Michelle Devore1:42:30

That is correct.

I

Interviewer1:42:30

Okay. Do you recall or do you know if you personally were involved in any of this in terms of ever handing you the check or processing it?

M

Michelle Devore1:42:46

I'm sorry. Deborah would not have handed me a check, no. And I do not recall any personal dealings with this.

I

Interviewer1:42:53

Do you not receive money personally on occasion?

M

Michelle Devore1:42:53

People will hand me an offering envelope, and then it goes into... we have two people who count the cash. The cash offering envelopes, usually cash. No, it could be credit cards on top of the offering envelope. Yes, they write their credit card information. It has a space for credit card information. That's something I would feel comfortable doing.

I

Interviewer1:43:21

So who would be the possibilities of who Deborah handed these funds to on this date?

C

Counsel1:43:33

Objection. Form and foundation. Go ahead and answer the question if you can.

M

Michelle Devore1:43:38

I wouldn't have any idea.

I

Interviewer1:43:45

You don't know?

M

Michelle Devore1:43:45

I would not know. Nobody marks who received the money.

I

Interviewer1:43:52

No, for what source? Whether it was the offering or somebody handed somebody the check. He's just telling you not to... you know, wait until she finishes the question. Exactly. Go ahead.

M

Michelle Devore1:43:58

There's no mechanism for that kind of accounting when somebody gives an offering. If they do not want it to be anonymous, they complete an offering envelope, and it goes into... if it's during a service, it'll go into an offering bucket. If it's not during service and they just want to make a natural donation over the phone or whatever, it's different. It comes in different ways. If they have it documented on an offering envelope, we do record that and do have record of that.

I

Interviewer1:44:32

Okay. If someone mails in a donation, is there any mechanism where you indicate this was mailed in as opposed to an offering bucket?

M

Michelle Devore1:44:38

Yes. To answer your question, if it was a document or an offering envelope that we... let me rephrase that. If it was an offering that was received at the place that we do business in St. Louis either via mail, PayPal, over the phone on a credit card, we keep record of that separately and document how this came in. If it was during service and they put it down on an offering envelope, we have record of that.

I

Interviewer1:45:10

So you do differentiate by what means the offering came in?

M

Michelle Devore1:45:16

Correct.

I

Interviewer1:45:16

So then why don't we have that for the $7,500?

M

Michelle Devore1:45:22

Because we don't have record of who gave that donation.

I

Interviewer1:45:30

But it's by check.

M

Michelle Devore1:45:30

Well, we do not have it listed by check.

I

Interviewer1:45:38

Well, this document would indicate it's made by check. Across the line it says 'check' $7,500. And this was apparently made at the counter. And your other document shows 'source not yet disclosed.'

Do you believe that the scenario was that someone out of state, out of town, went and deposited into your account... yours mean JMI... a check for $7,500, and because it didn't get mailed in or through the offering bucket, you didn't know who it was from?

M

Michelle Devore1:46:29

What I believe is that I don't know if it was a check or cash. We looked. We do not have record of the check. There was $7,500 that was donated and it was put into our account. Right. If they directly took the check to this out-of-state bank, you wouldn't have a copy of that. We wouldn't have a copy if they took it and deposited it from out of state, unless they made it payable to JMMI. I do not have copies of checks now.

I

Interviewer1:47:18

You didn't ask the bank for a copy of the check?

M

Michelle Devore1:47:18

We have no copy of a check.

I

Interviewer1:47:23

You didn't ask the bank for a copy of the check that somehow mysteriously gets deposited?

M

Michelle Devore1:47:23

Ashley called the bank, and what she was supplied was what I showed you on Exhibit 2-1. This one. And this is what was given to us: a counter credit and a deposit transaction detail. I do not have a copy of the check.

I

Interviewer1:47:43

No, I understand that. But you could get that through your account.

M

Michelle Devore1:47:51

According to Ashley, there was no check deposited. That's what I'm saying. She believes it was cash. We believe it was cash.

I

Interviewer1:48:03

Okay. I didn't hear you say that before. I'm sorry. So Ashley believes it was cash?

M

Michelle Devore1:48:03

That is correct. From an anonymous source that somehow had all your account information.

