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1 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

2 IN AND FOR THE COUNTY OF SANTA CLARA
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4 *************
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6 RANDY CHAPEL, )
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7 Plaintiff, )
)
8 vs. ) CASE NO.: 1-03-
CV-814749
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9 WESTERN SEMINARY, et al., )
)
10 Defendants. )
)
11 )
12
13 DEPOSITION OF ROBERT BRYCESON
14 Friday, April 15, 2005
15 Taken before ORA B. KOHN
Certified Shorthand Reporter
16 State of California
C.S.R. No. 11933
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1 INDEX OF EXAMINATION
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3 Examinations Page
4 EXAMINATION BY MR. DRESSER 6
5 EXAMINATION BY MR. ADLER 23
6 FURTHER EXAMINATION BY MR. DRESSER 35
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1 INDEX OF EXHIBITS
2 Exhibit No. Description Page
3 A Collection of Internet pages. 15
4 Pleasanton Presbyterian Church
5 B Collection of Internet pages. White 16
6 Stone Church
7 C Collection of Internet pages. 16
8 Streets of Hope Kenya
9 D Collection of Internet pages. Only 16
10 You
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1 DEPOSITION OF ROBERT BRYCESON
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3 BE IT REMEMBERED that, pursuant to Notice of
4 Taking Deposition, and on the 15th day of April, 2005,
5 commencing at the hour of 2:54 p.m., in the Offices of
6 Pizzotti & Jarnagin, 5776 Stoneridge Mall Road, Suite
7 178, Pleasanton, California 94588, before me,
8 ORA B. KOHN, a Certified Shorthand Reporter for the
9 State of California, personally appeared
10 ROBERT BRYCESON,
11 produced as a witness in said action, and being by me
12 first duly sworn, was thereupon examined as a witness in
13 said cause.
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15 ************
16
17 WILLIAM DRESSER, ESQUIRE, Law Offices of William
18 Dresser, 2400 Moorpark Avenue, Suite 301, San Jose,
19 California 95113, appeared as counsel on behalf of the
20 Plaintiff.
21 ANDREW R. ADLER, ESQUIRE, Law Offices of
22 Boornazian, Jensen & Garthe, 555 12th Street, Suite
23 1800, Oakland, California 94605, appeared as counsel on
24 behalf of the Defendants.
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1 ELLEN Y. HUNG, ESQUIRE, Law Offices of Gary L.
2 Hall, 114 North Sunrise, Suite A2, Roseville, California
3 95661, appeared as counsel on behalf of the Defendants.
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1 ROBERT BRYCESON,
2 Sworn as a witness by the Certified
3 Shorthand Reporter, testified as follows:
4 EXAMINATION BY MR. DRESSER
5 MR. DRESSER: Q. Would you please state your
6 full name for the record, spelling your first and last
7 names.
8 A. Robert Lance Bryceson R-o-b-e-r-t. And the last
9 name is B-r-y-c-e-s-o-n.
10 Q. Mr. Bryceson, have you ever had a deposition
11 taken before?
12 A. No.
13 Q. The woman to your right and to my left is a court
14 reporter. She's going to take down everything that you
15 say, everything that I say and anything that either Ms.
16 Hung or Mr. Adler may say. Do you understand that?
17 A. Yes.
18 Q. When it is finished, she will have the
19 transcription of this prepared in a little booklet form
20 that will read essentially in a question and answer
21 format. Do you understand that?
22 A. Okay.
23 Q. Now, she's going to take down only words that
24 come out. If you in a normal conversation and in this
25 room were to nod your head up and down and go "uh-huh"

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1 or use hand gestures, the people watching you right now
2 will know what you say, but she's only going to take
3 down the words that are spoken.
4 A. Okay.
5 Q. So if in part of the deposition I say, was that a
6 yes, I'm not trying to be rude. It's just to get a
7 clear record.
8 A. Okay.
9 Q. Now, the oath that you gave is the same as if you
10 were testifying in front of a judge or a jury. And this
11 transcript can itself be used in front of a judge or
12 jury for certain reasons.
13 A. Okay.
14 Q. So it's important that when you give an answer
15 it's an actual answer, not a joke or something. Not
16 that you would. Just keep in mind that the words come
17 out extremely literally, and they're used in a court
18 hearing in an extremely literal sense.
19 A. Okay.
20 Q. If I ask you a question that gets really long or
21 you don't understand it for any reason besides the fact
22 that it got really long, just let me know, and I'll try
23 to rephrase the question, okay?
24 A. Okay.
25 Q. Is there any reason why you wouldn't be able to

