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Baggs Letters

 Affidavit of facts showing how the defendants violated ORS 166.175 - 16.735


William F. McIver



Ulys Stapleton, Clyde Hammersly,
Joshua Marquis, Bernice Barnett,
Sharon Gribble Cunningham, James Huegli,
Betty Baggs Hutton, Bill McGowan,
Robert Huckleberry, Hillari Palatnik,
Maureen O'Boyle, Muriel Ries,
Bradley Avakian, Michael Menzies,
Nancy Hawkins, William Kennemer,
Stan Mazur-Hart, Rives Kistler
and unnamed Does



I, William F. McIver II, PhD., swear:

          I am a psychologist who testified in various states as an expert witness in cases of alleged sex abuse.  I said prosecutors, including Lincoln County's, sometimes took advantage of national hysteria about the subject to prosecute bogus charges.1  And some judges went along for political reasons.  I criticized psychologists, caseworkers, and prosecutors about the biased way they interviewed children in these cases.  I claimed psychologists and psychiatrists hired by prosecutors & parole boards often wrote phony personality evaluations.  And sex offender treatment programs they touted didn't work.2


          I consulted in school,3 day care center and divorce cases, and audio or videotaped all interviews with children start to finish. Parents, counselors, plaintiffs, and prosecutors, sometimes watched through a one-way mirror.  Children frequently denied saying things caseworkers and prosecutors claimed they said in unrecorded interviews.4


          The Newport News Times published an article of mine in 1984.  I said in cases of alleged sex abuse the Lincoln County DA's office and Children's Services Division showed the same zealously selective inattention to truth as Massachusetts witch hunters in 1692.5


          As a direct result of my views, the defendants made and circulated false civil and criminal charges against me to ruin my reputation and put me out of business. They claimed:

A) I had sex with a patient, Betty Baggs (Hutton),6 who filed a civil malpractice case, &

B) I had a secretary alter Baggs' time in an appointment book they said would have been evidence in a civil trial.7  Lincoln Co. prosecutors filed a criminal case.


          I settled the civil case out of court on my attorney's advice.8,9  In the criminal case I was found guilty of tampering with a witness and evidence and sent to Oregon State Penitentiary.10  Judge Robert Huckleberry, in a post conviction appeal, saw physical evidence the time slot wasn't altered.11  He heard experts (including the state's) testify they could find no sign of alteration.  Yet, he (& co-author Bernice Barnett) lied in a Memorandum of Opinion about the expert's testimony and the physical evidence they examined to uphold the tampering conviction,


          The defendants associated as an enterprise-in-fact to violate ORS 166.175 - 166.735.  The shared purpose of this enterprise was to ruin my reputation and stop me from working as a clinical psychologist and expert witness.


          The defendants committed multiple acts constituting a pattern of racketeering activity starting before 5/85 through 3/25/93,12 and beyond.  They allow their violations to go uncorrected.  Their actions continue to injure me, since as a 71 year old convicted felon I can't get a license to earn a living practicing my profession.  Each defendant did things necessary or helpful to the enterprise.


          The core issues of this case are the truth or falsity of:

A) The claim Baggs - Hutton and I had sexual contact of any sort; &

B ) The claim I tampered with evidence and a witness by having an ex-secretary erase a name written at 5: PM in a 12/16/83 appointment book page and rewrite it at 1: PM.


Evidence lawyer Jim Huegli & Betty Baggs Hutton fabricated her malpractice complaint:

1) Her conflicting claims in civil & criminal trials, depositions, an affidavit, & the TV tabloid, A Current Affair.

2) Her false sworn statements in depositions & an affidavit, & perjury in civil & criminal trials.

3) Lawyer Jim Huegli's conversion of stolen patient's records to enhance the case, his subornation of perjury & false testimony.



          In May 1985, Jim Huegli (then with Schwabe, Williamson, and Wyatt) filed a sex mal practice claim against me.13  He didn't even try to verify his client's allegations.  He boasted to The Oregonian he had "proof positive" his claim was true.  He sent copies of the complaint to lawyers and prosecutors in cases where I was to testify.  He had his client complain to the Psychology Licensing board.  Then he discovered she'd had sex with Jesus 3 times while He was on the cross.14  This, and other readily available facts Huegli hadn't uncovered, led him to agree to sign papers to drop his case.


          Before signing, however, he contacted my secretary, Sharon Gribble,15 and ex-secretary Mary Dobson. Gribble gave him Betty Hutton's name as a dissatisfied former patient who once called the office to dispute a bill. He solicited Hutton to file a bogus sex malpractice action against me.16, 17, 18


          Hutton swore falsely about circumstances under which she retained Huegli's services:  In a 4/15/86 deposition she testified she retained him when he went to her home a week after he first called her.  Then, in a 7/23/86 deposition, she claimed she retained him immediately after he called and introduced himself.  He objected to all questions about this contact:


Hutton vs. McIver, 85-1318 (4/15/86)19

Q. (By Ms. Martyn) During the first time you had these discussions with Mr. Huegli by phone, did you retain him as an attorney?

A. No.

Q. Do you recall when you retained him as your attorney?

A. I'm not sure.  I talked to him in person first.

Q. So you had - - Did you have more than one phone discussion before you talked to him in person?

A. No.

Q. So you had one phone conversation and then you talked to him in person.  Where did you meet him in person?

Q. Okay. And at that meeting, did you retain him as your attorney?

A. Yes.

Q. How did you retain him as your attorney?

A. I just asked him to represent me.

Q. Did you sign any kind of retainer agreement?

A. Yes.

Q. ----- that day?

A. Yes.


          Then, in a 7/23/86 deposition, Hutton changed her testimony to cover the sequence of events surrounding Huegli's trip to her home in Waldport to solicit her to sue:

Hutton vs. McIver, 85-1318 (7/23/86)20

Q. ... During the last continuation deposition, we were discussing your first contact with Mr. Huegli.  And you testified that Mr. Huegli had given you a phone call.  And, at that time, you were unsure of what time of the year or month you received a phone call from Mr. Huegli.  Do you have any better recollection at this point in time when you received a phone call from Mr. Huegli?

A. It was either at the end of August or the first of September of '83.

Q. Okay. Would that be of'85?

A. Okay.  '85.

Q. 1985.  Okay.

A. Sorry.

Q. And he asked you if you'd been a patient of Dr. McIver; is that correct?

A. Yes.

Q. What else was discussed during that phone conversation?

A. He asked me if - if I had been a patient of Dr. McIver.  And if I would be willing to answer any questions regarding Dr. McIver for another client of his,

Q. Okay. And what was your response?

A. A question.  I asked him if he will represent me.

{ lawyer discussion}

Q. Is it your testimony now that on that first conversation with Mr. Huegli, your second response to him was then would he represent you?

A. Yes.


          Hutton's change in testimony is belied by Dr. Suzanne M. Paulsen, to whom Dr. Robbins referred her after Huegli wrote "It is very important that this nice lady receive a psychiatric referral."21  In a 3/26/86 deposition taken for Hutton vs. McIver. Dr. Paulsen testified Hutton told her: "... some lawyer called her and wanted her to participate in a suit against Dr. McIver for improper sexual activities."22


          Hutton changed her testimony to cover the fact Huegli called to solicit her to sue.  He collaborated in this falsely sworn declaration.  Even though, during the 4/15/86 deposition, he claimed that, at this time, she was a "potential witness."23  Thus, admitting he didn't represent her.


          Had he said she became a client the instant after his greeting, Ms. Martyn wouldn't have requested a court order to let her ask about his first contact.


          Huegli called Hutton after she married Robert Hutton.  The couple had critical financial and marital problems.24  She filed for bankruptcy on 3/22/84, two months after they married.25  He drank heavily.  She told her physician, Jerry Robbins, MD., he physically abused her.  She abused prescription drugs,26 and was later hospitalized for drug abuse. She had attempted suicide.27


          A computer printout of her 5/16/83 psychological test results shows Betty Hutton marked the following items "True":28

-           There is something wrong with my mind.

-           Someone has been trying to influence my mind.

-           I hear strange things when I am alone.

-           Sometimes I feel as if I must injure either myself or someone else.

-           Most of the time I wish I were dead.

-           I don't seem to care what happens to me.

-           Much of the time I feel I have done something wrong or evil

-           No one cares much what happens to you.

-           At times I think I am no good at all.

-           I cannot do anything well.

-           At times I feel like picking a fist fight with someone.


          Betty Hutton admitted that, during the time she claimed we were having sexual relations, she was so disturbed Dr. Robbins and I wanted her to commit herself.  On July 1, 1983, she told Dr. Robbins' physician assistant she had taken "a fistful of Valium," bought a gun & planned to shoot herself & her dog.29  She was in a "vegetative" state, "huddled in the corner of the room, speech very slow, that sort of thing."30  Dr. Robbins thought she was "hoarding" and "abusing" drugs.31  His nurse called me over.  I found her hunched on the floor in tears & lifted her to her feet.  She didn't want to commit herself and we allowed her to go home.32, 33


          Her claims in her initial complaint, trials, affidavits, and depositions, are replete with contradictions:


- Before Huegli called her, Hutton told Arlen Quan, M.D. she hadn't had sexual relations with me.34  But after Huegli's call she sued alleging she had sex with me in my office.35


- She said we had sex "two or three occasions, I guess."36  Then, she changed it to twice.37  (In a 1996 deposition she said she didn't remember if it was more than once.)38


- But after she filed the suit, she told Dr. Robbins we had intercourse "several times," which left him with implication it was "...more than three, three or more" times.39  She told psychology licensing board members she had sex with me at least twice in 1983.40

- She said she had sexual relations with me "three or four months" after she started seeing me in 5/4/83.  Sometime in July or August 1983.41  However, this was after she started going with Robert Hutton, and attended his 7/11/83 birthday party.  A friend said during this time she and Robert were together "... almost every free moment."42


- Betty Hutton claimed she didn't meet Robert until 8/16/83.43  But on 8/1/83 she told Dr. Robbins "... she was seeing a man and that their relationship had developed to the extent that it was becoming a sexual relationship and she wanted some protection against becoming pregnant."44


- Dr. Robbins testified the man wasn't me.  "The implication of that was that this new relationship was the relationship that turned out to be her present marriage."45  She asked for birth control.46  He gave her Norinyl 1/50 on 8/1/83.47


- She said Robert didn't stay overnight at her home before they were married.48  But he'd moved out of Eagles Nest apartment # 8 on 12/1/83 and left her telephone number & address.49  When arrested on 12/5/83, he listed Betty Baggs' home ( Box 8865, Highway 101) as his and said he'd been living with her three days.50


- She professed she wasn't on birth control pills the end of August 1983,51 although she'd started on 8/1/83.


- In a 4/15/86 deposition she said we had not had sex in my office.52  In her civil complaint she said we had sex in the office.53  But in the civil trial she said it was in her home, not the office.


- She told Dr. Robbins we had sex in her home and the office.54  In a 10/23/85 deposition she said it wasn't in the office it was in her home.55  She said, although I asked her to, she didn't perform oral sex in my office.56  But on A Current Affair, she indicated she did perform oral sex in my office.  In the criminal trial she said we had sex two times, both at her home, not the office.57  And, there was no sex in the office, just "sexual misconduct."58, 59  Earlier, in the same trial she testified we had intercourse in the office and her home.60


- On 3/14/96 Hutton again stated we had intercourse at her house and the office.61  Then she claimed she never said there was intercourse in the office.62  When subsequently asked if she alleged there was intercourse in the office she said she didn't remember.63  This turned into: "The oral sex was in your office."64  Asked again if there was office intercourse, she said, "I don't think so."65


- She didn't remember if there was intercourse a third time in her home or anywhere else.66  Or how often it allegedly took place in the office,67 but said it took place at her house "once or twice, I'm not sure."68  She said she thought the first time was in her home during the Summer of 1983, but "I'm not sure."  It could have been June, but "I'm not positive."69


- She said she didn't remember if the alleged second time occurred Summer or Fall 1983.70 She didn't remember the time of year the alleged office intercourse occurred, or the month, or whether it was winter.71  Or if it was more than once.72  Or if it was morning or afternoon.73


- Although she previously testified the sexual relationship took place sometime in July or August 1983,74 in 1996 she "wasn't sure."  She didn't remember if the office sex happened on her 3rd visit, May 16, 1983.75  Or if it was on the 4th visit, May 20, 1983.76

- She didn't know the day, month, or season when the first intercourse at her home allegedly occurred.77


          Huegli had Hutton complain to the Oregon Board of Psychologists to make his case look better.  But, in an affidavit he later wrote for her, he said: "Sometime between the civil and criminal trial described above, I filed a complaint against McIver with the Oregon Board of Psychology Examiners ("OBPE") for his sexual misconduct toward me."78


          He knew this wasn't true.  He'd filed the complaint with the Board on 9/5/85.79  A day before he filed Hutton's civil complaint in Lincoln County on 9/6/85.  The civil trial (Hutton vs. McIver) was in 9/86.  The criminal trial (State vs. McIver) was in 8/88.80


          Some psychology board members (including Courtney Goodmonson & Nancy Hawkins) immediately announced they were going to revoke my license no matter what the trial outcome.  The Board assigned William Kennemer & Nancy Hawkins to investigate.81, 82


          On 8/1/85 Chair, Mazur-Hart, sent a letter inviting me to contact them.  But they wouldn't answer my calls or letters.  So on 9/20/85 I told them my insurance company lawyers, Ron Stephenson & Chrys Martin, asked that all communication about the cases be through them.


