..... Theodora


Deposition of Toni Hulse 12/30/96



In the Matter of the Marriage of:



and CASE NO. 94-3846-D-3


Respondent. _________________________________/



BE IT REMEMBERED THAT, pursuant to stipulation

of counsel for the respective parties hereinafter

set forth, the telephone deposition of TONI FRANCIS

HULSE was taken on behalf of the Respondent as a

witness in perpetuation of testimony, before Linda

M. Murphy, Certified Shorthand Reporter, State of

Oregon, on Monday, December 30, 1996, beginning at

the hour of 2:15 p.m., at the law offices of

Patricia Crain, 800 West 8th Street, in the City of

Medford, County of Jackson, State of Oregon.



CRISTINA SANZ, ESQ. Attorney at Law 900 West 8th Street Medford, Oregon 97501


PATRICIA CRAIN, ESQ. Attorney at Law 800 West 8th Street Medford, Oregon 97501


LINDA M. MURPHY Certified Shorthand Reporter, No. 93-0259 Registered Professional Reporter

ADVANCED COURT REPORTING & VIDEO SERVICE 909 West 8th Street Medford, Oregon 97501

Ashland Office: 288 Maywood Way Ashland, Oregon 97520

(541) 732-1988 (541) 488-5745 (541) 474-7883 (800) 343-3396 (541) 732-1987 FAX


PURSUANT TO STIPULATION between the respective

parties herein, the telephone deposition of TONI FRANCIS

HULSE was taken on behalf of the Respondent as a witness

in perpetuation of testimony, before Linda M. Murphy,

Certified Shorthand Reporter, State of Oregon, at this

time and place, on oral interrogatories to be propounded

to said witness pursuant to Oregon Revised Statutes.

IT IS STIPULATED AND AGREED that all irregularities

as to notice of time and place and manner of taking said

deposition are hereby waived, each party reserving the

right to object at the time of trial to any question or

answer as to the competency, relevancy or materiality

thereof, but that objections as to the form of the

question or responsiveness of the answers must be made at

the time of taking said deposition or shall be deemed to

be waived.

IT IS FURTHER STIPULATED that the reading and signing

of said deposition by the witness is hereby expressly

waived and that the certificate of the reporter taking the

deposition shall fully authenticate the same.











(None) 5


2 called as a witness in perpetuation of testimony

3 on behalf of Respondent being first duly sworn

4 to testify the truth, the whole truth, and

5 nothing but the truth, was examined and testified

6 as follows:

7 ///



10 Q Ms. Hulse, we're taking your deposition --

11 perpetuation deposition because, as I understand it, you

12 will be unavailable for trial -- to come up here for a

13 trial, correct?

14 A Right.

15 Q You know Mr. and Mrs. Coutsoukis?

16 A Yes.

17 Q Could you tell us when you met them or how long

18 you've known them?

19 A Well, I started working for them in November of

20 '93.

21 Q And what did you do for them?

22 A I was their housekeeper, I cleaned their house.

23 Q How often were you in their home?

24 A Every week, once a week, for three to four hours

25 a day.

(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 TONI FRANCIS HULSE 6

1 Q How long a period of time were you their

2 housekeeper?

3 A Until September of '94.

4 Q During the time that you would be in their home,

5 would either of the parties be present?

6 A Yes.

7 Q Who would that be?

8 A Either one of them, sometimes both of them. But

9 I didn't see Susan very often. It was usually Photius.

10 Q During the time that you were in the home, did

11 you have occasion to observe Photius with the child?

12 A Yes, I did.

13 Q Can you tell us your observations about his care

14 of and relationship with the child?

15 A He took excellent care of the child. A very

16 loving father, very caring, very conscientious. You could

17 tell he loved that child very, very much.

18 Q What kind of things did he do with the child? I

19 take it she was quite young at that time?

20 A Yeah, she was just a baby. Well, he fed her, he

21 made her own food and fed her and bathed her and changed

22 her and played with her. She had to have physical therapy

23 for her leg and he did that and, you know, just tried to

24 make sure that she had a well rounded life.