8
1 give your best testimony here today?
2 A. Not that I can think of.
3 Q. Did you attend a school called Western Seminary?
4 A. Yes, I did.
5 Q. And when did you first commence education at
6 Western Seminary?
7 A. Okay, timeline. It would have been in --
8 probably in the January, February -- I'm not sure when
9 it started -- in 1990. At that time Western Seminary
10 had a satellite campus in Phoenix at Scottsdale Bible
11 Church, and they had another one here in Los Angeles. I
12 began in the Phoenix school.
13 In September of 1991 I got a position in a church
14 here in Pleasanton, and I moved from Phoenix to
15 Pleasanton and stayed in Western Seminary but continued
16 the education in the Los Gatos satellite. So I didn't
17 have to switch schools or re-enroll or re-apply or
18 anything. I just picked up classes right where I left
19 off because I was technically in the same school.
20 And that -- let's see. That was September '91.
21 Then I graduated with an M. Div. in June of 1993. Might
22 have been May, but whatever the graduating time was.
23 MR. ADLER: Just for the court reporter's
24 benefit, M. Div. --
25 THE WITNESS: Masters of Divinity.

9
1 MR. DRESSER: Q. During the time period when you
2 were going to school at Western Seminary, did it come to
3 the attention of any teacher or administrator that you
4 had a child?
5 A. Yes.
6 Q. How is it that that came to the attention of the
7 school, as far as you understand?
8 A. I'll give you a time line there. In 1991 when I
9 first came out to the Bay Area, I started -- I was a
10 technical director at a church running sound, lights,
11 occasionally singing, that kind of a thing. And I was
12 on the church staff. I met a girl around December of
13 '91 we began dating. We decided -- one night in a --
14 for whatever reason we slept together. I felt bad. I
15 didn't want to go that route, so we began to break the
16 relationship off, but she was pregnant. This would
17 have been April, May of 1992 now.
18 At the time I immediately went in and resigned my
19 position, but the church would not accept my
20 resignation. They wanted to keep -- create some sort of
21 restoration process, which we began immediately. I
22 changed some of my duties and responsibilities, did a
23 lot of the same things, but wasn't up on the platform,
24 never led worship, none of those kinds of things, but
25 still did a lot of technical directing and whatnot

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1 behind the scenes.
2 Somewhere around -- must have been October,
3 Novemberish of 1993, I was still going to the seminary
4 the whole time, so I went down to pick up something at
5 the school. At the time my girlfriend, who was pretty
6 well with child, came with me, and I picked up the
7 paper, drove home. And a couple days later I got a call
8 from the seminary. And I believe it was David Eckman
9 who called and wanted to set up an appointment to talk
10 with me. It might have been someone else who called,
11 but the appointment was with David Eckman to talk.
12 Q. Let's go just back to clear up dates. You said
13 it was sometime in October or November. I believe you
14 then said it was 1993.
15 A. I'm sorry. It would have been '92. I'm sorry.
16 It would have been '92, yes.
17 Q. And so the manner in which this became known to
18 the school was that someone observed that your
19 girlfriend was pregnant?
20 A. Right.
21 MR. ADLER: Object to the question as calling for
22 speculation.
23 THE WITNESS: The manner in which it came to the
24 attention of the school is someone in the office saw my
25 girlfriend and told David Eckman, which instituted

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1 getting together.
2 MR. DRESSER: Q. Now let's clear up a couple
3 things. This woman who was your girlfriend is now your
4 wife.
5 A. Yes.
6 Q. And the child came out well?
7 A. Yeah.
8 Q. And you hadn't gone to David Eckman to tell him,
9 you know, I had --
10 A. No.
11 Q. -- I had conjugal relations?
12 A. No, I did not initiate any conversation at all
13 with anyone at the seminary.
14 Q. And subsequent to David Eckman calling you to set
15 up an appointment, about how long after that did you
16 meet with him?
17 MR. ADLER: Object to the question. Misstates
18 his testimony.
19 THE WITNESS: You want to rephrase it or?
20 MR. DRESSER: Q. Here's the situation. If I
21 have a question that's not accurate, let me know.
22 A. Okay.
23 Q. Mr. Adler may make objections. You'll see the
24 transcripts in this case are filled with objections.
25 But the questions -- if you understand the question and

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1 it's accurate, you can answer.
2 A. It was within about a week. It was a very, very
3 short time from the time I received a call to -- would
4 you please meet with David Eckman to meeting with him
5 was about a week. Might have been a couple days. I
6 mean, I don't recall exactly, but I know it wasn't like
7 a month or two months. It was very, very quick.
8 Q. And where did you meet?
9 A. We met at the seminary campus, which was at the
10 Big Stone Baptist church where the seminary offices
11 were. We met in one of the church office rooms.
12 Q. Was anyone there besides Dean Eckman?
13 A. I don't think so.
14 Q. Did Dean Eckman --
15 A. I'm sorry. You know, I can't -- it's weird, but
16 I can't remember if Tanya was with me or not. It's
17 possible he may have met with both of us. And it was so
18 long ago. It was not a hugely meaningful meeting to me.
19 I can't remember if she was with me, but she may have
20 been with me, but I don't recall. There was no other
21 seminary personnel or any other person there.
22 Q. Prior to the time that Dean David Eckman had met
23 with you, had anyone else from the school, in
24 administration or a professor, spoken with you about
25 your having had relations with Tanya?