          Kennemer & Hawkins also wouldn't communicate with me through my attorneys or give them any information.  They wouldn't allow me to give my side of the case, or tell us who witnesses were to allow me to confront them.  On 12/16/85 the attorneys told them substantial information established the Ward - Hutton complaints were without merit.  They asked Kennemer & Hawkins to hold off issuing a report until after the civil trials, when they could make this information available.  Kennemer & Hawkins refused.  They recommended license revocation before 4/15/86,83 five months before trial, without fully investigating.  Ostensibly, because of the unadjudicated, unsubstantiated, charges alone.  In their rush to revoke, they denied due process and refused to avail themselves of the following evidence:


- Dr. Quan, 5/17/84: Hutton said she had never had intercourse with me. [E. 49 D)

- Jerry Robbins M.D.'s notes on Hutton. [E. 115, A- C)

- Hutton's Division of Workmen's Compensation file.

- Betty Hutton's letters to her deceased husband and me. [E. 135 - 156 ]

- Betty Hutton's 10/23/85,4/15/86,7/26/86 depositions.

- Robert Hutton's deposition.

- Ron Robert's 2/20/86 affidavit about Mrs. Hutton and her new husband's possible motivation for suing. [E. 194 C ]

- Ward's medical file, including North Lincoln Hospital records.

- Documentation of Ward's contacts with porno distributors before her 1st appointment with me. (She had claimed I introduced her to pornographic paraphernalia); [E. 119 CD]

- Documentation of Ward's sexual liaison, before she met me, with a customer of the store where she clerked, (She had claimed her alleged contact with me was her 1 8t such in 20 years. )


          Kennemer & Hawkins refused to examine documents which would have shown:

- Stark contradictions in Hutton's trial, deposition, and affidavit testimony.

- Hutton changed her testimony to obscure the fact Huegli solicited her to sue;

- Huegli, to enhance his suit, committed theft, violating ORS 164.043 Theft in the 3rd degree; & ORS 164.095 Theft by receiving.


          Kennemer & Hawkins made their notes of contacts in these cases unavailable.


Evidence prosecutors fabricated tampering charges:

1) The readily visible three - dimensional physical reality of the appointment book page.

2) Photomicrographs and scientific testimony that incontrovertibly prove it wasn't altered.84


          The primary evidence is a 1" x 2" time slot for 5: PM on a 12/16/83 page in an Ideal appointment book.85  Prosecutors claimed I had Mary Dobson erase, from this page, the name "Betty Baggs" written at 5: PM, and rewrite it at 1: PM.  They copied the original during the 9/86 Hutton vs. McIver trial.  Stapleton, Hammersly, &, later, Barnett, saw the original.  Which means they could only have seen signs it had not been tampered with.  In Oregon vs. McIver they displayed a copy, though it couldn't conceivably show signs of tampering not on the original page.


          Because it's physically impossible to see, in the 5: PM time slot of the original, any signs of tampering which defense & state experts in a 1/17/92 post conviction trial86 testified they couldn't detect.  And which independent scientists at McCrone Associates, Inc., a laboratory specializing in ultramicroanalysis, microscopy, and solid state chemistry, cannot detect with state of the art techniques.  They concluded: "...we could find no evidence whatsoever that a name had been written in the 5:00 P.M. slot and subsequently erased or otherwise altered.  Because of the physical characteristics of the paper, had an alteration taken place, it would have been quite apparent"87


          Evidence of absence isn't absence of evidence.  It's evidence.  The lack of alteration is readily confirmed and verifiably certain.88  It's tangible, rock solid, proof clearly visible to the naked eye.  The slot's just a three-dimensional slice of untouched compressed paper fibers with no indentation, smudge, smirch, or even ultramicroscopic trace, of graphite.


          During the Hutton vs. McIver trial, after discussing patient privilege, Judge McMullen took the appointment book into his office to examine the 12/16/83 page.  He later said he examined three entries and found no signs of erasure.  However, in a 1/13/92 affidavit for McIver v. Oregon. he swore:


"I did not state, either on or off the record, that I had examined Dr. McIver's appointment book on the day that Mrs. Mary Dobson testified about and found there was no erasure.  Not only do I not recall doing so but it would also be inconsistent with what I believed to be true.  In my estimation there had been an instruction or request by Dr. McIver to the appointment secretary to make a change.  In addition, on my estimation, the requested change had been made.  The claims to the contrary conflict with my actual belief.  I know that I would not say anything like that because it would not be proper for me as the trial judge to make comments about the truth or falsity of evidence in open court."89


          Prosecutor Richard Hammersly & Detective Mike Menzies backed him up with affidavits.


          Judge McMullen took the book into his office.  The only reason to do this was to examine it.  He equivocated when he declared he "... did not state, either on or off the record, that I had examined Dr. McIver's appointment book on the day that Mrs. Mary Dobson testified about and found there was no erasure."


          However, nine months earlier, 3/26/92, Bernice Barnett stated: "I do believe that Judge McMullen obtained from Dr. McIver the appointment book which was in question, looked at it in camera, and supplied to the witnesses for use in the Bagley/Mrs. Hutton (sic) trial a photocopy in which names of other patients had been taken out."90  Independent observers, including one attorney, noted the event.91


          Judge McMullen lied when he swore: "In my estimation there had been an instruction or request by Dr. McIver to the appointment secretary to make a change.  In addition, on my estimation, the requested change had been made.  The claims to the contrary conflict with my actual belief."

It was physically impossible for him to see anything other than the conclusive absence of the alleged erasure & rewriting. So his "actual belief' could only have conformed with reality.


          I hired Sharon Gribble as full time receptionist / secretary on 9/7/84.  Shortly after this, she (unknown to me) started bilking her insurance company out of money by falsely listing her husband and son as my patients.92  She deposited payments in her personal account at Yaquina Bay Bank.  On at least one occasion, she paid a part time employee $30 in cash, but made out in her name, then endorsed, a business check for $350, which she deposited in her account.


          District Attorney Stapleton & Asst. D.A. Hammersly93 gave Gribble and ex-secretary Dobson immunity from charges of theft and perjury.  These prosecutors used their perjured testimony that I had Dobson alter the appointment time to fabricate criminal charges against me.  Huegli knowingly used this testimony and files Gribble stole to prejudice jurors in his civil case:


          Gribble stole documents from patient's confidential files and gave them to Huegli, who produced them in court in Hutton vs. Mclver.94  She gave Hammersly, Stapleton, detective Menzies, postal inspector Tom Shipley, Assistant A.G. Walt Barrie, & Jeanine McLaughlin (AG's office) confidential information about patients,95 and documents and copies of documents she stole from the office.  At no time in this process was there any judicial supervision.


          Moments before walking off the job on 8/13/85 Gribble used my signature stamp to write herself an unauthorized check for $200.  She also used it to defraud her insurance company by submitting bogus bills for her husband and son's nonexistent treatment.  She repeatedly committed perjury during the Hutton vs. McIver and State vs. McIver trials when she swore: 1) I had her falsify patient's records; 2) I recouped monetary gifts and loans to patients by passing the amount on to their insurance companies; 3) I had her pad bills to insurance companies; 4) I had her (and Mary Dobson) fake patient's test answers; 5) her husband and son were my patients; 6) their insurance bills were legitimate; 7) she gave me cash when they came in for their appointments; 8) I gave her $200 for a vacation when she walked off the job.96


          Gribble testified she started taking files from the office in mid -1984, 97 "over a year" before she quit in August 1985.98  That is, she started bilking her insurance company and stealing patient's records shortly before 9/7/84.  After Stapleton & Hammersly gave her immunity from prosecution and reason to think she could get away with it.  Shortly after I said the Lincoln Co. DA's office prosecuted a patently bogus State vs. Hawkins case.99  And shortly after I impugned their honesty in an article.


          Stapleton and Hammersly also gave Dobson immunity from prosecution in return for:

- Confidential information about my patients;

- Testifying falsely to at least two grand juries100 to get criminal indictments for insurance fraud and tampering with a witness and evidence;

- Perjury, when she testified I went to her home after Hutton vs. McIver was filed and had her change Baggs' appointment time.


          Dobson was Huegli's key witness in Hutton vs. McIver. and the state's chief witness in State of Oregon vs. McIver.  She'd been my secretary since 1979.  My family and I were on vacation when, by telephone, in August 1985, she told me she resigned.  She had Gribble take over.


          She, with Gribble, later gave Hammersly, Huegli, Menzies, and McLaughlin, names of around 100 patients, along with their confidential information.


          Dobson had many health problems.  During the Hutton vs. McIver civil trial, George Kjaer, M.D., testified her test results showed clinical signs of brain damage.101  The last year she worked she became increasingly disorganized.  She couldn't account for more than $30,000 in office funds and more than $150,000 in unsent statements.  I kept her on against the advice of my accountant, Greg Ripke.  She used the appointment book to jot notes, Avon sales, hairdressing and patient appointments, doodle and erase.  I didn't rely on the book because I couldn't make heads or tails of her notes. At the end of each day she posted a piece of paper with the next day's actual schedule on my door.


          After Huegli filed the Ward case (5/15/85) and before he came up with Hutton v. McIver (9/6/85) my insurance company's lawyer, Ron Stephenson, asked to see my appointment book for the time Ward was a patient.  I called Dobson to ask her to decipher it.  Ward's allegations surprised us.  She'd often brought candy, flowers, and other little gifts to the office, and had gone out her way to be pleasant.  Dobson asked me to come to her home.


          However, Dobson later testified I went there to talk about the Hutton case, rather than Ward. Prosecutors built the tampering charge on the claim I went to Dobson's house after Huegli filed Hutton vs. McIver.


          Dobson initially said I went to see her on the 16th or 17th of September 1985.102  Then, she realized she met my secretary, June Helbert, in "May or June,"103 or "July or August" 1985.104  She wasn't certain what month she'd gone to the office on the last of two visits to "talk about the suit just filed" against me and explain her records.  She was certain: 1) the meeting took place before September, and 2) it wasn't about Hutton vs. McIver. This was weeks, even months, before Huegli solicited Hutton.


          June Helbert testified she met Dobson in "mid-July" of 1985.  She said "within two or three days" after this I asked her about the appointment book & told her I was taking it to Dobson's house.  She knew this concerned Ward vs. McIver.  This was before Huegli filed Hutton vs. Mclver.