I

Interviewer1:48:10

Which is correct. Would you give your account information over the phone to somebody that was anonymous?

M

Michelle Devore1:48:17

If it... no, not anonymous. If it was somebody who had wired money in our account before, they would have that. Our credit card... I mean, they would have our bank account information.

I

Interviewer1:48:29

Deborah Frazier's wired money in before, hasn't she?

M

Michelle Devore1:48:34

She has.

I

Interviewer1:48:34

So you believe she would already have the account number?

M

Michelle Devore1:48:41

It's possible.

I

Interviewer1:48:41

Do you know... have you ever seen Deborah Frazier's handwriting?

M

Michelle Devore1:48:46

I mean, I have seen it.

I

Interviewer1:48:46

Would you be able to have an opinion as to whether that was Deborah Frazier's handwriting?

M

Michelle Devore1:48:52

I would not.

I

Interviewer1:49:01

Okay. So based on your conversations with Ashley, you believe that somebody went to an out-of-state branch of Bank of America and deposited $7,500 in cash. It did not disclose their name to you but had the bank account numbers?

M

Michelle Devore1:49:17

That is correct.

I

Interviewer1:49:30

And then the very same day, according to your ledger which is marked Exhibit Number 8, a $7,500 check goes out to Hertz Schram for a retainer for Frazier versus Frazier?

M

Michelle Devore1:49:42

That is correct.

I

Interviewer1:49:57

I don't know if I asked you... on those $5,000, the two $5,000 donations that Deborah made in July 2014, do you know or is it possible... do you know if these were in cash?

C

Counsel1:50:25

Objection to the foundation.

M

Michelle Devore1:50:32

Exhibit 9-2, I have no way of knowing what it was.

I

Interviewer1:50:37

Would Ashley know?

M

Michelle Devore1:50:37

She would not know unless it was listed on an offering envelope.

I

Interviewer1:50:44

But when you make a deposit, wouldn't you have to show that on your deposit slip?

M

Michelle Devore1:50:52

It depends on how it was made. Well, it says counter credit, right? This was a counter credit of $5,000. Right. So somebody... it would be your understanding went to the counter and deposited this?

I

Interviewer1:51:08

Yes. Somebody went and made a deposit for the two $5,000 checks or cash or whatever it is.

Okay. And now that's the same day that you received the funds from Deborah Frazier for the June Crusade?

C

Counsel1:51:41

Objection. There are too many disjunctions there. Could you rephrase it so we're clear what you're trying to connect?

I

Interviewer1:51:53

The 7/14/2014 counter credits for $5,000 each, and you see that, yes. Okay. That is the same day you received a $10,000 offering or donation from Deborah Frazier, is it not?

M

Michelle Devore1:52:10

Correct.

I

Interviewer1:52:16

And that was based on the June Crusade. She... I think we showed you a document where it was referenced as seed money from the June Crusade, and she actually made the donation in July.

M

Michelle Devore1:52:32

I don't know. Let me show you the July 12th statements that we had. You read the two July 12th. This was her promise. It looks like her promised seed for $5,000 and her crusade promised seed for $5,000. And that's listed on Exhibit 1, and it's for July 12.

I

Interviewer1:53:01

All right. Is it your understanding that... oh, I'm sorry. Did you get this from? Let's look at it right here. Oh, okay. I'm going to show you Deposition Exhibit Number 10. Is it your understanding that the June 12, 2014 crusade donation listed on Exhibit 10 of $10,000 actually references a promise made in June to pay that amount, and the funds were actually received July 12, 2014?

M

Michelle Devore1:53:44

Yes, because it's listed 'June Crusade Promised Seed.'

I

Interviewer1:53:54

Okay. So these two documents in your opinion are consistent, correct, referencing one donation of $10,000 promised in June, actually received in July? And you're referring to Exhibit 10 and 1?

M

Michelle Devore1:54:07

Yes.

I

Interviewer1:54:16

So who would know or what document would show whether these donations which you have identified are from Deborah Frazier were by check or cash?

M

Michelle Devore1:54:27

Ashley. And I can ask her.