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1 A. No. I could state that it wasn't the kind of
2 campus life where private and personal life interacted.
3 It was a commuter school. You'd go down for four hours
4 a day on a Saturday, and you'd go home and wouldn't see
5 anyone for a week again. In my year and a half at
6 Western Seminary Los Gatos, that one meeting with David
7 Eckman, one time I met with a professor, named Marilyn,
8 who was a Hebrew professor, in a coffee shop to get some
9 extra homework clarification. And once or twice I may
10 have met Jim Sawyer at the church I was in. Other than
11 that, there were no personal conversations private
12 moments, coffee, lunches, anything with any of the
13 professors. So for me to say would you talk to a
14 seminary professor about it was -- I wouldn't even
15 consider it. We didn't so much as have coffee, let
16 alone divulge personal issues about my life.
17 Q. About how long did you meet with David Eckman
18 for?
19 A. Probably an hour.
20 Q. During any time of that conversation with Dean
21 Eckman, did he indicate that this -- the school would
22 either take or consider taking disciplinary action
23 against you?
24 A. No.
25 Q. Did the school at any time require that you go

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1 through any counseling?
2 A. No.
3 Q. Did the school ever tell you that they were going
4 to suspend your education?
5 A. No.
6 Q. Was your education with Western Seminary ever
7 suspended by the school?
8 A. No.
9 Q. Did you ever go through a student development
10 committee or other disciplinary hearing?
11 A. No.
12 Q. Were you allowed to continue with your education
13 and graduate?
14 A. Yes. My daughter was born in December of '92. I
15 graduated the following -- you know, six months later.
16 I graduated on a Saturday, went to ceremonies. The very
17 next day I married Tanya.
18 Q. Did the school request that you give to them any
19 information about any counseling you went to, either
20 church counseling or psychological counseling?
21 A. No, not at all.
22 Q. Did anyone at the school ever tell you that you
23 would not be qualified to graduate unless you went
24 through some school program?
25 A. No.

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1 Q. Just going to show you a couple of things. I
2 pulled down from the Internet a document which has
3 "Pleasanton Presbyterian Church" on the heading. It has
4 two pages. I'm going to ask you to look at this.
5 MR. ADLER: Before you show it to him, might we
6 see it?
7 MR. DRESSER: Yes, you may look at it, Counsel.
8 MR. ADLER: Thank you.
9 MR. DRESSER: I'm going to show you that, and
10 I'll pass that on to Mr. Adler so he can look at it.
11 And I'm going to show you that one as well.
12 THE WITNESS: Yeah. You've done an Internet
13 search of my name obviously.
14 MR. DRESSER: I'm now circulating to Counsel
15 documents that can be obtained from the Internet.
16 Mr. -- concerning Mr. Bryceson. Exhibit A will be a
17 two-page document which is the Pleasanton Presbyterian
18 Church document.
19 [Whereupon, Deposition Exhibit A, a
20 Collection of Internet pages.
21 Pleasanton Presbyterian Church, was
22 marked for identification.]
23 Exhibit B will be a White Stone Church document
24 which is two pages.
25 [Whereupon, Deposition Exhibit B, a

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1 Collection of Internet pages. White
2 Stone Church, was marked for
3 identification.]
4 Exhibit three (sic) will be a Streets of Hopes
5 Foundation Kenya three-page document.
6 [Whereupon, Deposition Exhibit C, a
7 Collection of Internet pages.
8 Streets of Hope Kenya, was marked
9 for identification.]
10 And Exhibit 4 (sic) will be a three-page
11 document. The first page has on it a song, "Only You."
12 [Whereupon, Deposition Exhibit D, a
13 Collection of Internet pages. Only
14 You, was marked for
15 identification.]
16 MR. DRESSER: Q. Mr. Bryceson, do you know what
17 the document which has been marked as Exhibit A is?
18 A. Yes.
19 Q. What is that?
20 A. That's my current position as an interim worship
21 director at Pleasanton Presbyterian Church.
22 Q. What is -- did you assist in preparing the
23 information which is printed there?
24 A. Yeah. I think most of what's printed there is
25 probably an edited version of what I wrote for their Web

