December 5, 1984
RONALD GODWIN, a witness, called on behalf of the plaintiff, after having first been duly sworn, testified as follows:
DIRECT EXAMINATION
Q: How would you describe the amount of engery [sic] and time that is spent by Jerry Falwell in the many, many activities in which he is engaged in his many ministries?
A: Well, it is an exhausting schedule.
Q: How many hours a day would you say Jerry Falwell works at these ministries?
A: It might vary, but seldom would it ever be under twelve (12) hours a day.
Q: How many days a week?
A: Just seven (7) days a week.
Q: Are you familiar with Jerry Falwell's extensive traveling around this country?
A: I am.
Q: Do you sometimes travel with him?
A: Frequently.
Q: On a day-to-day operational basis, Dr. Godwin, how much time do you spend daily with Jerry Falwell?
A: Well, it varies, but I spend anywhere from an hour or so a day to most of the day.
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Q: Did you see what his reaction was when he read that ad over?
A: I was not present when Dr. Falwell saw the ad. I was with Dr. Falwell shortly after he had seen the ad.
Q: What did you observe about Dr. Falwell, Jerry Falwell, shortly after he had seen that ad?
A: He was more troubled, more serious, more concerned than I had ever seen him on any other issue, crisis or otherwise.
Q: Did he appear to be angry?
A: Yes, and deeply hurt, offended, I think.
Q: In all of the years of your intense association in working with Jerry Falwell had you ever seen him as hurt, despaired or upset?
A: No, sir, never.
Q: About anything?
A: No, sir.
Q: In the time that has gone on, in the approximate year that has transpired since he first became aware of that ad, have you noticed any change or difference about Dr. Falwell, Jerry Falwell?
A: There was a great deal of preoccupation and it was more difficult for me as an administrator to get Dr. Falwell's attention and to get him to be able to focus on the details of the organization we administer.
Q: Is that something that has continued since the fall or October or November of '83, even up to the present?
A: Generally so, yes, sir.
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CROSS EXAMINATION
Q: Thank you; after this ad parody appeared, Dr. Godwin, did you notice any decrease in the quantity of Mr. Falwell's activities in terms of preaching and speaking at different things? Did he cut back his schedule in any way?
A: Not to my knowledge. I believe he has kept his commitments.
Q: Did you notice any effect on the quality of his performance, as you watch the Old Time Gospel Hour and you see him speak? Did he seem to lose his dynamism in speaking, objectively?
A: I don't -- I have seen Dr. Falwell's general demeanor and behavior in subtle ways and in ways which are apparent to me, which may or may not be apparent to national audiences, affected over the last period of months.
Q: Would you describe exactly what you observed in terms of qualitative effect on his abilities?
A: Dr. Falwell is a very enthusiastic, optimistic individual. I often describe him as a person to whom the glass is always half full and never half empty. A certain degree of that enthusiasm and optimism, ability to concentrate, to focus on the myriad details of organizations such as ours, in my opinion, was diminished.
Q: You say it did impair his performance?
A: In my opinion, yes.
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Q: When you first saw him after he had been exposed to it, did you notice any overt emotion on his part?
A: Well, yes; I have already described the fact that he was more troubled, more serious. He is not a very -- if you are asking me about overt emotion, was he out of control, no.
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