Mary Dobson's testimony:105

[E. 131 A, L. 7 - 133 A, L. 13-17]

Mr. Connall:
Q. Do you know a woman named June Helbert?
A. I know the name and I think I've met her once or twice.
Q. All right. When did you first meet her?
A. Gosh. I don't know when I first met her.
Q. Okay. Where did you first meet her?
Mr. Marquis: Objection.......
Mr. Connall (continuing) : Do you remember my question?
A. Yes, I do.
Q. Okay.
A. I can't remember if it was up here at the courthouse or-I don't really know. I know I met her and I think she's a blond-haired lady.
Q. Do you recall going to Dr. McIver's office to have a conference with Doctor and meeting here there?
A. That's - - yes. Yes, that's where I met her. Thank you.
Q. Do you know when that was?
A. That would either have been in Mayor June of '85. Of course, I was there several times.
Q. But you only saw her once, didn't you? You were only introduced to her once there, weren't you?
A. Well, I came in one time and she had her back to the door, and she didn't even see me come
Q. Let's go back to when you first met her. Do you recall being introduced to her by
Dr. McIver at Dr. McIver's office?
A. I'm sure that I was.
Q. And you're telling the jury that you met June then under those circumstances in Mayor June of '85?
A. Well, that was the first time I had been back to the office since I left, and if that's when I met her, the first time I went back was either in Mayor June.
Q. All right. That's fine. And you learned that she was working full time, right?
A. Okay. If she was there full time, it would have had to be in July or August. Oh, I can't re- member. Sharon wasn't there to my knowledge.
Q. That's all right. I'm trying - - I'm not trying to be difficult with you about this question, but I want to try to pin this down as best we can. You, I think, are telling me that during the month of May or June of 1985, you went to Dr. McIver's office and there you were introduced to June Helbert, isn't that correct?
A. I shouldn't say in Mayor June, but that I was to his office in Mayor June and then I was back again in July or August and it was one of those times that I did meet her, and one time she had her back to me when I came in.
Q. After going there in July or August, did you then ever go to Dr. McIver's office again?
A. Not to my knowledge. That's been so long ago.
Q. What was the purpose - - why did you go to Dr. McIver's on that day when you met June Helbert?
Mr. Marquis: Excuse me. Objection ...
                        Colloquy, judge & counsel. (cont. P. 372)
Q. ... Do you remember why you went to Dr. McIver's office on the day that you met June Helbert?
A. Because he called and asked me to.
Q. All right. Fine. "He" is?
A. Dr. McIver.
Q. And why did he tell you it was he wanted you to come that day?
A. Because he wanted to talk over the suit that had just been filed against him..
Q. Fine. Did you, after you were introduced to June Helbert, talk about the suit that had just been filed?
A. Yes. That's what I went there for.
Q. Okay. Was there a certain amount of confusion and turmoil in the office at that time, and did you discontinue your conversation about the suit?
A. I didn't know of no confusion or anything else.
Q. Did you complete your conversation about the suit?
A. As far as I know we did.
Q. When you left the office on that day, did you have an understanding with Doctor that he would call you about this suit and get in touch with you?
A. I think he just said he would keep me posted as to what was taking place.
Q. Did you and the doctor agree that he would call you and you and he would get together and talk about the suit?
Mr. Marquis: Objection. May I ask a question in aid of objection?
The witness: No.
The Court: Yes, sir.
Mr. Marquis: Answer the question very closely.  Are we talking about the same lawsuit of Betty Hutton vs. McIver?
The witness: No.  I'm talking about ...
Mr. Marquis: Stop right there ...

[P. 400, L. 17 - 25; p. 401, L. 1 ]

Mr. Connall: Approximately two weeks after you met June, you went back to Dr. McIver's office and there you talked with him about his records?
A. Yes. The first suit.
Q. Was it greater than two weeks, or less than two weeks?
A. I really don't remember.
Q. Well, so that the best you can do with this is about two weeks after you met June?
A. That's just a guess.


Mr. Marquis: Ms. Dobson, are the times Mr. Connall is talking about before September of 1985?
The witness: That's what I'm answering on.
Mr. Marquis: Before September of '85?
A. Yes.

          June Helbert testified I took the appointment book to Dobson's within two or three days after they met in July, 1985:

Oregon vs. McIver, Lincoln Co. # 370940, 370941.

[E. 183 C, L. 9. - E 184 ]

Q. Now, at some point after you went to work for Dr. McIver, could you tell me whether you met Mary Dobson at the office?
A. Yes,
Q. About when was that?
A. I believe it was within - I'd say it was about the first week in July.  Shortly after I came to work.
Q. You came to work in May?
A. Yes. mid-May.
Q. How long was it after you came to work in mid-May was it that Mary Dobson came to the office?
A. As near as I can pinpoint it would be mid-July.
Q. And you were introduced to her at that time?
A. Yes.
Q. And who introduced you to her?
A. Doctor.
Q. All right. Had you been out of the office for a period of time after you went to work in May?
A. Yes. I was down at Girl's State.
Q. Where?
A. Girl's State.  U of O.
Q. For how long?
A. The first week in July sometime.
Q. Before you met Mary Dobson had doctor made any statement to you about legal process being served?
A. Well, I was there when it was served. I'm sorry, is that not - what was the question sir?
Q. That's not my question.  Had Dr. McIver made any statement to you about legal process being served?
A. No.
Q. Were you present in the office on the day when process was served?
A. Yes.
Q. And were you aware of the service of that summons?
A. Yes.
Q. I show you 116 (note: Ward vs. McIver) Is that the summons to which you refer?
A. That's the one that was served then, I believe.
Q. That's the one that was served?
A. Yes.
Q. All right. How long was Mary Dobson in the office that day?
A. The first day I met her?
Q. What?
A. The day I met her?
Q. Yes.
A. Well, I can't tell you how long. I was gone to lunch and she was there after I came back.
Q. How long did she remain there after you came back?
A. About half an hour.
Q. What?
A. About half an hour.
Q. Was it at that time that Dr. McIver introduced her to you?
A. Yes, u-huh.
Q. All right. And could you tell the Court whether after that meeting, Dr. McIver made any statement
to you about his intent to go meet with her?
A. Well, he asked about the appointment book and said he had some questions for her and was
going out to the house.
Q. All right. How long was it after you met Mary Dobson that Dr. McIver asked you about the ap- pointment book and told you he was going to her house?
A. Within two - three days.
Q. Okay. How long - at a later time did Dr. McIver make any comment to you about the appointment book and having met with Mary Dobson?
A. Yes. He handed the appointment book to me the next morning asking about the method of maintaining an appointment book.
Q. And what kind of questions was he asking you about the method of maintaining the appointment book?
Mr. Marquis: Objection. Beyond the scope.
The Court: Objection sustained.
Mr. Connall (continuing)
Q. Was it an extensive discussion with the doctor about the method of maintaining the appointment book?
A. Yes.
Q. All right. to the best of your knowledge when was it that Doctor returned after he had announced where he was going with the book and asked you the questions about the appointment book?
A. The next morning.
Q. About what month was that, do you know?
A. In July.


          Gribble hadn't yet given Huegli Hutton's name.


Mid - July visit.

          Dobson came to the office at my request to discuss her notes & billing system.  She then asked me to come to her home to do it.  As this was the first time I had been there she gave me a tour.  I saw no one else there.  She looked over the book as I wandered about the living room.  I teased her about drawings she'd made, and joked it looked like she'd written a woman's name (not Baggs') in the evening, at around at 7: PM., though none was.  I said something to the effect that it would horrify the insurance company lawyers if it looked like I saw women after hours.  A fleeting, inconsequential spoof.  I neither asked her to erase anything nor thought of stopping her if she did.

It was no more an issue than what she had for breakfast.


          Even though prosecutors cited testimony I gave during the Baggs vs. McIver civil trial to say it was.  They charged it showed I asked her to change Baggs' appointment time.  However, I confused Huegli's first case (Ward), which I went to Dobson's house to discuss, with his second (Baggs).  My testimony appeared to support their assumption.


          Except for the unyielding absence of any alteration.106


Q. (Mr. Huegli): Dr. McIver, did you fabricate any of the Betty Mrs. Hutton records after the lawsuit was filed?
A. Are you talking about my written records?
Q. Any of your records.
A. There was one time when I asked my secretary to check one impossible time.  I asked her to look at the times that people came in, and it was like, as I recall, like an evening appointment and I do not see women in the evening.  I took her [sic] and I took all the notes and I said "Would you look at these and see what explanation you can come up with" and she came up with some explanation and she changes the name, erased or crossed out, and put it where she felt that the time that [sic] Betty actually had come in, it was something like that, and it was upon my request to ask her to take a look to see how they could jive with standard practice.107
Q. Dr. McIver, you asked Mary Dobson, didn't you, to change those records of my client after this lawsuit was filed; isn't that true?
A. After it was filed, I asked her to look at them, just as I explained, I said "Hey, I don't under- stand.  How does this look to you. "
Q. It didn't look good, did it?
A. No. I don't see women at night or whatever it was, and I just asked and she came up with an explanation, I forget what it was, she can tell you. And then she changed it, said "No; oh, it was here she came in" because of one thing or another.
Q. You took that -
A. That was done with my approval.


          But confused testimony can't change the confirmable fact Baggs' appointment time wasn't altered.  It can't change Dobson's testimony she met June Helbert in the office before Hutton vs. McIver was filed, showing I went to her house long before prosecutors said I did.  It can't change Mrs. Helbert's testimony I took the appointment book to Mrs. Dobson's home "Within two - three days" after Ward vs. McIver was filed - in mid-July.


          Dobson called my office repeatedly after Huegli filed the Hutton case.  During this time she was meeting with Huegli, Hammersly, & Menzies.  She spoke with June Helbert and me.  She claimed Hammersly wanted her to go before a grand jury to say something against me, but was vague about what.  She sounded confused.  She had difficulty being specific.  She said he suggested they could charge her son with drug abuse.  And she was terrified Hammersly would have her daughter investigated by CSD for endangering her granddaughter.108


          Dobson told June Helbert and me Hammersly threatened she could "do it the easy way or the hard way."  That is, say certain things to a grand jury or risk having her son and daughter investigated for drug, and child abuse, respectively.  She said Hammersly repeatedly assured her the statements she would make weren't harmful, just part of a larger picture they needed to make a point.


          The picture became clear when she testified I came after Huegli filed Hutton vs. McIver
to have her change Baggs' name from 5: PM to 1: PM.109


          Dobson had apparently mentioned my visit and general conversation to Huegli.  Including my ribbing her about her note taking system and writing some name at 7 o'clock or later. Hammersly and Detective Menzies then spoke with her.  Subsequently, she declared I'd come to her home after Hutton vs. McIver was filed, rather than after Ward vs. McIver.  That I asked her to alter Betty Baggs' appointment time, instead of teasing her about the way she sometimes jotted names in after hours time slots as reminders to bill or call people, etc.


          Huegli then claimed he contacted the DA's office because Dobson told him this latter version.  This allowed him to enhance his civil case, and prosecutors to charge me with tampering with evidence and a witness.


          The bottom line, of course, is photomicrographs and other state of the art scientific tests establish the physical impossibility the paper fibers of the time slot were altered by writing or erasing.  The unequivocal lack of tampering shows:

- The "crime" never happened;

- Dobson lied about altering the record;

- Huegli - Gribble lied in their claim she told them she altered it;

- Stapleton - Hammersly lied when they said Huegli told them Dobson claimed she altered it.

- Stapleton, Hammersly, Marquis, Glode, and Barnett lied when they claimed the record had been altered.

- Stapleton, Huegli, Marquis, and Barnett suborned perjury when they allowed Dobson to testify she altered it.

- McMullen lied when he denied examining it and said he thought it had been altered;

- Huckleberry lied when, after examining it during a post-conviction trial, and hearing experts testify they found no sign of alteration, he ruled it was altered.

- Avakian lied when, after examining the book and reading Dobson's recantation and the state expert's testimony, he ruled it was altered.110

- Assistant Attorney General Rives Kistler lied to apellate judges when he told them the record was altered.  He also lied about what defense & state experts' testimony.111


          I first heard I was a grand jury target when, over a month before the indictment, a prosecutor in Memphis announced it in court 10 minutes after calling the Lincoln Co. DA's office.  Prosecutors tried to discredit me with that information,112 along with the complaints and copies of depositions Huegli took in his civil cases, and the licensing board's notice of intent to revoke my license.


          Also, at this time, I appeared on a Town Hall TV program.  It covered allegations of sex abuse, psychological evaluations, and treatment programs at Oregon State Hospital.  I said much of this work was junk science.  Specifically, the penile plethysmograph, the ink blots & other invalid techniques.  After the show, psychologist Orrin Bolstadt, whose psychologist wife's work in one case113 I'd called bogus, walked up to chirp I was soon going to get my "comeuppance" and have criminal charges brought against me.  He wouldn't give details.  I was indicted a month later.


          Up until this time, in spite of prosecutor's efforts, I continued to testify as an expert witness and speak out against bogus prosecutions and sham mental health experts.  On lawyer Tom Cooney's advice I let the insurance company settle the civil complaints to get them out of the way.114


          I took part in a videotaped study of abused and non-abused children with the "anatomical dolls" relied on by CSD workers and prosecutors.  This, and later studies, showed the dolls were scientifically worthless as diagnostic instruments.


          I suspected Stapleton & Hammersly115 wanted identities of these children, and information about my patients.  Some were in law enforcement, others were lawyers.  Suspicions confirmed.  It turned out they got much of this information from Dobson & Gribble.  Around this time, I discovered somebody stole patients files from my office and someone tampered with my mail in the Newport post office each night.