25 I mean, he took her for walks, he took her to

(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 TONI FRANCIS HULSE 7

1 the store, you know, spent a lot of time with her.

2 Q Could you tell whether or not he and the child

3 were bonded with each other?

4 A Oh, definitely. Oh, definitely. There was no

5 question there. I mean, when Photius walked into the

6 room, she just lit up. She definitely knew that was her

7 daddy.

8 Q During the time that he cared for the child, did

9 you ever observe whether she was sick?

10 A There was one time that I saw her sick and

11 that's when Photius and Susan, I guess, had split up for

12 two or three weeks and Susan had put her in a care center.

13 And when she came home about three weeks later, I observed

14 that she seemed to be sick. I never seen her sick before.

15 Q How did she act as best you recollect when she

16 was sick?

17 A She was real quiet, withdrawn. She acted

18 withdrawn. I used to get such a kick out of her because

19 when I came over to the house, I'd say hi to her and she'd

20 just start smiling and her eyes would light up, I mean,

21 she loved people and she was always a very happy baby.

22 And this one day I observed her she really didn't care

23 whether I was there or not.

24 Q And was that while the parties were separated or

25 do you remember?

(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 TONI FRANCIS HULSE 8

1 A Well, he had come home then, he had come back to

2 the house.

3 Q Okay. Did you observe any change in the child

4 after Photius returned home?

5 A She went back to her normal self, being healthy.

6 Q Okay. Do you recall when this separation

7 occurred?

8 A Oh, gosh.

9 Q Could it have been in about January of 1994?

10 A I'm going to say it was around the holidays. I

11 have this letter here in front of me and it says January

12 of '93. I'm going to say around the holidays. I don't

13 know for sure an exact date or anything.

14 Q But since you didn't start working for them

15 until late '93, presumably it would have been after the

16 holidays in '94?

17 A Yeah, yeah, yeah.

18 Q After the parties separated, was there a

19 difference in the home in what it looked like?

20 A Yeah. It was evident that Susan working full

21 time and trying to be a full-time mother, she really,

22 really needed me as a housekeeper.

23 Q And do you know how child care got arranged for,

24 how Susan did that?

25 A No, I don't, huh-uh.

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1 Q Okay. Did you ever observe Photius to interview

2 child care providers?

3 A Yes. He interviewed several people for

4 baby-sitters, and he didn't want a baby-sitter that was

5 going to sit in front of the television all day. He

6 wanted a baby-sitter that would spend quality time with

7 his daughter and take very good care of her and he was

8 very adamant about that. And if you didn't, you left.

9 It's that simple.

10 Q Did you ever see the mother interact with the

11 child?

12 A Yes. There was times when Susan came home from

13 work. If I was having a late day, I would be there later

14 than normal, and you could tell that Susan loved her

15 daughter very, very much.

16 Q Were you able to form an opinion as to which

17 parent was the primary parent?

18 A I would have to say Photius.

19 Q Did you observe the relationship between the

20 parties, between Photius and Susan?

21 A Yes, I did.

22 Q What was that -- how was that relationship?

23 A Well, I thought they were rather hostile to each

24 other.

25 Q And was this the whole time that you worked

(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 TONI FRANCIS HULSE 10

1 there?

2 A Yeah. You know, I didn't see Susan and Photius

3 together a lot. But I'd say the times that I did see them

4 together, which was maybe anywheres from 15, 20 minutes to

5 a half hour, it seemed to me like there was hostility,

6 which I thought was very sad because children pick up on

7 that so easy.

8 Q During the time that Photius cared for the child

9 and was in the home, did you notice whether or not the

10 child ever had diaper rash?

11 A The only time I knew of that, that she had a

12 diaper rash, was when she was in the care unit.

13 Q And that's when the parties were separated?

14 A Yes.

15 Q Photius at that time then was not caring for

16 her?

