Deposition of Toni Hulse 12/30/96
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 TONI FRANCIS HULSE
PERPETUATION OF TESTIMONY
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.
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 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
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 12
REDIRECT EXAMINATION BY MS. CRAIN 16
INDEX OF EXHIBITS
INDEX OF INFORMATION REQUESTED BY COUNSEL
INDEX OF OBJECTIONS MADE BY COUNSEL
1 TONI FRANCIS HULSE,
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 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
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.
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1 Q How long a period of time were you their
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
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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
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?
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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
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
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
25 Q And was this the whole time that you worked
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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
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
24 A Oh, no. She had playtime by herself. She had
25 to have playtime by herself.
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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.
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2 BY MS. SANZ:
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
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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
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
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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.
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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
15 A No.
16 Q Have you ever witnessed him physically abuse
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.
22 REDIRECT EXAMINATION
23 BY MS. CRAIN:
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
9 (Deposition concluded at 2:25 p.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 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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