          Stapleton, Hammersly, & Menzies116 also hatched a phony investigation for insurance fraud.  They got confidential patient information, including patients' psychological evaluations and diagnosis, by sending insurance companies bogus subpoenas marked "investigation pending" not issued by a grand jury or under judicial supervision.  They tracked my speaking engagements and cases in which I was going to testify.  They got the postal service to put a 30-day cover on my mail in 4/15/86.  When it expired the postal service extended it from 5/13/86 to 6/15/86 at the request of Cpt. Mike Fitzpatrick, Richland WA, police department.  Ostensibly, he told me, because he thought I might be in contact with two people who'd consulted with me and were later charged with kidnaping and interstate flight.


          The postal service extended it well beyond 9/4/86.  Menzies' notes show he asked postal inspector Tom Shipley to extend the cover into November 1986.117  Lincoln County prosecutors used it as a fishing expedition.  "Cover" means copying information on the envelope.  But some test letters I sent were opened, others weren't delivered.


          My secretary, June Helbert, and I realized someone had stolen files from the office.  I suspected Stapleton, Hammersly, Menzies, & Huegli were involved.  This turned out to be true.  Huegli displayed some of these documents in the civil trial and prosecutors had copies.118, 119


          So I hid some files and destroyed others.  I announced this in a local paper and a tape recording to let people know my concern about dishonesty in the DA's office.120  This recording later became part of an impeachment packet they sent lawyers and prosecutors throughout the country.  Clearly, they wanted to put me out of business.


          The contrived criminal indictments did the job.


          I showed the appointment book to my lawyer, Des Connall.  He saw it wasn't erased and told me to hold onto it so he wouldn't be in the evidence chain.  I knew Stapleton, Hammersly, & Huegli got information about my patients illegally.  That they had Gribble steal documents from my office.  So I asked my wife to put the book and some patients' files someplace outside the house.


          However, come trial time, we couldn't find the book.121  Marquis knew the alteration didn't exist when he had Dobson testify.  But he knew prosecutors Hammersly & Stapleton gave Dobson immunity from prosecution for perjury for saying it did.  So, on her word, I was convicted of tampering with evidence, business records, and a witness.


          He knew Dobson's claim was false because he saw the tangible lack of any signs of alteration in the copy of the page.  He also worked with Stapleton and Hammersly who framed the bogus charge.


          But he had a potential glitch in his case.


Summary:          In a 4/15/86 deposition in Hutton vs. McIver, Hutton testified she went to my office for a 12/16/83 appointment.  She made unequivocal, graphic, allegations about that visit to show she remembered the appointment date correctly.  But in the July, 1988 criminal trial, Oregon vs. McIver, and a 3/14/96 deposition, McIver vs. Hutton, et al, she reversed her testimony to say she didn't go that day.


          The date, December 16, 1983, was the keystone of the tampering charges.  Hutton changed her testimony so it wouldn't contradict Marquis' claim that, after she filed her suit, I had her 5: PM appointment time for 12/16/83 changed to 1 :PM.


          If she said she kept her appointment, she'd have had to say it was at 1: PM (The time actually written in the appointment book) or 5: PM (The time Marquis declared was written in the book. ).


          If she said 1: PM she'd gut his case.


          If she said 5: PM, she'd have to explain why, after office hours, 8 days after applying for a wedding license, and one month before she married,122 she went to see a man who, according to Robert Hutton, who moved in with her 13 days before,123 she professed she was "deathly afraid" of, who used her for sex, exposed himself to her, threatened her, and made her feel "dirty."124


          So when Marquis (who read in her 4/15/86 deposition she kept the appointment)125 asked her about it during the criminal trial, she said she didn't go.


          Under cross examination, however, she admitted that on 12/15/83 she'd told her physician she had an appointment with me.126  And that she submitted a bill and was paid mileage for going to that 12/16/83 appointment.127  She testified the travel was for a visit to her physician's office.  Yet his records don't show her there on 12/16/83.


          SAIF128 records also show that on 2/16/84 they received a health insurance claim form from my office for the 12/16/83 office visit.129  SAIF has no record of Hutton disputing the bill.130  My secretary also recorded her 12/16/83 visit on a patient ledger card.  And I took notes during the 12/16/83 appointment.131


April 15, 1986 Deposition132

E 65 A, L 24-25: E 65 B- L. 1 - 6

Q. Dr. McIver's records indicate that you had a visit with him in December - I believe December 16th of 1983 - and that was your first visit since August.  Does that sound correct to you?
A. Yes.
Q. Why did you go back to see him in December?
A. I don't remember as I - Maybe he told me to or they maybe - - -

E. 66 Co L. 8 - 25

Q. Do you recall what occurred during the December visit?
A. He just told me I shouldn't get married.
Q. Do you recall how long the December visit was?
A. No. It wasn't very long.
Q. So there was some discussion that occurred between you and Dr. McIver in the December session?
A. Yes.
Q. Were you there the full hour?
A. No.
Q. Why did you leave.  Did you leave early?
A. Yes.
Q. And why did you leave early?
A. Because I got tired of what he was talking about.
Q. What specifically was he talking about on that occasion?
A. That I shouldn't marry Robert, and that I should let him come out to my house again.

E. 66 D. L. 22 - 25

Q. Did he expose himself to you at the December visit?
A. Yes.
Q. And exactly what is it that he did when he exposed himself to you on that visit?

E. 67 A. L.1 - 6

A. Just unzipped his pants and showed me what he had, and, you know, like, See what you do to me?  And all that.
Q. Did he have an erection at the time?
A. Yeah.
Q. So that occurred at the December visit, correct?
A. Yes.

          But, when Marquis, then Connall, asked her about the date during Oregon vs. McIver she said she didn't go to my office on 12/16/83:


Testimony in Oregon vs. McIver133

E. 73 B. L. 7 - 16

Q. Drawing your attention to specifically one appointment date, December 16th of 1983, that would have been a Friday, did you go to an appointment at Mr. McIver's office on that day?
A. No, I didn't.
Q. How do you know that?  It's a long time ago.
A. I went to a birthday party for Robert's grandson.
Q. Are you sure about the date?
A. Yes.


(Marquis) Q. Are you sure about that December 16th date?
  A. Yes

E. 74 B. L. 20 - 25

(Connall) Q. You are absolutely positive that you did not go to Dr. McIver's office on the 16th day of December, 1985?
  A. 1983.
  Q. I mean '83.
  A. Yes, I am.

E. 74 C. L. 1 - 2

Q. At any time that day?
A. That's right.

           When Mr. Mackesson asked her about the 12/16/83 appointment, she changed her testimony again to say she knew there was an appointment that day but she didn't keep it :

E 75 D, L. 2 - 25

Q. Now, isn't it true that in the same deposition134 you there testified that on December 16, 1983, that you did see Dr. McIver at his office?
A. I don't think so.
Q. Do you recall as part of that same deposition being asked these questions and giving these answers:

"Question by Ms. Martyn: Dr. McIver's records indicate that you had a visit with him in December.  I believe December 16th of 1983, and that was your first visit since August.  Does that sound correct to you?"  And that your answer was "yes."

Was that your testimony during that deposition?

A. I don't know.  I know there was an appointment that day but I didn't keep it.
Q. My question is was that your testimony?
A. I don't remember. You're reading it. I - That's been years.
Q. My question is, do you remember giving that testimony on that day?
A. I just told you I don't remember.
Q. Is that testimony incorrect?
Marquis: Objection.  Asked and answered.  I know this is an offer of proof but -

E. 76 A. L. 1 - 25

The Court: Objection sustained.
By Mr. Mackesson (continuing)
Q. Let me read you these questions and ask you if you recall the questions and giving the following answers.
  " Question by Ms. Martyn: Do you recall what occurred during the December visit?
  "Answer: He just told me I shouldn't get married.
  "Question: Do you recall how long the December visit was"
  "Answer: No. It wasn't very long.
  "Question: So there was some discussion that occurred between you and Dr. McIver in the De- cember session?
  "Answer: Yes.
  "Question: Were you there for a full hour?
  "Answer: No.
  "Question: Why did you leave? Did you leave early?
  "Answer: Yes.
  "Question: And why did you leave early?
  "Answer: Because I got tired of what he was talking about."

E. 76 Bo L. 1 - 10

Q. Do you recall those questions and giving those answers?
A. No.
Q. You don't recall the deposition?
A. I recall there was a deposition, yes. There were a lot of depositions.
Q. Do you recall giving that testimony?
A. Not really.
Q. Is that testimony true or false?
A. I didn't see him in December.

E. 76 C. L. 11 - 25

Q. State Industrial Claim.  And as part of the processing of that claim Dr. Robbins was able to obtain mileage for you whenever you had to go to see Dr. McIver and Dr. Robbins; is that correct?
A. Uh-huh.
Q. And did you tell Dr. Robbins on the 15th day of December, 1983, that you had an appointment with Dr. McIver?
A. I guess I did.
Q. Well, knowing that, is it still your testimony that you did not see Dr. McIver in December of 1983?
A. Yes.  When I did these, all I did was check with their office, get the dates, and fill it out.
Q. But you submitted it, and you got money for it, didn't you?
A. Do you want to get into submitting money?
Q. That's not my point. I asked a very simple question.
The Court: Try to answer the question.
By Mr. Connall: (continuing)
Q. You submitted it and got money for it, didn't you?
A. Evidently.  Like I said I would just call up and say what dates.
Q. And that resulted in Dr. Robbins filing it for you; is that correct?  Or did he sign off on it, and then you signed it And sent it personally?  Is that right?
A. I would just put in what date they said or they would mark the date.
Q. All right.  But then as a result of that you would sign it.  You signed what is the functional equivalent of a certificate and you submitted it for money?
A. I guess I did.
Q. And you received payment in the amount of $52.50 on that submission, didn't you?
The Court: Why don't you go ahead and answer that -

E. 76 D, L. 1 - 13

The witness: I got travel expense for one -
The Court: Mrs. Hutton? This is an offer of proof
The witness: One visit.
The court: Even though, perhaps, there may be a little badgering of the witness.
The witness: That is travel for one visit to Dr. Robbins.  That's what it figures out to.  I can read.  You read it.  That's travel for one visit to Dr. Robbins and a prescription.  See that "R"?  That is a prescription.  This is one visit to Dr. Robbins.  That's what the 146 miles comes to.


Deposition: McIver vs. CBS. et al135

E. 84 A. L. 462 - 470

McIver: ... Did you have an appointment in my office on 12/16/83?
Hutton: I did not go to your office on 12/16/83.
McIver: OK. Do you recall if you had an appointment on that date?
Hutton: I went to a Birthday party on 12/16/83.
McIver: Who's birthday party?
Hutton: Robert's grandson.
McIver: Did you receive mileage reimbursement from SAIF for driving to your 12/16/83 appointment?
Hutton: Not that I know of.


          Hutton committed perjury when she swore she didn't go to the appointment.  Marquis & Huegli knew it.  She changed her testimony to further the charge I had Dobson transpose her name from a nonexistent 5: PM appointment to the actual 1: PM. time.136


          Attorneys Stephenson & Martin sent Huegli copies of Baggs' insurance form, ledger card, and case notes during Hutton vs. McIver.  He knew she'd previously testified she kept the appointment.  He read my notes of her 12/16/83 visit.  He also read, in Dr. Robbins' notes, she asked for mileage payment for this visit.  And he had SAIF records showing they paid it.137  Marquis had these transcripts & knew this.


          My wife found the book when I was in the penitentiary.  I got a post-conviction trial on the claim prosecutors knowingly presented false evidence.



Before this trial, however, A Current Affair nationally broadcast a program with a segment about me called Dr. Dirty on September 22, 1991, and at least three other times after that throughout 1991 - 1992.  Betty Hutton said I used her for sex.  An actor depicted a doctor (me) slowly unzipping his fly approaching a seated female's (Baggs) face.  Marquis proclaimed I had sex with patients.  He made the factual assertion I told Dobson to alter a record (As opposed to having been found guilty of doing it.).


          Producer Palatnik's crew filmed Marquis in the Lincoln County courthouse library walking into the main courtroom folder in hand pretending court was in session on a Sunday.