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1 page, um-hm. Yeah.
2 Q. What is Exhibit B?
3 A. Exhibit B is a printout of the Web page of the
4 White Stone Church, which was a church plant I pastored
5 for four years.
6 Q. And that's from the Web site from the White Stone
7 Church?
8 A. Um-hm. Yeah.
9 Q. What is Exhibit C?
10 A. It is in regards to a ministry which rescues
11 street orphans off of the street of Kenya who have
12 been -- Kenya has been devastated by the AIDS crisis
13 and poverty. And it gets them into a group home and
14 into an orphanage. I'm on the board of directors for
15 this foundation.
16 Q. And what is Exhibit D, or at the least the first
17 page of Exhibit D?
18 A. That is lyrics of a worship song that I co-wrote
19 with some friends of mine, which I still make royalties
20 on actually. It's in wide circulation.
21 Internationally, I might add. I know it's being sung in
22 Russia, as well as Brazil and some other place. I've
23 probably got five or six other songs that you can find
24 on the Internet as well that are circulated and have
25 gone globally as well.

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1 Q. Is the information that's contained on Exhibit A
2 accurate as it concerns you?
3 A. Yeah. Yeah, for the most part. Yes. I mean, I
4 didn't look -- I haven't read the edited version, but
5 yeah. Yes, it is. I just glanced over it.
6 Q. Did the school ever request that you submit a
7 written statement, in terms to be agreed upon by the
8 seminary, acknowledging that one, by engaging in sexual
9 intercourse regardless of -- whether it occurred on one
10 occasion or multiple occasions, that you violated the
11 spirit of the seminary standard of character and
12 conduct, and two, that you had opted out of a process of
13 the seminary in trying to respond to investigations of
14 alleged misconduct?
15 A. I never signed anything from my last year and a
16 half at Los Gatos. I seem to recall as just standard
17 procedure for both Multnomah School of the Bible and
18 others, that upon initially enrolling, there was some
19 kind of a conduct document. I couldn't recall at all
20 what it would have said by now, though. Just sort of
21 standard things. But from the time that I met with
22 David and Western Seminary was aware of my situation,
23 there was no repercussions. No additional things needed
24 to be signed. No follow-up to writing something what
25 you mentioned, so.

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1 Q. Did anyone from Western Seminary ever tell you
2 that if you violated any character or conduct code that
3 you would be subject to discipline by the school?
4 A. No.
5 Q. Just to make it clear -- I think you already
6 answered the question, but because there are specific
7 things that are relevant to this case, I'm just going to
8 ask you some specific ones. Did the school, meaning
9 Western Seminary, ever request that you provide an
10 express written waiver of any privilege of
11 confidentiality between yourself and any counselor?
12 A. No, I never wrote anything. I seem to recall
13 that I verbally gave David Eckman permission to contact
14 the church leaders who were over me during this season
15 of life. And he could follow up with them or talk with
16 them regarding what was happening in my situation.
17 Q. Do you know whether he ever did?
18 A. I don't know whether he ever did or not.
19 Q. And did any -- was that ever made a condition of
20 your continuing to remain at school?
21 A. No. In fact, I don't think we ever met again or
22 discussed the issue again with anyone at the school.
23 Q. I'm going -- there is a couple of people who are
24 still at Western Seminary who may be witness to some of
25 the things involving my client, Randy Chaple. I'm going

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1 to ask you a couple questions about them. Do you know
2 -- you've indicated you know who James Sawyer is,
3 correct?
4 A. Um-hm. Yes.
5 Q. Did he teach any courses that you took?
6 A. Yeah, I took several courses from him. Probably
7 more than any other professor.
8 Q. Did you find him to be a competent professor?
9 A. Yes.
10 Q. Did you find him to be honest?
11 A. Yes.
12 Q. Do you know anything about whether he is ordained
13 or is a pastor in any fashion?
14 A. No, I don't think he was. Around the same
15 season, he came and attended the church that I was going
16 through this process with. He attended off and on a
17 little bit. And so as far as I know, if he was showing
18 up at our place on Sundays, he was not pastoring a
19 church somewhere. So -- and he attended there -- I
20 don't know how long, but it was quite a few times I'd
21 see him there.
22 Q. Did you ever have what you would consider a
23 penitent/clergy relationship with the Reverend professor
24 James Sawyer?
25 A. No. I wouldn't have named that. He was a

