Deposition of Vickie Anders 12/24/96
<!***** Document starts here ***********************> IN THE CIRCUIT COURT OF THE STATE OF OREGON
FOR THE COUNTY OF JACKSON
In the Matter of the Marriage of:
SUSAN SAMORA COUTSOUKIS,
and CASE NO. 94-3846-D-3
TELEPHONE DEPOSITION OF VICKIE ANN ANDERS
PERPETUATION OF TESTIMONY
BE IT REMEMBERED THAT, pursuant to stipulation
of counsel for the respective parties hereinafter
set forth, the telephone deposition of VICKIE ANN
ANDERS 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 Tuesday, December 24, 1996, beginning at
the hour of 8:04 a.m., at the law offices of
Patricia Crain, 800 West 8th Street, in the City of
Medford, County of Jackson, State of Oregon.
ON BEHALF OF THE PETITIONER:
CRISTINA SANZ, ESQ. Attorney at Law 900 West 8th Street Medford, Oregon 97501
ON BEHALF OF THE RESPONDENT:
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 VICKIE ANN
ANDERS 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
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.
INDEX OF EXAMINATION PAGE
DIRECT EXAMINATION BY MS. CRAIN 5
CROSS-EXAMINATION BY MS. SANZ 8
INDEX OF EXHIBITS
INDEX OF INFORMATION REQUESTED BY COUNSEL
INDEX OF OBJECTIONS MADE BY COUNSEL
1 VICKIE ANN ANDERS,
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:
8 DIRECT EXAMINATION
9 BY MS. CRAIN:
10 Q Please state your full name.
11 A Vickie Anders.
12 Q And where do you reside?
13 A At 3121 Cheltenham Way, Medford, Oregon.
14 Q How are you employed?
15 A At Sizzler.
16 Q What do you do at Sizzler?
17 A I'm a hostess.
18 Q How long have you been employed at Sizzler?
19 A 18 years.
20 Q As part of your employment at Sizzler have you
21 come in contact with Mr. and Mrs. Coutsoukis?
22 A Yes.
23 Q How is it that you came to be in contact with
25 A They came in the restaurant and I was their
(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 VICKIE ANN ANDERS 6
1 hostess or had to serve them lunch.
2 Q And how long have you known them?
3 A Good question. Over a year, I think, maybe
5 Q Have you known both of them the same amount of
7 A No. I probably know Photius a little longer.
8 Q How frequently does he come into the Sizzler to
9 eat lunch?
10 A Everyday -- he went from four to five days a
12 Q During the times that he comes in, does he bring
13 his daughter?
14 A Yes, most of the time.
15 Q And have you observed her relationship with him?
16 A Yes.
17 Q Can you tell us what you've observed about their
19 A He's the most caring father I've ever witnessed
20 ever in my restaurant. He takes extremely good care of
21 her. He's focused on her needs during the whole lunch.
22 He is very caring. He never gets upset with her. He's
23 absolutely wonderful with her. I've never seen a father
24 more dedicated to a daughter, ever.
25 Q Does he, on occasion, then, take her outside and
(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 VICKIE ANN ANDERS 7
1 walk around with her?
2 A Uh-huh. He plays with her outside and then will
3 bring her in and she'll have dessert, you know, whatever
4 else he can get her to eat. He likes to get her to eat,
5 which she does pretty well.
6 Boy, yeah, he plays with her outside and -- for
7 quite awhile actually. Then they come back in and have a
8 little more lunch.
9 Q And do they appear affectionate with each other?
10 A Oh, yes.
11 Q Okay. Did you see the mother with the child?
12 A Not very often. Probably under five times I
13 would think have I seen her.
14 Q And do you recall the first time that you saw
15 her with the child?
16 A The first time I seen her with the child, she
17 came up -- I don't know if it was exactly the first time.
18 It might have been the first or second time, but it was of
19 a very few times I've actually seen Teddy unhappy
20 throughout the lunch. She cried. She never cries and
21 this time she cried a lot. I don't know why, what was
22 going on at the table because I'm not right there all the
23 time. She was acting up more than I've ever seen her act
24 up when her mother was there the first couple of times.
25 After that, she was fine.
(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 VICKIE ANN ANDERS 8
1 Q Did you think that -- did you realize at first
2 that the mother was, in fact, the mother?