          Palatnik, Oboyle, & McGowan138 advanced Marquis' and Hutton's allegations with no effort to check them out.139  Fox Attorney Muriel Ries, Bill McGowan & Maureen O'Boyle didn't read a single pertinent document, or try to contact Marquis, Hutton, Huegli, psychology licensing board members, Dr. Robbins, attorneys Stephenson, Martyn, Connall, Mackesson, Cooney, or me.  Following, is the transcript of her show, Dr. Dirty: (Paragraphs numbered for reference. Palatnik's copy in bold)



1. O'Boyle: When Betty Hutton went to a shrink to help her handle a tragedy she never expected what would happen on the couch.
2. Hutton: It was nothing romantic.  It was just bang, and that was it.
3. Marquis: McIver put them (female patients) in a position where they felt obligated to have sex with him.
4. O'Boyle: Dr. Dirty.
5. Hutton: I try to believe doctors.  They are supposed to take care of you.
6. O'Boyle: This woman claims her shrink was a master manipulator and, instead of offering help, he offered himself.  That's next ...  When a psychiatrist in Oregon lost his medical license at least one woman breathed a sigh of relief.  She claims Dr. McIver practiced more than medicine on his office couch.  But now the doctor is fighting to get his license back, and Bill McGowan tells us she wants the world to know about Dr. Dirty.
7. Hutton: It was something that I never expected to happen to me because nobody ever flirted with me, nobody had ever bothered me.  And I never thought about anybody wanting to.  I mean, I wasn't that type of person.  I was just an old grandma.
8. McGowan: When Betty Hutton sought psychological counseling she expected compassion and guidance from a medical professional.  But, according to court papers, Betty said she got a session in seduction from a doctor who took advantage of her emotional vulnerability and prescribed his own brand of therapeutic lust.
9. Hutton: He unfastened his pants and he ... he was instantly there all the time.  Well, I mean, I've never seen anything like it.  And he wanted to have oral sex, just sex ...  I mean it was nothing romantic.  It was just bang, and that was it.
10. McGowan: When she looks back on her ordeal, Betty almost detaches herself from what happened.  The experience is still too painful to remember.  Betty began seeing Dr. William McIver after the death of her first husband, Buck.  They had been childhood sweethearts and were married 29 years.
11. Hutton: I always had somebody to tell me what to do and all of a sudden I was alone.  And he just took over and told me, you know, what to take, where to go, how long I could see my parents in California, and things like that.  And I just did what he said.
12. Marquis: He used his trust and the reliance they had on him for their emotional stability to take advantage of them and put them in a position where they felt obligated to have sex with him.
13. Hutton: When I look back, I can't believe I was very naive.  I'm 46 years old.  I was really dumb.  And I always had been trusting about people ...  And I had trust in him completely.
14. McGowan: Betty filed a civil lawsuit against McIver charging that he had subjected her to unwanted sexual behavior by threatening to cut off her disability payments.  She had been receiving compensation after suffering a fall at work.  Halfway through the trial Betty settled the case out of court for $125,000.  It was the second case involving sex abuse charges that had been brought against Dr. McIver.  No criminal charges, though, had ever been filed involving sexual accusations.
15. Marquis: It might be immoral or unethical, and it might even be actionable, in the sense that people could sue for it, but if an adult has consensual sex in Oregon with somebody else, as long as they're not being subjected to it because they're literally mentally incapable, or under the influence of drugs or alcohol, it's not a crime, if it was consensual sexual conduct between adults.
16. McGowan: Joshua Marquis did end up prosecuting Bill McIver on a technicality.  Tampering with a witness.  In preparing for the civil trial, Dr. McIver contacted his former secretary and asked her to change the time in an appointment book of a session he had held with Betty Mrs. Hutton years earlier.
17. Marquis: The reason the appointment book was so important, was the particular patient who claimed that she was sexually molested in his office in the evening was scheduled in the appointment book at a 5: PM appointment.  McIver wanted Mary Dobson to change it to a mid-afternoon appointment so it didn't look like she was there in the evening, and it would tend to disprove her claim that she'd been molested in the office at that time.
18. McGowan: Now Dr. McIver is seeking to have the Oregon conviction overturned, which could allow him to practice there again.  At the moment, his license has been suspended.
19. Marquis: I think he was rightfully accused, rightfully convicted, and rightfully sent to prison.
20. McGowan: Aside from the Oregon suspension, Dr. McIver's license has been revoked in Minnesota, and the state of Alaska refused to renew it after a routine background check revealed he conveniently forgot to tell them about his prior legal troubles.  Betty Mrs. Hutton hopes that by speaking out she can warn the world about the good doctor and his healing ways.
21. Hutton: I was raised to trust policemen, doctors, and ministers, and, you know, try to believe doctors.  They are supposed to take care of you, not hurt you ... I don't want him to be able to do that anymore.
22. O'Boyle: Despite our repeated requests, Dr. McIver refused to speak with us.


          Baloney.  Palatnik called to ask if I would be on a show about interviewing children in cases of alleged abuse.  I agreed on condition my attorney Wayne Mackesson approved and he didn't.


          So, at Palatnick's request, I arranged for her to get tapes of some of my interviews with children & a talk about this I gave to the Oregon Sheriffs' Association, from Mrs. Velma Hartwig, who she interviewed in Eddyville.  Palatnik also led Mr. and Mrs. Hartwig to believe she was doing a show about false allegations of child molestation.   She didn't say the program was about the civil & criminal charges against me.


          She parroted everything Marquis & Hutton said.  She made no attempt to examine documents she could easily have gotten with a note or call to anyone of sundry sources (The Lincoln County District Attorney's office; my civil case attorneys Tom Cooney, Chrys Martin & Ronald Stephenson; my criminal case attorneys Des Connall & Wayne Mackesson; the Alaska, Ohio, and Minnesota licensing boards, me) These documents include:

- My 12/26/90 petition for post-conviction relief claiming prosecutors relied on perjured testimony. [E. 109 ]

- Dobson's 3/26/91 deposition in which she admitted she saw no signs of the erasures she had claimed she made at my request. [E. 126 - 127 ]

- Dr. Arlen Quan's 5/17/84 statement Hutton said she had not had sexual relations with me. [E. 49 D ]

- The 2/4/86 Kennemer-Hawkins report stating Hutton told psychology board members intercourse took place "at least 2 times" in her home, as opposed to his office, as she claimed in her complaint. [E. 94 - 95 AB ]

- Hutton's 10/23/85 deposition answer, "No," when asked if she ever had sexual relations with me in my office as she claimed in her complaint; [E. 67 D, L. 11 - 13]

- Hutton depositions, testimony, & other records showing she committed perjury when she testified said she didn't keep her 12/16/83 appointment (discussion supra).

- Hutton's letters to her deceased husband & me. [E. 1345 - 156]

- Hutton's medical record; showing suicide attempts, marriage problems, drug abuse.

- My case notes on Hutton.

- My correspondence with professionals concerning Hutton's condition. [E 194 B]

- Hutton's psychological test results. [E. 115 D]

- Attorney Thomas Cooney's 12/22/89 affidavit stating he advised me to let the insurance
carrier settle to reduce exposure. [E. 125]

- Hutton's Division of Workmen's Compensation file.

- Ron Robert's 2/20/86 statement about Betty Hutton and her new husband. [E 194 A]


          Had Palatnik honestly said she was doing a show on the civil and criminal cases I would have jumped at the chance to show her these documents.  Especially the appointment book, which was physical evidence the tampering convictions were bogus.


          It took a calculated effort for her to ignore so many sources of information.140  Literally, the only thing she got right was my name.  She swore falsely in a 3/31/93 affidavit when she claimed she "... took steps which I, as a responsible journalist, ordinarily take and which are considered common practice in the field of journalism when researching an investigative story."141


          Her "research" was so nonexistent she failed to uncover otherwise inconsequential information I'm not a "psychiatrist," I didn't lose a "medical license", and I wasn't "fighting" to get my license back.142


          It's plain from Hutton's answers to deposition questions Palatnik didn't ask to see medical records, or contact Huegli, or talk with Dr. Jerry Robbins.  Neither did she ask Hutton if she'd seen subsequent therapists, nor ask to talk with anyone who knew her at the time of her alleged sexual relationship with me:


McIver vs. CBS, Hutton, Marquis, et al143

McIver: ... Did Palatnik ask for authorization to see your medical records for the time you saw me?
Hutton: I don't think so.
McIver: Did Palatnik ask to, for authorization to talk to Jim Hueg1i?
Hutton: I don't think so.
McIver: Did Palatnick ask about letters you'd written to Buck and myself?
Hutton: I don't think so.  I just don't remember.
McIver: Did Palatnick ask if, at the time it allegedly occurred, you told anyone about your alleged sexual relationship with me?
Hutton: I'm not sure.  I don't remember.
McIver: Did Palatnick ask if you'd seen subsequent therapists?
Hutton: I don't think so.
McIver: Did she ask for authorization to talk with the M.D. who referred you to me?
Hutton: I don't think so.
McIver: Did she ask to talk with anyone who knew you during the time you allege sexual contact with me?
Hutton: I don't think so.


Post conviction trial144


Judge Huckleberry & prosecutor Barnett denied my right to a fair post-conviction trial by lying about evidence they heard, read, and saw.


          Judge Huckleberry upheld the conviction to find I had Dobson erase Baggs' name written in a 12/16/83 appointment book page at 5: PM, and rewrite it at 1: PM, after first erasing the name written there.  Although in this 1/17/92 post conviction trial:


- He heard defense and state experts testify they found no sign of erasure or rewriting at 1: PM, 4: PM, or 5: PM. in the appointment book;

- He read, in her 3/26/91 deposition, that Dobson reversed her testimony to admit there wasn't any erasure or rewriting;

- He saw, literally, when he examined the page in court, the concrete absence of signs of the alleged erasure or rewriting.


          Yet, in his Memorandum Of Opinion, he attributed testimony to the document experts which was completely opposite of what the transcript shows they actually said.


          State witness Dobson had testified, to at least one grand jury, and juries in a civil and criminal trial, that I had her erase Baggs' name from the 5 PM slot and rewrite it in the 1 PM slot for 12/16/83.  But on 3/26/91, when attorney Mackesson confronted her with the page, she admitted there wasn't any erasure.


          She conferred with Barnett then claimed "... it must have been at 4 o'clock."145


(Mackesson) Q. Please look at the entry for 5: PM.
(Dobson) A. Uh-huh.
Q. Does it appear to you that there's any erasure at 5: PM?
A. No, I really don't notice any.  I notice that (indicating), and I usually put X's down.

[E. 127 A, L. 25: E. 127 D.: E. 126 ]

Q. Well, again, there doesn't appear to be any erasure on the 5: PM?
A. No. I could have been wrong.
Q. Did you intentionally misstate your testimony during either the Hutton trial or the McIver criminal trial?
A. No. I wouldn't intentionally do that.
Q. Could you have been mistaken about the date?
A. No.
Ms. Barnett: You want to explain to him?
Witness: Yes.  When I changed it, I put my "M" there.  That's how I would know.
Mr. Mackesson: Q. When you would have changed what?
A. When I changed it for Dr. McIver, when he came out to the house.
Q. Well, my question is: is there any erasure that you made at the 5:00 PM entry on December 16?
A. No.  As I said, I cannot tell any.  The only thing I was looking at was this little mark I put down so I would know when it was.  So it must have been at 4: 00 o'clock.  I don't remember.  But I know I put my mark down so if ever I was shown this, I would know.
Ms. Barnett: For clarification, are you saying that the change may have happened at 4: 00, rather than 5: 00?
The witness: It might have; yes.
Mr. Mackesson: And did you talk about the fact that you changed one name from one place to another, you exchanged a name, when we talked briefly earlier?
A. I said I could have.  I couldn't remember.  I was mainly going for that little mark, because that's how I I would know, and I told no one of that mark ----
Q. Well, the mark
A. - - At that time.  I told no one.  I did later on.
Q. Who did you tell later on?
A. I think I told Josh there would be a mark, a little "m" or an - - and just some scribble, so I would know where I changed it.146
Q. I notice it's on the line for 4:00 p. m.
A. Yes.
Q. Is there anything significant - -
A. It could have been.  That's what I'm saying: I could have been mistaken about 5: 00 o'clock.  It could have been the 4: 00 o'clock ... I knew whatever time I did, out at the side I put a little "m", some way that I would know.
Q. Okay.  Well, does there appear to be any erasure under the entry at 4: p.m.?
A. Not that I can see.  But that's - - and it would be so hard, and there - - as far as that goes, yeah, there's something erased up here.  No, there has been something erased at 4: 00 o'clock.  I can see it right here, that little mark right above.  And John might have been coming in at 1: 00, and I just switched him down and traded.  That's been an awfully long time ago.


          But Barnett had the same glitch Marquis had with Hutton's appointment time.147  If the man scheduled at 4: PM was there, it would shoot down the revamped claim Baggs' name had been written (and erased) at 4: PM, not 5: PM, after all.148  So she came up with Marquis' solution and had the patient, John Mills, testify he didn't go that day.  He said he didn't go there in December

("... too close to Christmas.").


          There was a second glitch and a second solution.  Blue Cross routinely sent patients copies of insurance billing forms listing dates and charges.  If Mills acknowledged receiving a copy for December, it would be simple to show he accepted the dates and charges without challenge.  Which would give lie to his testimony that he hadn't kept his appointment, and Dobson's claim Baggs' name was written in, and erased from, the revised 4: o'clock slot.


