In his February 25, 2008 deposition, Defendant Patterson had this to say about his relationship with ERLC President Richard Land:
Question (Mr. Richardson): Okay. Are you familiar with the Dallas Morning News article in — on May 19th, 2000 where Dr. Land made a statement about his position and belief on this issue?
Answer (Defendant Patterson): No.
[Exhibit 1 is marked]
Q. If you would, go to the last page when you get through. Go ahead and take a minute and look at it.
A. Uh-huh.
Q. It will be exhibit 1. You’ve had an opportunity now to read the document I just marked as Exhibit 1, which is the Dallas Morning News article May 19, 2000 which says “Baptists draft changes to statement of faith.” And I specifically wanted to — wanted to direct your attention to the last page of that article that says, The change — before I do that, let me ask you this. You said that Dr. Land is the president of the Southern Baptist Ethics and Religious Liberty Commission; is that correct?
A. That’s correct.
Q. And has been since 1988, correct?
A. I don’t recall the date.
Q. A long time?
A. Yes, a long time.
Q. And would you agree that it is obvious that the Southwestern Baptists see Richard Land as a brilliant, cultural and philosophical thinker, and as well as seen thusly by trustees and administration at Southwestern Seminary?
Mr. Sharpe: Objection, speculative.
Q. Go ahead.
A. The first thing one learns in this life is that you can’t speak for Southern Baptists. So I couldn’t speak for Southern Baptists, I’m happy to tell you that I certainly view him thusly.
Q. Well, let me narrow it down then to the trustees and administration at Southwestern Seminary and say, would you agree that they view Richard Land as a brilliant, cultural and philosophical thinker?
A. I — I’m unable to speak for my trustees, I’ve got 40 of them.
(Editorial insertion: SWBTS established the Richard Land Center for Cultural Engagement on October 17, 2007.)
Q. Okay. And in the exhibit I just handed you, number one, the last page, you have it there before you, see if I read this correctly. “The change in the Faith and Message would not prohibit women from serving as seminary professors or administrative leaders,” Dr. Land said. Did I read that correctly?
A. You read that correctly.
Q. Do you agree with his statement?
A. Yes, I do.
Q. And how is that consistent then with your position that women are not qualified to serve as seminary professors or administrative leaders?
A. Well, you did not state my position correctly.
Q. I — I assume you’re going to say certain seminary classes, right?
A. Certain areas of the seminary, that is correct.
Q. Okay. So you’re saying then that Dr. Land, in your opinion, is not taking into account all positions in the seminary, is that correct?
A. Sir, I can’t speak for Dr. Land.
Q. Have you ever discussed it with him?
A. Not that I recall.
Q. How often do you see Dr. Land?
A. Minimally, three times a year.
Q. And when’s the last time you saw him?
A. It would have been last week.
Q. And did you tell him you were giving your deposition this week?
A. I don’t think I mentioned it to him.
Q. And you’re testifying under oath today, Dr. Patterson, that you have never, to your recall, discussed with Dr. Land the issue of Dr. Klouda’s termination?
A. I — I don’t recall it. It’s not to say that I have not.
Q. Do you have any — and I don’t mean this to be cute, but I need to ask you, do you have any unusual disability with regards to being able to recall?
A. No, sir, I just don’t recall. I live a reasonably busy life and see a lot of people.
Now flash forward three days after Defendant Patterson’s deposition to his chapel sermon of February 28, 2008. In an exposition of Matthew 5:33-38, Defendant Patterson discussed his friendship with Dr. Land by revealing the following, which can be heard at approximate 13 minutes and 21 seconds into the message:
My dear, precious friend, Dr. Richard Land, whom I love with all my heart as you know. We don’t disagree on just about anything, but once in a while we do have a disagreement and when we do it is fun. I mean we get on the phone late at night, and I mean from 11 until 1 in the morning you wouldn’t even know we were Christians. Man, we go at each other, and we have the best time, and then we say, ’see you in the morning,’ you know. And we’re happy about it.
Well, I called him up and I said, ‘Dr. Land I’m fixing to preach on this and not only that I’m fixing to appear in court, and I’ve been getting more and more under conviction about this. What do you have to say about this?’
Then he said, “render unto Caesar the things that are Caesar’s and unto God the things that are God’s.”
And so I took it that he would not hesitate to swear in court to tell the truth and nothing but the truth so help him God.
But I can’t go there with Dr. Land, who may be listening today. Love you, Dr. Land, but you’re wrong again.”
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