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Question (Mr. Richardson): What do you understand the stipulation or stipulations were that was placed on Dr. Klouda in her being a professor at Southwestern?

Answer (Defendant Patterson): Stipulation, as I understand it, is that she should teach only biblical language and exegesis and that she should not teach exposition of the biblical books.

Q. Of what?

A. Of the biblical books.

Q. And as far as you know, did she operate within the confinement of those stipulations?

A. I think that there is reason to question whether she did.

Q. Has there been allegations that she didn’t?

A. Yes, I had students come to me and raise that question.

Q. When?

A. A number of times, but to give you dates, I cannot.

Q. How many students do you say came to you?

A. I have no idea at this point.

Q. And what is it you’re saying they said?

A. That essentially she was actually teaching exposition in the classroom.

Q. And give me an idea of what that would be?

A. That she would not only teach the language, but that then she would draw conclusions about it from the ministry and that kind of thing.

Q. And that would violate the stipulation put on her when she was hired as a — elected as professor, correct?

A. As I understand it, it would.

Q. How — give me some idea, if you would, when it was that you say students came to you and made this comment?

A. Once again, I couldn’t give you dates. I can tell you that shortly after I came to the seminary I began to have some students come in.

Q. And telling you that she was doing that which violated the stipulations under which she was hired?

A. I don’t think most of the students had any idea about exactly what the stipulation was. I think they came with concerns about what was going on in the class.

Q. So they — they just come to see you as the president to say I’m concerned because Dr. Klouda is drawing conclusions on what she’s been teaching, is that kind of the way it happened? According to you?

A. Not — not in all cases.

Q. Well, what other — did it happen that way in some cases, some student walks in and says, Dr. Patterson, I sure need to talk to you, I have concerns about the fact that Dr. Klouda is drawing conclusions? Is that kind of the way it happened?

A. I don’t recall that that was the exact verbiage involved in it. They were concerned that Dr. Klouda was — was teaching in a way that violated our commitment to the Baptist Faith and Message, and to the fact that she was instructing pastors and future pastors in these matters.

Q. Did any of them say whether or not they had discussed that with Dr. Klouda?

A. I do not recall anybody asking that.

Q. Did you ask them?

A. I almost always do. I don’t remember the conversations in — in great detail, but almost always I ask that question.

Q. So you think you asked this student or students that came in and expressed to you that they had concerns that Dr. Klouda was violating the BFM in the method in which she was teaching?

A. Uh-huh.

Q. And you asked them, well, have you talked to her about it, is that kind of the way it went?

A. That is usually what I would do. But I stress that I do not remember specific conversations at that point.

Q. And I assume that when they came, that if — the ones you say came, if they did come and say what you’re saying they said, that you automatically knew yourself that if this was happening, that that would be a violations of the stipulations placed on Dr. Klouda, correct?

A. Would you state that question –

Q. Sure

A. — one more time, please, sir.

Q. If these students did come to you, as you say they did, and say the things you’re saying they said, you automatically, knowing the stipulations placed on Dr. Klouda, would know that that would be in violation of those stipulations, correct?

A. If their testimony were correct, yes.

Q. Right. So I assume that you would have made some kind of memorandum, note, documentation, of this conversation or conversations that you say you had with students, correct?

A. Negative.

Q. I’m sorry.

A. Negative.

Q. Why wouldn’t you at least document it if — if you have a professor violating dictates that has been placed on them, whether it’s Dr. Klouda as a female or a professor that’s a male, why wouldn’t you, or at least have someone in your administration document it?

A. For the simple reason that people approach me in the halls, ask me things when I can’t document, and not only that, I don’t document everything that comes into my office.

Q. I full well respect that in both instances. But I’m talking about you telling us that somewhere between five and ten students came to you specifically telling you as the president of the seminary, that Dr. Klouda was violating the stipulations placed on her as a professor. Now that’s not just a hallway conversation, is it?

Mr. Sharpe (Patteron’s Lawyer): Objection –

Q. (By Mr. Richardson): Would you agree?

Mr. Sharpe: Mischaracterization.

A. I have hallway conversations about everything imaginable.

Q. (By Mr. Richardson) Well, tell me, if you would, what you did do then, if anything, if it’s a fact that as many as five to ten students came and told you that Dr. Klouda was violating the stipulations? What did you do?

A. I began to watch the situation very carefully, which is what I would do in any case.

Q. You watched the situation very carefully, but you didn’t record who it was that came to you or what it was they said, right?

A. No.

. . .

Q. Now — what did you do and how did you do it to watch this situation very carefully?

A. My approach to the presidency is always to keep my ears to the ground. And simply listen for what people are saying who are in various classes, and I don’t draw any conclusions on anything until I have heard a considerable amount. And then if necessary, I would proceed in maybe some other way. But mainly I’m listening to what people say.

Q. Okay. Now, you told me that that’s your typical way of operating, what did you do in the case of Dr. Klouda?

A. Exactly that.

Q. So you — as I understand you’re saying, kept your ear close to the ground?

A. Yes.

Q. I assume that that means listening to the gossip?

A. I don’t say gossip, because I don’t know that it is gossip.

Q. How would you characterize it?

A. I would call it student discussion.

Q. And when you “kept your ear close to the ground,” what student discussion is it you’re claiming that you heard with regards to Dr. Klouda and how she was teaching?

A. I don’t recall the exact nature of those discussions, other than the fact that students were struggling with the question of whether or not this was appropriate in our ecclesiastical setting.

Q. Do you know of any place in the documentation at Southwestern that it would state that you came to hear from students that Dr. Klouda was violating her stipulation? Is that written anywhere that you know of?

A. Not to my knowledge, no.

Q. If that was true and those things you’re saying happened didn’t happen, why wouldn’t you put that somewhere as — as a reason for terminating Dr. Klouda?

A. Because the reason for termination of Dr. Klouda is ultimately an eccles — ecclesiastical concern.

Q. Meaning your interpretation of the scriptures?

A. Yes.

Q. When these — if, in fact, these students you’re saying came to you and said the things to you your’e saying they said, did that cause you any great deal of concern?

A. I’m always concerned that student opinion is a matter of importance.

Q. And I’m not interested in what you’re always concerned about, I’m interested in Dr. Klouda. Did that cause you any specific concern?

A. Yes.

Q. And the only thing you’re saying you did was keep your ear close to the ground?

A. That’s essentially correct, yes.

Q. Did you go talk to Dr. Klouda and ask her if this was happening?

A. I did not.

Q. Did you have anyone monitor her classroom to see if this was happening?

A. I did not.

(To be continued . . . )