          Mackesson then showed Mills the copy of the insurance form listing four December visits (including the 16th).149  Mills initially admitted he'd probably seen it, then said he hadn't and the dates were wrong:150


McIver vs. Oregon, Lincoln Co. # 904733

E. 105 B- L. 18 - 25


Q. And the appointments with Dr. McIver, do you remember approximately how many you had?


A. I don't remember for positive how many I had. Between five and ten, maybe.
Q. And would those appointments have always been after work?
A. I believe they were probably around 4: 30 or something like that; towards the end of the day, yes.


Q. And you never missed an appointment with Dr. McIver, did you?
A. I never missed an appointment that I made with Dr. McIver.

E 105 C- L. 24-25: E. 106 A- L.1-10.

Q. Let me show you what's been marked Exhibit 5, which is a Blue Cross billing form, and that shows there are four dates in December; December 8, December 16, December 21.
A. Yes sir, I see that.
Q. Have you ever seen that form before or a copy of it?
A. I probably did because Blue Cross, whenever they bill the company, they send me a copy
of the bill, and so I probably saw that.
Q. Right.  Do those dates sound correct?
A. But I don't recall seeing it.  No, they don't.

E. 106 B. L. 3-5.


Q. Do you know if you saw him in December?
A. I didn't see him in December.  That was too close to Christmas.


          Yet the Blue Cross form he received at the time lists him seeing Dr. McIver on December 1,8, 16, and 21.  Mills lied to conform his testimony to the revised Dobson- Barnett version that Baggs' appointment had really been at 4: PM, rather than 5: PM., after all.


Summary: Barnett knew Baggs' name hadn't been transposed from 5 to 1 PM as she charged because her expert found no sign of alteration in either slot and she saw no sign of alteration.  When Dobson recanted, Barnett had her say it was at 4 PM. (Although her expert testified he found no sign of alteration there either). When Mill's records showed he kept the 4 P.M. appointment, Barnett had him testify he didn't.


          Judge Huckleberry's memorandum version of underlying facts is at odds with reality:

"The alteration would show that Mrs. Hutton was in his office for an appointment at 1:00 P.M. on December 16, 1983, as opposed to later in the day.  The petitioner says that it was his practice not to see a female patient alone in his office.  If the appointment of Mrs. Hutton was at 1:00 P.M., office staff was present.  If the appointment was at 4:00 P.M. or 5:00 P.M., it appears that the petitioner would have been alone with Mrs. Hutton, which evidence would have been consistent with Mrs. Hutton's theory of her case against McIver."151


          This is duplicitous. Judge Huckleberry and Barnett knew Hutton told conflicting versions of her story.  They also lied about the document examiner's conclusions:


          Dr. Grimsbo examined the document with his naked eye, a Sony infrared video camera, various filters, and hot light, to test for graphite particles left by erased writing.  He wrote his initials on a test section and erased them.  With a stereo microscope at 20 to 30 power he saw that erasing disrupted fibers.  This showed erasure was detectable.  He also used the microscope to examine alleged alterations.  And oblique lighting (electrostatic data process) to see if there were signs of indented writing:


E. 44 D. L. 3 - 21


Q. All right.  Now, on the entries that you examined, let's take the 1: 00 o'clock entry first.  Were you able to determine Do you have an opinion as to whether or not there was any alteration, obliteration, or prior writing on the 1:00 o'clock entry?
A. I found no indication that there was.  And my opinion would be that there wasn't any obliteration or writing.
Q. And the same question with respect to the 5:00 o'clock entry.
A. I would answer it the same way.
Q. And the same question with respect to the 4:00 o'clock entry.
A. I would answer it the same way
Q. In your examination of that page of Exhibit 1 on those three entries, is there any evidence at all of
any alteration or obliteration or prior writing on any of those three entries?
A. I didn't see any.


          Could it be plainer?  Dr. Grimsbo examined the page at l:PM, 4:PM, and 5:PM.  He found no sign of prior writing or erasure.  No microscopic trace of graphite.  No indentation.  No disrupted fiber.  Nothing but the absence of alteration.


          Lt. Hurley, used a stereo microscope, standard microscope, filters, different types of high contrast film, different printing papers, an ultraviolet high intensity Luma light, a long wave & a short wave ultraviolet light, & electrostatic data process.  He couldn't find any sign of prior writing or erasure at 1 :PM, 4:PM, or 5:PM152, 153


          Yet Judge Huckleberry (and Ms. Barnett, to the extent she wrote the memorandum)154 gave a brazenly false version of Lt. Hurley's testimony.  Their depiction is an across-the-board reversal, the diametric opposite, of what he actually said:



"Lt. Michael Hurley ... testified that given the nature of the paper upon which these appointments were noted, he is unable to form an opinion one way or another whether an erasure had occurred."



E. 47 BCD

Q. Did you subject the entries for 1:00, 4:00, and 5:00 P.M. on December 16 to those three tests?
A. Yes.
Q. With respect to the 1:00 o'clock entry, was there any evidence of a prior writing or obliteration or alteration?
A. I couldn't detect any.
Q. With respect to the 4:00 o'clock entry, was there any evidence at all of any prior writing or alteration or obliteration?
A. None that were detected.
Q. Same question with respect to the 5:00 P.M. entry.
A. No, sir, none were detected
Mr. Mackesson then asked if he used the electrostatic data test on the three entries in question on December 16:
A. It would be the entire page, sir.
Q. Was there any evidence of obliteration, alteration or prior writing by use of that test at the 1 :00 o'clock entry?
A. No.
Q. Same question with respect to the 4:00 o'clock entry.
A. No.
Q. And the same question with respect to the 5:00 o'clock entry.
A. No.
Q. Did you do any other tests other than the ones I've covered in the cross-examination?
A. The different, I guess pure photographic techniques that would be using high contrast film and various types of filters, different red filters and green filters and paperwork and development techniques, but other than that, no.
Q. The ones you -- the tests you just described, did you use those in examining the 1:00, 4:00, and 5:00 P.M. entries on December 16?
A. Yes.
Q. And did any of those tests disclose any alteration, obliteration or prior writing in any of those three entries?
A. No.
Q. And did any of those tests disclose any alteration or prior writing in any of those three entries?
A. No.


          Lt. Hurley clearly did not testify (per the memorandum) "... that given the nature of the paper upon which these appointments were noted, he is unable to form an opinion one way or another whether an erasure had occurred."  Totally the opposite.


          Neither expert found a hint of erasing on the original.  Therefore, prosecutors couldn't see any on the copy.  They saw only tangible absence of alteration.  So Barnett asked Dr. Grimsbo if it wasn't possible there could have been an "undetectable" erasure there:156


          Ms. Barnett: "Now, the truth is, Mr. Grimsbo -- the truth is that you didn't detect any erasure, but that doesn't mean that there wasn't one there?"

          Dr. Grimsbo: "If we're looking at it from the fact of 100% certainty, I cannot say that someone would not have erased that. As an example, I could go to Mervyn's to buy a sheet, and the sheet is pressed, folded, and in a plastic bag. I buy the sheet in good faith that it hasn't been on another bed. I don't believe it to have been on another bed, but I can't say with 100% certainty that it has never been on another bed.

          The same way here. I can't find any indication that there was writing in those areas. My opinion is, based on that, that had not been written and obliterated. I can't say 100% that it couldn't have happened, because things do happen. There is always the possibility."


          The answer couldn't be clearer.  Judge Huckleberry knew this.  He's a bright man who enjoys reading mind puzzle books and is conversant with the concept of probability theory.  He knew there are no absolutes in science.  He knew it was dishonest to hold Dr. Grimsbo's analogy meant the opposite of what he said.  Barnett had asked if it was possible undetectable erasures could exist.

          Dr. Grimsbo explained, by analogy, anything was possible, but in this case, the probability was negligible.  However Judge Huckleberry turned his statement on its head to mean there was an acceptable probability an undetectable erasure existed.


          Our language is replete with abstract ways to compare things; to say "big" and "little" and "more than" and "less than."  Analogies like: "He's got the chance of a grasshopper tossed in a bass pond," "When pigs fly," or "A snowball's chance in hell"  ... usually get the idea across without numerical elucidation.  They mean virtually no possibility; infinitesimally small likelihood.


          The transcript shows both experts' testimony was unequivocal.  They said they didn't see any signs of alteration at 1, 4, or 5 P.M. (the time allegedly erased): "I didn't see any" ... "none that were detected"... "No."


          "No" isn't up for interpretation.  There's no part of "NO" to misunderstand.  Judge Huckleberry & Ms. Barnett falsified the experts' opinions.


          Assistant Attorney General Rives Kistler, echoed Judge Huckleberry's fiction in his 11/27/ 92 brief to the appellate court.157

          "Petitioner's expert conceded that the appointment log could have been altered if it were done very carefully, and the state's expert agreed.  Far from being "uncontroverted." as petitioner argues, the evidence was both controverted and supported the post-conviction court's finding.  If the log were altered, then the factual predicate for petitioner's post-conviction claim fails."


          By implication: The verifiably unaltered log shows the factual predicate for the post-conviction claim was justified, and Barnett's claim and Judge Huckleberry's decision weren't justified.  (Kistler also parroted other distortions in the memorandum, showed a selective inattention to the record, & lied to appellate judges.158)


          As previously noted, it was physically impossible to see alteration on a copy of a page experts couldn't detect on the actual page.  So Marquis couldn't have seen the erasure he declared was there in the criminal trial, testified was there in the post-conviction hearing,159 & proclaimed was there on A Current Affair:


          In sum: Barnett saw the unaltered actual page; the undisturbed fibers, lack of pencil grooves and absence of lead particles.  All plainly visible to the naked eye.  She couldn't possibly see any sign of erasing her expert admitted he couldn't see.  But she claimed, and let Marquis falsely testify, the 5:PM slot was erased.160


          Judge Huckleberry looked at the page.  He saw the time slot unmarred by any sign of alteration; smudges, indentations, or disturbed fibers.  He heard document experts testify they found no alteration.  He knew Dobson recanted.  Yet he claimed it was altered.  He lied about tangible, verifiable, reality and denied my right to a fair trial.


          Attorney Bradley Avakian was Psychology Board Hearing Officer on April 20, 1993. He read transcripts of the criminal and post-conviction trials supplied by Assistant Attorney General Bennie Won.  He read Dobson's admission the 5 P.M. time was unaltered & her revised claim she erased Baggs' name from the 4 P.M. slot and wrote in Mills' name.  He read her assertion she previously said this to Marquis.


          He read Hutton's declaration she didn't go to the office on 12/16/83, although her previous testimony and documentary evidence shows she did.


          He read Mills' testimony he didn't go to the office on 12/16/83, although office and Blue Cross records showed he did.


          He read the document experts' unequivocal assertion they didn't find signs of alteration at either time. Yet he later wrote, "Neither expert provided a definitive opinion on whether an erasure had been made."161


          He agreed to examine all the evidence, including the appointment book.  I left a stereoscopic microscope with him in case he wanted to verify the absence of alteration he'd see with his naked eyes.  He later admitted he saw no sign of the alleged alteration:162

Q. ... did you look at the ... were you interested in knowing whether or not the 5: pm slot, this is the erasure question, the 5: pm slot for 12/16/83 had been erased?
A. As distinguished from knowing whether there was prior adjudication to that effect?
Q. Yes.  Thank you.
A. Yes.  I think I was interested in that.163
Q. Thank you.  Did you look at the 5: pm slot on the 12/16/83 page of the appointment book with your naked eye?
A. Yes.
Q. Would you please describe what you saw?  Did you see signs of erasure like you just did now, or did you not?
A. No.  I did not."


          Yet he declared the page was altered and lied in his report to the psychology board:

          "When the licensee instructed Mrs. Dobson to alter the appointment book he misused his influence as a psychologist & supervisor in violation of Principle 1f (of the Ethical Principles of Psychologists.).164

          "The licensee undertook activity which would likely lead to the harm of his employee because of his own personal problems in violation of Principle 2 f.  The licensee engaged in a practice which resulted in an illegal & unjustifiable action in violation of Principle 3 b."165

          "The conduct was a clear exploitation of a subordinate individual who was by nature of that subordination in a professionally vulnerable position.  The conduct placed the employee in a position of legal harm to herself since she was committing a potentially illegal act by altering the appointment book.  The licensee allowed his personal problems to interfere with his professional relationship with an employee.  The licensee's conduct was committed for completely self-serving reasons in that the alteration of the appointment book supported his defense in a civil lawsuit."166


          This left me a convicted felon unable to practice my profession for a living.