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1 professor to me. I enjoyed his classes. I enjoyed
2 conversation with him before and after class. I don't
3 think I ever once can recall a conversation that I would
4 had with Jim outside of the seminary situation. Until
5 one day I saw him at the church and just, Hey. Hi. Dr.
6 Sawyer, good to see you here. It was that kind of thing.
7 There was no let's sit and talk. Not even let's go and
8 have coffee together.
9 Q. You've indicated you've met you met with Dean
10 Eckman.
11 A. Um-hm.
12 Q. Did you take any courses from him?
13 A. Yes. I think I took one, maybe two classes. I
14 know for sure one.
15 Q. Do you remember which course you took from Dean
16 Eckman?
17 A. Boy, what was the name of it? I think it had to
18 do with the pastoral counseling or something of that
19 nature. Philosophy of counseling. Did a lot of
20 philosophy of classes in those days.
21 Q. Did you ever take any courses from a Gary Tuck?
22 A. No. He was there at the time, but I never had
23 classes from him.
24 Q. Did anyone ever tell you anything about Gary Tuck
25 sufficient for you to reach an opinion concerning any

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1 reputation that he might have?
2 A. Not really.
3 MR. ADLER: I object to the question insofar as
4 it clearly calls for hearsay and speculation. I can't
5 keep you from answering, sir.
6 THE WITNESS: No, I didn't. I don't recall.
7 MR. DRESSER: Q. Did you ever have a position of
8 employment with Western Seminary?
9 A. No.
10 Q. Do you know a gentleman by the name of Lynn
11 Ruark?
12 A. No.
13 Q. Do you know a Steve Korch?
14 A. Doesn't ring a bell at all.
15 Q. Are there any individuals who you had as a
16 professor or administrator at Western Seminary that
17 you've kept in contact with?
18 A. No. Trying to think if I saw David Eckman at all
19 a few years back when I was serving at Creekside
20 Community Church at Alamo. No, I don't think so. I
21 mean, once I graduated I'd hear of them. They were
22 locally around. I would hear about, you know, through
23 mutual acquaintances and friends, that kind of thing,
24 but I don't recall ever meeting with him or seeing him
25 speak or anything.

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1 Q. Let me go over my notes.
2 A. I had two friends at Creekside Community Church
3 of Alamo, when I served there as an associate pastor,
4 who were very taken with David Eckman. They loved a
5 book he had written. One of them was kind of a mentor
6 of mine. That's how I kept in touch. But I don't
7 remember seeing him personally during that time.
8 I guess I can clarify one date issue I said
9 earlier I couldn't remember exactly when I graduated.
10 But then I recall I went through the ceremony on a
11 Saturday and married on a Sunday. That was June. So I
12 remember that date. June 26th, so.
13 Q. The --
14 A. There was about six of us. I think I was in the
15 first graduating class of that satellite campus. Might
16 have been the second, but one of the early ones.
17 MR. DRESSER: I have no further questions at this
18 time. I'll reserve my right to ask questions after
19 Counsel asks you a couple.
20 MR. ADLER: I'd like to take a break. I'd like
21 to get copies of the exhibits so I can give them a look
22 before we go on.
23 (Brief recess.)
24 EXAMINATION BY MR. ADLER
25 MR. ADLER: Q. My name is Andrew Adler. I,

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1 along with Ms. Hung, who's the lady on the other side of
2 the table, represent the seminary, Lynn Ruark, Steve
3 Korch and Gary Tuck as defendants in this lawsuit.
4 Let me ask you first of all, sir, am I correct in
5 my understanding that the only person associated with
6 Western Seminary with whom you spoke regarding your
7 girlfriend's condition was Dean Eckman.
8 A. Yes, with whom I spoke. But David Eckman, in a
9 meeting, informed me the reason we had the meeting is
10 someone else in the office highlighted it, brought it to
11 his attention, so he's the one who met with me.
12 Q. Did you ever have any contact with anyone whom
13 you understood to be from the Portland campus?
14 A. No, never.
15 Q. Did Dean Eckman ever indicate to you that he had
16 communicated with anyone at Portland about your
17 situation?
18 A. Didn't indi -- not to me. He didn't indicate
19 that to me.
20 Q. Did he ever indicate that he communicated with
21 anyone else at Western Seminary Los Gatos, or any of the
22 other campuses regarding your girlfriend's condition?
23 MR. DRESSER: Other than what he already said?
24 MR. ADLER: Setting aside whoever it was who told
25 him.