3 A Yeah, because I knew -- Photius had told me she
4 was coming in and stuff. So, yeah, I knew that that was
5 the mother.
6 Q Do you recall making a statement to Photius how
7 you thought that, perhaps, she was the baby-sitter or
8 something like that?
9 A Gosh, I don't remember. I might have. I can't
10 recall that.
11 Q Okay. During the times that you did see the
12 mother with the child, did the child seem as attached to
13 the mother as to the father?
14 A No. She's more attached to Photius. There's no
15 question about that.
16 MS. CRAIN: I don't think I have anymore
17 questions. I believe the other attorney may have some
18 questions for you.
19 THE WITNESS: Okay.
22 BY MS. SANZ:
23 Q Hi, Vickie. This is Cristina Sanz.
24 A Hi there.
25 Q How are you doing today?
(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 VICKIE ANN ANDERS 9
1 A Great.
2 Q Okay. I just have a few questions.
3 When you say that Photius and Teddy go outside
4 to play, how many minutes are they out there?
5 A Oh, goodness. They go out, like, I don't know,
6 10, 15 minutes, then he'll bring her back in, eat a little
7 bit, and then they might go out and play again before they
8 leave and stuff. So he's out there quite a bit with her.
9 Q And then they go out again another 10, 15
10 minutes or so?
11 A Probably not that long the next time. I
12 wouldn't think they spend -- maybe. It changes once in
13 awhile. It depends on how much energy she has that day.
14 Q So approximately how much a second time? Less
15 than the first time, but --
16 A Yeah, I would say probably 10 minutes or so.
17 Q And what do they do?
18 A He gives her piggyback rides and he walks with
19 her and then he let's her walk. He's always right next to
20 her. He never leaves her side.
21 Q Okay. Do you know whether Teddy has any kind of
22 medical problems or health problems?
23 A I would assume she does. I don't know exactly
24 what they are.
25 Q Has Photius ever talked to you about that?
(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 VICKIE ANN ANDERS 10
1 A Not in-depth by any means. He said she had
2 neurological problems, but that's the extent of what he's
3 told me.
4 Q Did he blame it on anyone in particular or any
5 event in particular?
6 A I think he -- I think it had something to do
7 with his divorce. I don't know. I think it was something
8 like that, that she went through a lot of trauma and
9 stuff. That's what he contributes it to.
10 Q Her health problems are due to the trauma of the
12 A Yeah, I think that's what he said, something
13 along those lines.
14 Q Anything else you recall about that?
15 A Nope.
16 Q Does he ever speak negatively about Mrs.
17 Coutsoukis in front of Teddy?
18 A No, not that -- huh-uh. When Teddy is there, he
19 barely rarely even talks to me. He's very focused on her.
20 But, see, Teddy leaves a lot of the times earlier in the
21 day, and then he'll come back in and finish his iced tea
22 and stuff. Then -- so he's actually there without her
23 after lunch quite a bit.
24 Q And when you're -- do you ever join them for
(541) 732-1988 ADVANCED COURT REPORTING (800) 343-3396 (541) 474-7883 & VIDEO SERVICE (541) 488-5745 VICKIE ANN ANDERS 11
1 A No.
2 Q So when you know what's going on at a table,
3 it's when you're actually helping with a meal or
5 A Yeah, I check on them quite frequently and make
6 sure they don't need anything or napkins or drinks or
7 anything like that.
8 Q And you're by --
9 A I'm in that section within viewing distance I
10 would say 70 to 80 percent of the time.
11 Q So that's how you've drawn your observations
12 basically by being in the same section that they are in?
13 A Yes, because you can hear them talk out of the
14 corner of your ear. It's not that you're there hovering
15 over their table listening to them, but you watch them
16 throughout the dinner.
17 MS. SANZ: All right. Thank you.
18 THE WITNESS: Thank you.
19 MS. CRAIN: Okay, Vickie. I think that takes
20 care of it. We appreciate you doing this at 8 o'clock in
21 the morning.
22 THE WITNESS: No problem.
23 (Deposition concluded at 8:10 a.m.)
(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 29th day of December, 1996, 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
25 <!***** Document ends here ***********************>
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By Photius Coutsoukis, Respondent.
"I Was There"
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