          Depositions, trial transcripts, & other documents listed as Exhibits fully support the
charges against the defendants.  They are incorporated into this affidavit.


          Proof tampering charges were manufactured is, besides photomicrographs & other scientific findings, the appointment book itself.  It will be available at trial.


          Given my experience with the courts (as expert witness and defendant) I would be less than candid if I didn't express reservations about finding a judge who won't shield fellow judges and prosecutors.  One who'll let a jury to hear these eminently triable facts.


          I made exhibit copies from original, & copies of, original documents.  I affirm all statements in this affidavit are true.


William F. McIver II, PhD.
Pro Se


1 They'd knowingly use patently phony expert witnesses, such as Ann Fillmore, with a non existent Pill. in "Victimology & Hostage Taking" from the University of Edinburgh (Scotland). Or Ian Bays, MD, who was not
only a biased, incompetent interviewer, but routinely lied on the witness stand.  [Back]

2 Let readers ask if any "trea1ment" could change their sexual preference. People who overtly use children for sex are no more likely to change their rationalizations than professionals who covertly use them for personal gain. Their justifications are perverse, fixed, & endless.  [Back]

3 e.g. In 1987, I met with representatives of the Catholic Diocese in Cleveland. Ohio. It had the most extensive parochial school system in the country.  I told them that, considering the number of teachers and priests under their supervision, it was reasonable to believe some molested children & some would be falsely accused of molesting children.  I suggested ways to investigate this & develop a program to minimize false accusations and deal with those that were valid.  They weren't interested.  [Back]

4 Presumably, lawyers who thought their client guilty weren't as likely to ask me to consult.  [Back]

5 "Misused Tool" - Newport News Times. 8/21/84. A Case for a Therapeutic Interview in situations of Alleged Sexual Molestation, The Champion, Jan-Feb, 1986.  This article was published in legal journals in a number of states, including Oregon. [E. 10]  [Back]

6 Betty Baggs later married Robert Hutton.  She filed false and defamatory civil charges, committed perjury in a civil and criminal trial, & lied about these charges 1) to members of the Psychology Licensing Board; 2) on A Current Affair; 3) in an affidavit; 4) in four depositions; 4) to various doctors.  (Link to Letters)    [Back]

7 They also piled on equally bogus charges of insurance fraud they refused to try in spite of my invitations to do so.  [Back]

8 Hutton vs McIver, Lincoln Co., # 85-1319 [E-50]  [Back]

9 Attorney Thomas Cooney's affidavit, (E 125-0]  [Back]

10 Oregon vs McIver, Lincoln County # 870940; 870941 - [E-10]  [Back]

11 McIver vs. Oregon, Lincoln County # 904733. Post-conviction trial.  [Back]

12 Marquis affidavit, McIver vs. CBS et al; U.S, District Court # 92-632TC [E-IOI-I03 A]  [Back]

13 Ward v. McIver, Lincoln. Co. A 8505-03020 [E 117]  [Back]

14 Huegli to Oregon Bar: "A thorough investigation led to the conclusion her case had a foundation in fact ..." [E 48; Par. 2]  [Back]

15 For consistency, Sharon Gribble-Cunningham is referred to as Sharon Gribble.  [Back]

16 I deny having any kind of sexual contact or relationship with Baggs - Hutton anytime.  Including oral, anal, vaginal, visual, phone, frottage; or any permutation of same.  [Back]

17 Hutton vs McIver, Lincoln Co. # 851318.  To bolster his case, Huegli: 1) Committed theft by converting records Gribble stole from my office; 2) Falsely claimed Mary Dobson told him I asked her to alter a record; 3) Suborned perjury from Gribble & Dobson; 4) Knowingly let Hutton falsely testify about his initial contact with her; 5) Knowingly let her falsely testify she had sexual relations with me. 6) Knowingly let her falsely testify she didn't keep a 12/16/83 appointment with me. 7) Wrote false statements in an affidavit in her behalf. 8) Submitted a knowingly false complaint in Hutton v. McIver [Back]

18 In an 8/23/86 letter to Jim Huegli, attorney Chrys Martin wrote: "Jim, as you admitted to me by phone, and as is clear from your letter; your recent "re-evaluation" of the case and demand of $500,000 is a thinly-veiled attempt to set up Dr.McIver's insurance carrier for a bad faith claim." [E 97 A, Par. 2]  [Back]

19 Hutton deposition; Hutton vs. McIver, 85-1318 (4/15/86) [E 70 B ,L. 21 - E 70 C, L. 1-16]  [Back]

20 Hutton deposition, Hutton vs. McIver,  85-1318 (7/23/86) [E 64 B, L. 15 - 64 CD, L. 10 - 13]  [Back]

21 Huegli letter to Dr. Robbins [E 49 B]  [Back]

22 Paulsen deposition, Hutton vs. McIver, Lincoln Co. # 85138. [E 108 C,D]  [Back]

23 Hutton deposition Hutton vs. McIver Lincoln Co. # 85138. (4/15/86) [E 70 - B; L. 4 - 16].  [Back]

24 Quan letter to SAIF [E 49 D]  [Back]

25 Wedding application & certificate, [ E 74 D]  [Back]

26 Robbins deposition; Hutton vs. McIver Lincoln Co. # 85138. [E. 112 C, L. 21 - E 112 D, L. 4].  The Oregon Medical board called Dr. Robbins on the carpet for acceding to her demands for drugs.  [Back]

27 supra, & Hutton deposition, Hutton vs. McIver Lincoln Co. # 85138 (10/23/85) - [E 51 B - 52 A]  [Back]

28 Computer print out of Hutton answers to MMPI test. [E 115 D]  [Back]

29 Robbins' deposition, Hutton vs. McIver # 851318. [E 112A, L. 23 - 25].  [Back]

30 ibid [E 112 B L. 22 - 24]  [Back]

31 ibid[EI12C,L.21,- EI12D-L.I-6]  [Back]

32 ibid [E 114 A, L 3 - 25 ]  [Back]

33 Physician's Assistant Ferguson's chart notes. [E 115 A]  [Back]

34 Dr. Arlen Quan's 5/17/84 letter [E 49 D] - [emphasis added] "... she alleged that some months ago Dr. McIver had wanted to have an affair with her but that she resisted though on one occasion he had physically touched her.  However; there had been no sexual intercourse." (Note: Mrs. Hutton met Mr. Hutton in July, 1983 [she claimed it was August].  He moved into her home 12/1/83.  They were married on 1/22/84.  Mrs. Hutton saw Dr. Quan 9 - 10 months after she met Mr. Hutton, 5 months after they started living together, & 4 months after they married.  "Some months ago" suggests Dr. McIver "wanted to have an affair" while she was going with Mr. Hutton, or living with him, or was a newlywed.)  [Back]

35 Hutton vs. McIver. Lincoln Co.# 851318. [E 50].  [Back]

36 Hutton vs. McIver, supra, [E 58-B, line 2]  [Back]

37 Hutton deposition (10/23/85), Hutton vs. McIver. Lincoln Co.# 851318 [E 75 B, L. 22-25]  [Back]

38 McIver vs CBS, Hutton, Marquis, et al. CV 92-06327 -HO,. [E. 79, C, L. 77 - 91 ]  [Back]

39 Robbins' deposition, Hutton vs. McIver. Linc Co. # 851318. [E 113 A, L. 5 - 8]  [Back]

40 Kennemer - Hawkins report to Oregon Board. of Psychologists Examiners. [E 94 B, L. 7]  [Back]

41 Deposition (10/23/85), Hutton vs. McIver Lincoln Co. # 85138. [E 53 A, L. 2-25; E 53 B, L. 1]  [Back]

42 Ron Robert's statement to private investigator James McMahon.[ E. 194 A]  [Back]

43 Hutton 4/15/86 deposition, Hutton vs. McIver Lincoln Co. # 851318. [E 68 A, L. 9]  [Back]

44 Robbins' deposition, Hutton vs. McIver. Lincoln Co. # 851318. [E 114 A. L 18 - 21]  [Back]

45 ibid, [E 113 D, L. 1-4]  [Back]

46 ibid, [E 114 C, L. 10- - 25]  [Back]

47 ibid, [E 113 C, L. 8-9 & E 115 - C] under "Fertility control."  [Back]

48 Hutton 5/15/86 deposition, Hutton v. McIver. Lincoln Co. # 851318 [E 69-A, LI7-19]  [Back]

49 The Eagle's nest ledger card. [E 93 A]  [Back]

50 Dept. of Corrections form. [E 93 B]  [Back]

51 Hutton, 4/15/86 deposition. [E 68 D, L. 21-25]  [Back]

52 Hutton 4/15/86 deposition [E 67 -D, L. 11-13]  [Back]

53 "Intentionally, wantonly, & recklessly" Hutton vs. McIver, Lincoln Co. # 851318. [E 50- B; L. 19-20]  [Back]

54 Robbins deposition, Hutton vs. McIver, Lincoln Co. # 851318. [E 113 B, L 13]  [Back]

55 Hutton vs. McIver, 10/23/85 deposition. [E 53 B, L. 18]  [Back]

56 ibid, [E 61 A, L25 -& B, L. 1 - 7 ]  [Back]

57 Oregon vs. McIver, Lincoln Co, 870940, 870941. [E 75-B; L. 20 through D; L 1 ]  [Back]

58 This was 15 years before Monicagate, when a surprised country first heard oral sex wasn't sex.  [Back]

59 Oregon vs. McIver, Lincoln Co, 870940, 870941. [E 75 C, L. 7-8]  [Back]

60 Oregon vs. McIver, Lincoln Co. 870940, 87941 [E 73-D, E 74-A; L. 1-5]  [Back]

61 McIver vs- CBS. Hutton, Marquis, et al CV 92-06327 -HO. [E 79 D, L. 93; E 90 C, L. 1098; E 90 D - E 91, L. 1161 - 1165 ] Transcript available from Mrs. Sue Grabowsky (541) 689-0200  [Back]

62 ibid, [E 91 A, L 1170]  [Back]

63 ibid, [E 91 B, L. 1265 - 1266 ]  [Back]

64 Ibid [ E 92 B, L. 1269 ]  [Back]

65 Ibid [E91 B,L.1273]  [Back]

66 ibid[ E 91 BC, L. 1277 - 1282 ]  [Back]

67 ibid[ E 79 C, L. 97]  [Back]

68 ibid [E 79 C, L. 102]  [Back]

69 ibid [E 79 C - 80 B, L. 103 - 121]  [Back]

70 ibid [ E. 80 B, L. 125 - 129]  [Back]

71 ibid [E. 80 C, L. 145 ]  [Back]

72 ibid [E. 80 D, L. 147]  [Back]

73 ibid [E. 80 D. L. 150 - 153 ]  [Back]

74 Hutton vs McIver, Lincoln Co. # 851318. [E. 53 A-B. L. 1 - 25 ]  [Back]

75 McIver vs CBS- Hutton- Marquis. et al, CV 92-06327 -HO; [E 81 AB, L. 202 - 207 ]  [Back]

76 ibid [ E 81 B, L. 205 ]  [Back]

77 ibid [E 81 BCD, L. 208 - 241 ]  [Back]

78 McIver vs. CBS. et al, U.S. Dist. Ct. # 92-632TC. [E 77 C, L. 7-10 ]  [Back]

79 [E.49A]  [Back]

80 Huegli letter to Oregon Board of Psychologist Examiners, [E 49 A] ??  [Back]

81 Kennemer - Hawkins report to OBPE. [E 95 - 95 AB ]  [Back]

82 Black's Law Dictionary, 6th ed. -"Investigate: to follow up step by step by patient inquiry or observation.  To trace or track, to search into; to examine and inquire into with care and accuracy; to find out by careful inquisition; the taking of evidence.  Investigation: The process of inquiring into or tracking down through inquiry, inspection, observation, search."  It's necessary to state the obvious because a common denominator in their actions has been the defendants' dogged refusal to honestly investigate & report results.  [Back]

83 Mazur- Hart notice of proposed license revocation. [E. 95 CD ] Board members: Stanley-Mazur Hart, Laura Parrish, Raymond Sanders, Steve Stack, Nancy Hawkins, Courtney Goodmonson, William Kennemer.  [Back]