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1 A. Right. Setting aside whoever it was that told
2 him, I don't recall any other name being mentioned, so I
3 couldn't say for sure. The only two people that I knew
4 pretty much for sure would have been David Eckman from
5 that meeting, and I'm fairly sure Jim Sawyer. He was
6 coming to church during that season of my life. It was
7 common knowledge of the church, so I assumed he knew as
8 well.
9 Q. Might it have been Professor Sawyer who told Dean
10 Eckman?
11 A. I don't think so, because the day I went down to
12 get those papers, Jim wasn't there. It was someone else
13 in the office.
14 Q. And you associate the Seminary's discovery of
15 your girlfriend's situation with her having been on the
16 seminary property that day?
17 A. David Eckman told me that.
18 Q. Okay.
19 A. Right.
20 Q. Am I, though, correct in my understanding that to
21 the best of your knowledge, the only people associated
22 with Western Seminary who were aware of your
23 girlfriend's pregnancy were Dean Eckman, Professor
24 Sawyer and the presently unknown individual who reported
25 your girlfriend's condition to Dean Eckman?

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1 A. As far as I know. I could say the only person,
2 even Jim Sawyer, the only person that I recall ever
3 meeting with in any official capacity was David Eckman.
4 So even if Jim Sawyer knew, I know not because I met
5 with him regarding this situation. It was -- David
6 Eckman was the only person that I dealt with personally
7 regarding my situation in an official capacity.
8 Q. But what I'm trying to find out right now is
9 whether or not Dean Eckman shared his knowledge of your
10 girlfriend's situation with anyone else anywhere at the
11 Seminary.
12 A. I wouldn't know that. But I do know that Dean
13 Eckman was not -- he was getting his information second
14 hand, so he wasn't the first person.
15 Q. Have you, as you sit here today, any reason to
16 believe that Dean Eckman communicated with the Portland
17 main campus about your girlfriend's pregnancy?
18 A. I assumed he did.
19 Q. On what do you base that assumption?
20 A. Continuing in school and on to graduation, and
21 just maintained the course that I was on without any
22 other changes.
23 Q. So simply the fact that you were allowed to
24 continue, suggested to you that he had communicated to
25 Portland?

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1 A. Yeah.
2 Q. Dean Eckman?
3 A. Right.
4 Q. And Portland decided to do nothing?
5 A. Yes. That's what I assumed.
6 Q. But that was simply an assumption. That wasn't
7 based on anything David Eckman told you, was it?
8 A. I know I was told officially just to stay the
9 course; that I would graduate. Just stay the course.
10 So I was told that, yes. Whether I was told that -- I
11 wasn't told by anyone but Dean Eckman. Now where he got
12 his information and his official capacity to give those
13 words, I wouldn't know. I just assumed it came from --
14 he was Dean of the school, for crying out loud.
15 Q. So let's see if I get this straight. You've
16 assumed that Dean Eckman communicated with Portland?
17 A. Yes.
18 Q. But Dean Eckman never said he communicated with
19 the Portland?
20 A. I wouldn't -- I don't recall whether he said that
21 to me directly, no. I don't recall that now.
22 Q. And you had no contact with anyone whom you
23 understood to be a Portland-based representative of the
24 Seminary?
25 A. No. I never met or talked with anyone from

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1 Portland.
2 Q. You never received anything in writing from
3 anybody in Portland?
4 A. I don't think so, other than my diploma.
5 Q. So the entire basis for your assumption that Dean
6 Eckman reported your girlfriend's situation to Portland
7 was simply that you were permitted to go on?
8 A. Yeah. I should also interject that, though,
9 another capacity to it was our whole situation with my
10 girlfriend and I was under direct and immediate church
11 care. We weren't --
12 Q. I'll get there in just a second.
13 A. That was -- came up in the discussion. So at
14 that time the seminary would have been intervening in
15 the church's authority or capacity or dealing with the
16 situation. It was - you know, my situation was
17 completely one hundred percent under our church's care.
18 So that was a part of the reason why it was communicated
19 to me why the seminary didn't, you know, demand more,
20 ask more, request more, that kind of thing. It was
21 under the church's care, and it's being managed the way
22 the church sees fit.
23 Q. When you say that was communicated to you --
24 A. Yeah.
25 Q. -- that was communicated by Dean Eckman?

29
1 A. Yes, I believe so. Well I mean, he's the only
2 person I talked to in an official capacity, so.
3 Q. Then was it your impression that Dean Eckman
4 believed that the procedure you were going through at
5 the church was a satisfactory substitution for official
6 action by the Seminary?
7 MR. DRESSER: Objection. The question calls for
8 the state of mind of Dean Eckman.
9 THE WITNESS: I don't -- you know, I don't know.
10 What I know for that -- I was left with the impression
11 that because the church was managing our situation, the
12 seminary felt whatever steps -- the steps that the
13 church were taking were full and adequate. And anything
14 that they would have done would have just been muddying
15 the waters and creating more problems. And anything
16 they would have wanted done was what the church was
17 doing anyway.
18 Q. Who gave that you impression?
19 A. David Eckman.
20 Q. Anyone else at the seminary?
21 A. No.
22 Q. When you were asked to come and meet with Dean
23 Eckman, did you have any impression as to what it was
24 you were being called -- or why it was you were being
25 called to his office?