17 A Right.

18 Q Did you at any time feel that his attention

19 towards the child was inappropriate?

20 A No.

21 Q Did he on occasion leave the child or allow the

22 child to play by herself or was he giving her constant

23 attention?

24 A Oh, no. She had playtime by herself. She had

25 to have playtime by herself.

(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 TONI FRANCIS HULSE 11

1 Q And how did she react to that?

2 A Well, sometimes she'd be fussy. Sometimes, you

3 know, she acted like, I don't want to do this right now.

4 I want you to hold me, and he would just say no. Here are

5 your toys and you're perfectly safe, you're okay, and

6 would allow her to play by herself. And she'd fuss for

7 awhile, but then she'd get busy doing something and forget

8 all about it.

9 Q Did you ever hear any conversation between the

10 parties about the care of the child?

11 A Once in awhile I did. I can't come out with

12 specific words, but it seemed to me like sometimes Photius

13 thought maybe things weren't done quite, you know, the way

14 he thought they should be done. And Susan said something

15 to the effect of, you know, it's okay, you know, if it

16 takes a couple of minutes before I get to her, you know,

17 it will be all right, you know. But I just kind of felt

18 that was kind of normal.

19 Q Okay. Were you aware of who primarily did the

20 cooking, the shopping and the care --

21 A Oh, Photius did. All the time.

22 MS. CRAIN: Thank you, Toni. I don't have any

23 other questions. The other attorney may have some

24 questions for you.

25 THE WITNESS: Okay. Thank you, Pat.

(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 TONI FRANCIS HULSE 12



3 Q Hi, Ms. Hulse, my name is Cristina Sanz.

4 A Hi.

5 Q Hi. I'm Susan's attorney.

6 A Uh-huh.

7 Q Let me just ask you a few questions.

8 You stated that when you were working for the

9 Coutsoukises you would not see Susan very often. She was

10 working out of the home at that time?

11 A Oh, yes.

12 Q She would sometimes come home during the day to

13 nurse Teddy?

14 A Sometimes.

15 Q And then, of course, you were there only about

16 three or four hours a day one time a week?

17 A Right. Yeah.

18 Q Did you notice when father and daughter were

19 together, when father, Mr. Coutsoukis was providing care,

20 would he do anything odd -- that seemed odd to you in

21 terms of his care for his daughter?

22 A No, not at all, not to me.

23 Q How about in terms of his attitude about

24 parenting or that sort of thing?

25 A No, it wasn't odd to me at all. Photius felt

(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 TONI FRANCIS HULSE 13

1 that because she was a helpless baby, you know, that

2 she -- she should be cared for promptly.

3 I mean, I teased him one time, I remember I

4 teased him once, and I said, you spoil her, you know.

5 She's going to grow up knowing that if she snaps her

6 fingers, daddy is going to come running. But I think

7 every little girl and daddy have that relationship and

8 Photius's comment to me was, when she got old enough to

9 fend for herself, then things might change.

10 Q How old was she at the time?

11 A Oh, gosh. She wasn't walking. You know, I'm

12 sorry. I don't have any recollection of ages and dates

13 and times very well.

14 Q Okay. You also testified about the time when

15 you saw Teddy ill?

16 A Uh-huh.

17 Q This is when the parents were separated?

18 A Well, you guys kind of misunderstood me. They

19 had been separated and I didn't see any of them for three

20 weeks.

21 Q Okay.

22 A Okay?

23 Q During that -- when she was ill, the marriage

24 probably was going through --

25 A Right.

(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 TONI FRANCIS HULSE 14

1 Q -- problems?

2 A Right, right. And then I came to the house on

3 my regular day and here was Photius with Teddy.

4 Q When he returned?

5 A Yeah, it was when he returned and he was taking

6 care of the child again, that is when I noticed that she

7 was sick.

