FOR THE COUNTY OF JACKSON

In the Matter of the Marriage of:

SUSAN SAMORA COUTSOUKIS,

Petitioner,

and CASE NO. 94-3846-D-3

PHOTIUS COUTSOUKIS,

Respondent. _________________________________/

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. 

APPEARANCES ii

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

REPORTED BY:

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 

STIPULATION iii

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

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. 

INDEX iv

INDEX OF EXAMINATION PAGE

DIRECT EXAMINATION BY MS. CRAIN 5

CROSS-EXAMINATION BY MS. SANZ 8

INDEX OF EXHIBITS

(None)

INDEX OF INFORMATION REQUESTED BY COUNSEL

(None)

INDEX OF OBJECTIONS MADE BY COUNSEL

(None)  5

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:

7 ///

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

24 them?

25 A They came in the restaurant and I was their

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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

4 longer.

5 Q Have you known both of them the same amount of

6 time?

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

11 week.

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

18 relationship?

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

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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.

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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.

20 ///

21 CROSS-EXAMINATION

22 BY MS. SANZ:

23 Q Hi, Vickie. This is Cristina Sanz.

24 A Hi there.

25 Q How are you doing today?

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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?

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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

11 divorce?

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

25 lunch?

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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

4 assisting?

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.)

24

25 --o0o--

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1

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

4

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.

20

21

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