30
1 A. No, but I suspected.
2 Q. What was your suspicion?
3 A. Well, you can't be in a situation like that and,
4 you know, be in a church and go through the situation
5 without feeling all the weight of it. Somewhere I
6 figured somebody called the school and talked with them.
7 That's what I assumed. And I've gone there for a year
8 and a half and no one ever called me for a private
9 conversation. So it was pretty obvious that -- well I
10 assumed what was going to be talked about.
11 Q. Did you expect to be disciplined?
12 A. I don't -- I think so. I think so at the time.
13 I mean, I was already going through a lot of turmoil and
14 trouble with the church. For me I felt like I just
15 don't want more grief. I'm six months away from
16 graduating. I've paid thousands of dollars to get here.
17 I just want to get the degree and complete it and just
18 move on with my life. I've got bigger decisions now.
19 To me anything that the seminary would have to do with
20 my personal life at that juncture was just more
21 interference from -- you know, they had never taken an
22 interest in my personal life before in any way, shape or
23 form. Suddenly -- I just wanted to get my degree and
24 get out. I think that's why I didn't, you know, go and
25 talk to anyone there.

31
1 Q. Let's go back for a moment. I think I asked you
2 if, when you heard from Dean Eckman, or pardon me, when
3 you heard that you were to see Dean Eckman, if you
4 thought that that was probably about your girlfriend's
5 situation, and you said it probably was.
6 A. Yeah.
7 Q. And then I asked if you expected to be
8 disciplined. And I believe you indicated you thought
9 that was a possibility.
10 A. I thought it might have been a possibility, yeah.
11 Q. Why did you believe -- what was there about the
12 seminary in your understanding of the seminary that
13 caused you to expect to be disciplined when the seminary
14 found out that your girlfriend was pregnant?
15 MR. DRESSER: Objection. The reference to the
16 institution as a seminary is misleading. It is an
17 educational institution and a school. If you wish to
18 refer to it by its name, which is Western Seminary,
19 that's one thing, but to refer to it as the seminary is
20 misleading.
21 MR. ADLER: Q. Sir, you understood what I meant?
22 A. I understand what you mean. It was a
23 Christian-based organization wanting to uphold
24 Christian-based values. I was -- assumed, you know,
25 like that they might say we don't want you to graduate

32
1 then. We're going to do something in addition to make
2 this harder, make it more difficult. Something like
3 that may happen.
4 Q. If that had been done, that would not have
5 surprised you, would it?
6 A. No, I suppose not.
7 Q. Have you spoken about this case with Mr. Dresser?
8 A. Yes, earlier, about a year ago I think or about a
9 year ago.
10 Q. Did Mr. Dresser tell you how he got your name?
11 A. Somebody via the seminary remembered me and my
12 situation, but I don't remember if he mentioned whom.
13 Q. Did he tell you it was Professor Sawyer?
14 A. I don't remember if he mentioned who it was. I
15 don't remember that.
16 Q. What did he tell you about this lawsuit?
17 A. It had to do with a student who has been a recent
18 student whose had sexual relations with a girlfriend or
19 a girl, and that there has been some kind of fallout
20 regarding it. And the seminary is wanting to withhold
21 his degree and not allow him to graduate because of it.
22 Q. Did Mr. Dresser tell you that the student had
23 gotten the girl pregnant?
24 A. I -- I don't think -- I think that might have
25 been my surmising from my situation. I don't really

33
1 recall now.
2 Q. And you and I have spoken about this case,
3 haven't we?
4 A. Yes.
5 Q. Within about the last week?
6 A. I think it was a week ago we spoke, yeah, on the
7 phone.
8 Q. I think you recounted to me that Mr. Dresser had
9 told you that the girl in question had gotten pregnant.
10 A. Yeah, but subse -- but I didn't know if he had
11 said that or if I was saying that. So I remember the
12 case was about sexual relations. The pregnancy thing I
13 think I might interjected on my own.
14 Q. What else do you recollect of our conversation,
15 if anything?
16 A. That you were -- there was more that you felt
17 that you could have said, but you didn't want to change
18 my opinion or my -- or add more information. You wanted
19 to get whatever raw feelings or thoughts I had to come
20 out. So you asked me a few questions here and there
21 regarding how much I know. And that we would be at this
22 table or this deposition. And I recall you also asking
23 me if you knew how I might have been discovered, like
24 where did this guy come from. You wanted to know how do
25 they know about you, where did you come from, who at the