84 Note: The defendants who promulgated tampering charges resolutely ignored the physical reality of paper, writing, & erasing.  Paper is a three-dimensional mat of interlaced fibers compressed to form a solid surface.  It has density, texture, & thickness.  Pencil lead is a honeycomb of layered graphite sheets bonded in gum.  An eraser is mostly rubber & pumice, hardened with zinc oxide & sulphur, held together with burnt vegetable oil, rough buffed & compressed.  Writing disrupts.  It drives graphite into, under, and between fibers.  It indents.  Erasing tears.  It pulls, pushes, & rips out graphite particles lodged in the mat.  It slashes, shears, twists, & bends fibers.  The more thorough an erasure the greater the destruction.  It can't be undone.  There's no such thing as an immaculate extirpation.  [Back]

85 This appointment book will be evidence at the trial. Photomicrographs [E-163-164]  [Back]

86 McIver vs. Oregon, Lincoln Co. # 904733.  [Back]

87 McCrone Associates, Inc., Affidavit & report - [E 157-180]  [Back]

88 "... capable of immediate and accurate determination by resort to easily accessible sources of indisputable accuracy." [Uniform Rules of Evidence 9 (2) (d)]  [Back]

89 McMullen Affidavit, McIver vs. Oregon, Lincoln Co. 904733. [E. 98 AB] Hammersly - Menzies affidavits [E. 98 CD ]  [Back]

90 McIver vs. Oregon, Lincoln Co. # 904733.[ E. 40 C]  [Back]

91 Stephenson letter to Attorney Ernest Lundeen. [E. 116 A ]  [Back]

92 Gribble's insurance form [ E. 23 ]. Mrs. Helbert, secretary at the time, testified she never saw Barney in the office. Oregon vs. McIver, Lincoln Co. # 870940, 870941. [E. 40 A, L. 1 - 13 ]  [Back]

93 District Attorney Ulys Stapleton, Assistant DA Clyde Hammersly  [Back]

94 Trans., Ore ion vs. McIver. Lincoln Co, # 870940,870941. [E. 29 - B; L. 21-24] & Trans., Hutton vs. McIver, Linc. Co. # 851318 [E 17-D -E 18-A-D]  [Back]

95 ibid, [E. 17 - 21; E. 33-34]  [Back]

96 ibid, Gribble testimony, [E. 37 A, L. 2 - 7 ]  [Back]

97 Transcript: [E. 28, L. 6-9]: Connall: "- August of '84 that you started taking records.  Now, am I incorrect in my analysis of your testimony?  Gribble: No, you're correct." During this time The Newport News Times published my article criticizing the DA's office. [E. 10]  [Back]

98 Gribble quit days after she took all the patient ledger cards out of the office during the weekend she & her family moved into a new home.  Or. vs. McIver. [E. 30 B, L. 24 - 25; E. 30 C, L. 1 - 25 ]. Hammersly, Menzies, & Stapleton had copies of these records shortly after that.  [Back]

99 [E. 181-182]  [Back]

100 At the time, Oregon statutes mandated as minimum, seven jurors. Richard Hammersly was granted several motions to allow less than seven but more than five.  Robert Huckleberry & Bernice Barnett refused to acknowledge this, although the motions & orders are (or were) in the court clerk's file.  [Back]

101 [E. 197]  [Back]

102 [E. 134 D, L. 22-24]  [Back]

103 [E. 131 C, L. 20 - 23 ]  [Back]

104 [E. 131 D, L. 18]  [Back]

105 Oregon vs. McIver, Lincoln Co. # 870940, 870941.  [Back]

106 McCrone Associates, Report On Alleged Appointment Book Erasure. [E. 157 - 180]  [Back]

107 As I didn't go to Dobson's home after Hutton vs. McIver was filed, and Betty Baggs' name is not listed for a 5: PM, or later, appointment in the 1983 book, my reference to her name in this exchange is clearly meaningless.  [Back]

108 According to Dobson, the child was once taken to pediatrician, Steven Burns, M.D. because of temporary blindness.  She thought it was caused because the child was left unattended in a room with a faulty kerosene heater while the mother partied.  [Back]

109 During a deposition before the post-conviction trial, attorney Wayne Mackesson showed Dobson the page she'd claimed she altered. She admitted the alteration wasn't there. (E. 126 - 127 ]  [Back]

110 Hearing officer Avakian's proposed order to OBPE. [E. 5 - 6]  [Back]

111 Respondent's Brief; Appellate Court # A 73725. [E. 96 A]  [Back]

112 Deposition given in Indiana vs. Brady # 25820. [E. 11-12]  [Back]

113 Hawkins case [E 181-182]  [Back]

114 [E. 125 D]  [Back]

115 Scientifically confirmable physical evidence the appointment time wasn't altered proves Hammersly lied to a grand jury to get the indictments for tampering with a witness & evidence.  He suborned perjury from Gribble and Dobson.  He received and converted documents Gribble stole from my office.  He allows these violations to go uncorrected.  This also applies to Ulys Stapleton.  [Back]

116 Detailed charges for Stapleton, Hammersly, & Menzies, in case statements.  [Back]

117 Menzies' note about mail cover. [E. 116 C ]  [Back]

118 Jim Huegli produced several during the 9/86 Hutton vs. McIver civil trial.  Gribble testified she gave them to him. [E. 31]  [Back]

119 Huegli also tampered with a witness in McIver vs. CBS, Marquis, et al.  Knowing I was going to depose Bradley Avakian, Huegli told him I had once "implicitly" threatened him. [E - 1 C, L. 145 - 147]  Huegli also made this baseless claim to enhance his case during Hutton vs. McIver & had asked Judge McMullen to have me searched.  [Back]

120 [E 124 ]  [Back]

121 Judge Huckleberry [E. 42 CD] wrote that I had it in my possession "... during the entirety of the criminal court proceedings."  This is duplicitous.  I was in the position of a diabetic who misplaced his insulin.  I had confirmed my mail was being tampered with, & Gribble, Huegli, & Lincoln County prosecutors, had stolen some of my patient's records.  I had solid reason to suspect prosecutors wanted to get this particular piece of exculpatory evidence.  So I asked my wife to hide it (along with other material dealing with my patients).  In the clang and jar of criminal proceedings she forgot where she put it.  It's as simple as that.  [Back]

122 Marriage application, certificate & wedding license. [E. 74 D]  [Back]

123 Lincoln Co. Dept. of Corrections interview sheet. [E. 93 B ]  [Back]

124 Robert Hutton deposition; Hutton vs. McIver, Lincoln Co. # 851318, [E. 92 C, L. 21]  [Back]

125 Marquis aff., McIver vs. CBS, et al, U.S. Dis. CT.# 92-632TC. ] E. 101 C, L. 23 - 25 ]  [Back]

126 State vs. McIver, Lincoln Co. # 870940;87094. [E. 76, L. 16 - 19]  [Back]

127 Dr. Robbins' notes .[ E.72 C ] - Oregon vs. McIver, Lincoln Co. 870940 - 41. [E. 76 C, L.11 - 19]  [Back]

128 State Accident Insurance Fund.  [Back]

129 Health insurance form. [E. 72 A ]  [Back]

130 Ledger card. [E. 72 B ]  [Back]

131 12/16/83 notes for Baggs' appointment. [E. 71 ]  [Back]

132 Hutton vs. McIver, Lincoln Co. # 85-1318. [E. 65 - 70]  [Back]

133 Oregon vs. McIver, Lincoln Co. # 870940 - 41.  [Back]

134 Hutton vs. McIver, Lincoln Co. # 851318. (4/15/86)  [Back]

135 McIver vs. CBS, et al., U. S. Dist. CT. CV 92-06327 TC. [E 185 - 186]  [Back]

136 Why would I change a time for a day she wasn't there?  It's verifiably certain she didn't have a 5: PM appointment.  So if she didn't go to the office that day, Marquis' case boiled down to claiming I changed an unwritten appointment time for an unkept appointment.  [Back]

137 [E. 71; 72ABC]  [Back]

138 Host Maureen O'Boyle & announcer Bill McGowan.  [Back]

139 Case statements for McGowan, O'Boyle, & Palatnick in appendix.  [Back]

140 The Supreme Court held this "purposeful avoidance of truth" constituted actual malice. Harte-Hanks,
492, US at 692.  [Back]

141 Palatnik affidavit; McIver vs. CBS. et al, U.S, rust. Ct. CV 92-06327 HO, [E. 107 B, L 11 - 17]  [Back]

142 In theory, US 9th District Judge Michael Hogan, who dismissed her as a defendant, wouldn't have done so had he known she & Marquis, lied in their affidavits.  However, he didn't notify us he'd dismissed Marquis until 400 days after the fact.  He later dismissed the case for failure to prosecute after his clerk called me in New York at 5:15 PM Pacific time (8:15 PM Eastern) to say he wanted me to be in Eugene, OR. in 15 hours for oral argument when the court opened the next morning.  This is the same office that would sign for certified mail then scratch out the signature & refuse it.  [Back]

143 McIver vs. CBS. et al, U.S, Dist Ct CV 92-06327 HO. [E. 84 BC, L. 518 0 535]  [Back]

144 McIver vs. Oregon, Lincoln Co. # 904733  [Back]

145 Dobson deposition, McIver vs. Oregon, Lincoln Co. # 904733. [E. 127 C, L. 16 ]  [Back]

146 If Dobson had told Marquis it was the 4 PM time, she, by implication, further confirmed the fact Baggs' name was not written in the 5 PM slot.  Which means he not only had her falsely testify she erased Baggs' name; but, to further his claim the name was transposed from an after-hours appointment to a regular office time, he had her falsely testify she erased it from the 5 PM slot.  [Back]

147 Marquis' Glitch: If Hutton admitted she kept either her actual 1 PM appointment, or the fictional 5 PM time, his case was blown: She'd have to acknowledge keeping her previously scheduled 1 PM time, or say that, eight days after her wedding, she went after hours to see a man she claimed threatened her, used her for sex, and who she was afraid of.  Marquis' Solution: Have her deny going.  If records showed she was there, have her deny them, too.  [Back]

148 Anyway, 4: PM was a regular office hour.  Which makes meaningless the claim Dr. McIver wanted Baggs' name moved from there to another regular hours slot.  [Back]

149 John Mills' Blue Cross insurance form. [E. 106 C ]  [Back]

150 McIver vs. Oregon. Lincoln Co. # 90473; Mills' testimony. [E. 105 - 106 ]  [Back]

151 Memorandum, [E. 42 D - 43 A]: "If the appointment was at 4 or 5 PM; it appears that the petitioner would have been alone with Mrs. Hutton.. ."  This is a fabrication.  There's a world of difference between 5 and 4 PM office times.  Confirmable evidence shows Baggs' name was never written at 4 PM, just as it wasn't written at 5.  But if it had been, there would have been no more point in changing it than if it had been written at 10 AM or noon.  (What happened to her claims it was home sex not office sex &, besides, she wasn't in the office that day?)  [Back]

152 Hurley testimony; McIver vs. Oregon, Lincoln Co. # 904733; [E. 46 - 47 ]  [Back]

153 Knowing the 5: PM time for 12/16/83 hadn't been altered, prosecutor Barnett asked Lt. Hurley to see if he could find Baggs name erased anywhere in the book.  He found it had been erased from the 6: PM time for 6/28/ 83 & was clearly written at 1 :PM.  But the name replacing it at 6:pm ("Dr. K.") wasn't in Dobson's writing.  Letter from Hurley to Steve Tolliver. [ E. 45 C ]  [Back]

154 Barnett apparently wrote the opinion; Judge Huckleberry, the conclusion.  He signed off on all of it.  [Back]

155 [E. 43 , L. 5 - 9 ]  [Back]

156 [ E 44 D. L. 6 - 9 ]  [Back]

157 Respondent's Brief; Appellate Court # A 73725. [E. 96 A]  [Back]

158 Ibid; P. 5, "Not only did petitioner's expert "bac[k] off his own opinion ... but the state's expert, Lieu- tenant Hurley ... Testified he could not say one way or the other that an entry could have been erased without leaving any sign of alteration or erasure."  Kistler failed to disclose Hurley's unequivocal "No" response when asked if he could find any signs of "alteration, obliteration, or prior writing" in any of the time slots he examined.  [Back]

159 [E 100 CD]  [Back]

160 "I had no reason to believe then nor have I ever had any reason to disbelieve the veracity of the evidence presented by the State in that case." Marquis, McIver vs. Oregon, Lincoln Co. # 904733 [E. 100 D ]  [Back]

161 [E. 5 C, Par. 6 ]  [Back]

162 [E.3 B, L. 408 - E 3 C, L. 420 ]  [Back]

163 This was the professed reason for the hearing.  [Back]

164 Avakian report; [E. 5 D, P.. #3]  [Back]

165 ibid, P. 4, Par. 4  [Back]

166 ibid, P. 4, Par. 5  [Back]

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