I

Interviewer1:54:45

Okay. Okay. All right. So can you talk to Ashley about that?

M

Michelle Devore1:54:51

I can. I want to make another note about that one.

I

Interviewer1:54:56

These are documents that are kept in the regular course of your business?

M

Michelle Devore1:55:03

Which documents are you talking about, counsel? Still the same? 1, 10, and 9-2?

I

Interviewer1:55:10

Yes.

M

Michelle Devore1:55:10

The 9-2 is a bank statement, and 9-1 and Number 10, Exhibit 10, is Debbie's detailed statement for her tax purposes that's issued in January of every year of whoever's given. And Exhibit 1 is a general ledger that we do maintain in the day of the course of business.

I

Interviewer1:55:30

All right. And so all these are things that you maintain in the regular course of business?

M

Michelle Devore1:55:36

That is correct.

I

Interviewer1:55:36

And all these documents are documents that you have access to and knowledge of based on your position as... what you told me the title was?

M

Michelle Devore1:55:51

Executive Officer.

I

Interviewer1:55:51

Executive Officer. Is that true? Can you... these documents that we just identified, they're kept in the regular course of business, and that's true?

M

Michelle Devore1:55:58

That is true.

I

Interviewer1:56:03

And as Executive Officer, you have knowledge of these documents and are aware of their contents?

M

Michelle Devore1:56:10

I am now, yes. That is correct.

I

Interviewer1:56:15

Okay. And you are able to... when you say 'I have now,' is that because you never had reason to have to look at them specifically? These specific ones?

M

Michelle Devore1:56:22

I've never looked at these specific ones before.

I

Interviewer1:56:28

Okay. But you know they exist?

M

Michelle Devore1:56:28

Correct.

I

Interviewer1:56:34

And that these kind of documents are generated on a regular basis?

M

Michelle Devore1:56:34

Correct.

I

Interviewer1:56:34

And that if you have need to look at a particular one, you have access to it?

M

Michelle Devore1:56:42

Correct.

I

Interviewer1:56:42

And that you in fact did access these kinds of documents to pull these specific ones related to Deborah Frazier?

M

Michelle Devore1:56:53

Correct.

I

Interviewer1:56:53

All right. And these were provided by JMMI in response to discovery requests?

M

Michelle Devore1:57:00

Correct.

I

Interviewer1:57:00

All right. And so you've indicated that you have personal knowledge of these documents and that you've reviewed them prior to coming to this deposition today?

M

Michelle Devore1:57:13

No. I reviewed them unfortunately right now, and we just went over them.

I

Interviewer1:57:18

Okay. Is that because you've given us boxes of documents and you didn't personally touch each one?

M

Michelle Devore1:57:24

That's correct.

I

Interviewer1:57:24

Okay. But you have knowledge of these as having been kept in the regular course of business with JMI, correct, in your role as Executive Officer?

M

Michelle Devore1:57:36

I want to say administrator, but that's wrong.

I

Interviewer1:57:44

Okay. Change. We are going off the record. It is 11:48 a.m.

U

Unknown1:57:58

Too many times people get fickle funny about their money. They're like, 'Oh man, okay, there it goes.' You get uncomfortable. That's a devil. If you get any kind of uncomfortable, you feel any kind of squirming in you, it's a devil. You need to rebuke it and keep going because he's trying to keep you from your blessing. So right now we're giving you an opportunity to come forward and give an offering unto God, unto the Most High. And you need to just trust in him no matter what happens that it's going into the best, most integral place on earth: God's kingdom. And it will be used as you can even see, look around, everything is used for the kingdom. Amen. Everything is used to reach souls. You have a part in that. So put your offering in and let it be sacrificial. Don't be stingy to God because he ain't stingy with us. You feel uncomfortable? I'm sorry, I don't care. You better shake that devil loose and you better put something down in the offering because it's for you, not for us. And every single person in here should be giving something. I don't care if you don't have but a nickel, you put that in there. Where's David? Where's Mr. Taylor? Where's Mr. Taylor? Don't call him David. And I don't owe you any explanation.

Part 1 of 3, Deposition of Michelle Brannon: Per Apostle David E Taylor “Axe Michelle”

About Michelle Devore