8 Q Did he blame anyone for her illness?

9 A As far as to my ears, he blamed the caretaker.

10 Q And who was the caretaker?

11 A Whatever nursery she put -- Susan put her in.

12 She put her in a nursery was what I understood.

13 Q Was there stress in the home?

14 A Yes, there was.

15 Q What kind of illness did she have?

16 A She had a cold. She had a terrible cold, which

17 I know kids get, I realize that. But she had a diaper

18 rash, which she never had before and she was depressed.

19 Q Diaper rash?

20 A Diaper rash.

21 Q Did you change her diapers?

22 A No, but I was right there. I mean, sometimes

23 I'd talk to Teddy while Photius changed her.

24 Q But it wasn't part of your duties or --

25 A No, no. I was there strictly to clean the

(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 TONI FRANCIS HULSE 15

1 house.

2 Q And you didn't take it upon yourself to

3 routinely change her diapers?

4 A No.

5 Q Were you there during every diaper change?

6 A Not every one, no.

7 Q You mentioned he was interviewing baby-sitters.

8 Was there a time when he had a baby-sitter also caring for

9 Teddy when he was at home?

10 A Oh, yes. He had a business that he had started

11 in his own home and he had taken one of the back bedrooms

12 and turned it into an office with computers. I'm too dumb

13 to understand what his business was, but there were times

14 where he desperately needed to go back there and shut the

15 door and make phone calls and get some work done. And at

16 that time, that's when he would have a baby-sitter take

17 care of Teddy in the house. But I noticed that it seemed

18 to be mostly in the afternoon, like, between maybe three

19 and five.

20 Q Now, other than the bad cold that she had, did

21 you know whether she had any other medical problems?

22 A No. I knew that she had some type of medical

23 problem that required some physical therapy for her legs.

24 Q Do you know what that was?

25 A No, hon, I don't.

(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 TONI FRANCIS HULSE 16

1 Q Did Photius talk to you about it?

2 A He had mentioned it to me, but he didn't explain

3 it very well to me, so I really didn't understand it.

4 Q Did he talk to you about why she was, you know,

5 blame anyone as to why she was having these problems?

6 A No.

7 You know, I want to say one thing right now.

8 Photius never put Susan down in any way, shape or form.

9 Q You anticipated my question.

10 Did he ever speak negatively about her in front

11 of her daughter?

12 A No, no, never.

13 Q Have you ever witnessed him verbally abuse

14 Susan?

15 A No.

16 Q Have you ever witnessed him physically abuse

17 her?

18 A No. But I'm only there three or four hours once

19 a week, you know. I don't live with him.

20 MS. SANZ: Thank you.

21 ///



24 Q Toni, I have one follow-up question.

25 Did you ever observe Susan to be verbally

(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 TONI FRANCIS HULSE 17

1 abusive towards Photius?

2 A Not verbally abusive. That's too strong.

3 What's the word I want? Short with him, rude. I would

4 say rude, yes.

5 Q And was this in front of the child?

6 A Yes.

7 MS. CRAIN: I think that's all we have. Thank

8 you.

9 (Deposition concluded at 2:25 p.m.)


11 --o0o--















(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745


2 STATE OF OREGON ) ) ss. C E R T I F I C A T E 3 County of Jackson )


5 I, LINDA M. MURPHY, do hereby certify that:

6 At the time and place heretofore mentioned in

7 the caption of the foregoing matter, I was a Certified

8 Shorthand Reporter, in and for the State of Oregon;

9 That at said time and place I reported in

10 stenotype all testimony adduced and proceedings had in the

11 foregoing matter;

12 That thereafter my notes were reduced to a

13 computer-aided transcript and that the foregoing

14 transcript is a true and correct transcript of all such

15 testimony adduced and proceedings had and of the whole

16 thereof, to the best of my ability.

17 IN WITNESS THEREOF, I have hereunto set my hand

18 this 2nd day of January, 1997, in the City of Medford,

19 County of Jackson, State of Oregon.



22 ___________________________________ LINDA M. MURPHY 23 Certified Shorthand Reporter Certificate No. 93-0259 24


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By Photius Coutsoukis, Respondent.

"I Was There"

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