34
1 school would know you. Those kinds of questions.
2 Q. Anything else you recollect of that conversation?
3 A. Not significant. Nothing significant that I can
4 recall.
5 Q. Anything that you can recollect of your
6 conversation with Mr. Dresser?
7 A. The first -- I've had two conversations with him,
8 just to clarify.
9 Q. Okay.
10 A. Maybe three. But the first one was a year ago
11 because I can remember it was April 4th. It was the
12 closing Sunday that would be pastoring White Stone
13 Church. That's the very first time I ever met him, in
14 which he kind of filled me in that there was this case.
15 Western Seminary. At some point in the future, if it
16 wasn't resolved, I might be called upon to give a
17 deposition. And here we are a year and a week or so
18 later. I did speak with him again I guess it was just a
19 couple days ago preparing to come here.
20 Q. And what do you recollect of that second
21 conversation?
22 A. The second conversation that I had just a couple
23 days ago was kind of getting here. Telling him what I
24 remember about the case. I did at that time mention an
25 issue of I thought it was about him getting a girl

35
1 pregnant, but he clarified he hadn't said that. It was
2 a sexual situation and things of that nature just to
3 clarify what he had said to me.
4 Q. Am I correct in my understanding that you don't
5 know if Jim Sawyer was an ordained minister or ordained
6 member of the clergy while you were a student at the
7 seminary?
8 A. I don't know if he was or wasn't.
9 Q. You saw him at your church?
10 A. Um-hm.
11 Q. On Sundays more than once?
12 A. More than once.
13 Q. And you assumed if he had been an ordained
14 minister, he'd have been busy with his own congregation
15 on Sunday?
16 A. Yeah. If he was pastoring a church or on staff
17 at a church, he would have been there on Sundays.
18 Q. Let me take a short break. Let me talk with Ms.
19 Hung for a moment. I may be done.
20 (Brief recess.)
21 MR. ADLER: I have nothing more.
22 MS. HUNG: I don't have any questions.
23 FURTHER EXAMINATION BY MR. DRESSER
24 MR. DRESSER: Q. Mr. Bryceson, are you yourself
25 an ordained minister?

36
1 A. Yes, I am.
2 Q. And did you become an ordained minister because
3 you graduated from Western Seminary as compared with a
4 church process?
5 A. Well, there is a combination of both. Yes in the
6 sense that one of the prerequisites to be ordained was
7 to have the degree from the school, a master's degree.
8 M. Div. was one of the prerequisites that I had. I was
9 ordained in a Baptist general conference and in the same
10 church that we had the whole restoration process go
11 through with this, which I might add completely broke
12 apart about four months before I graduated. So, you
13 know, our whole process broke down. So like I said, I
14 graduated. I got married, and I was completely out of
15 the church just kind of drifting. Worked in a cabinet
16 shop for about eight months when that very same church
17 asked me to came back on staff as a teaching pastor,
18 adult education director. So I came back on that same
19 church's staff because they felt they failed in making
20 the process work all the way.
21 And then I was brought back in a higher capacity
22 position. And a lot was the consequence of having M.
23 Div. And worked there again for the next fours years as
24 the teaching pastor. That's the church I got ordained
25 in.

37
1 In the process of going to do a church plan five
2 years ago, I was switching my ordination over to a
3 different group, Evangelical Covenant. One of the
4 proceedings there to switch over was a master's degree.
5 Q. And are you still ordained through the covenant?
6 A. No, I'm not completely done with the process yet.
7 So technically I'm 99 percent done. There's one more
8 class I need to pick up, a church history class for
9 them. So I'm officially still ordained with the Baptist
10 General Conference.
11 Q. So having the Master's of Divinity was a
12 prerequisite to be ordained, but getting the Master's of
13 Divinity by itself did not by itself lead you to be
14 ordained, correct?
15 A. No. If I understand the question right, without
16 the Master's I could not have been ordained. But just
17 having the master's did not mean I could be ordained.
18 There was more to the process than that.
19 Q. And there were other students who were going to
20 Western Seminary who obtained degrees and did not go
21 into pastoring; is that correct?
22 A. Oh, yeah.
23 Q. Now, you said something that the process broke
24 apart sometime before you graduated?
25 A. Yeah, the process with the church did. Yes. So

38
1 it just -- it failed for a variety of reasons. Wrong
2 people in regards to accountability team they had set up
3 with me. People who just didn't know what they were
4 doing. A failure to even determine what's the goal, you
5 know, what are we trying to do with this guy.
6 There came a point when they had filled all the
7 positions and there was no room left for me. So after
8 going through, it was about a 10, 11 month process with
9 this church. It was just -- for a year I was the -- I
10 was just kind of the grunt of the church. You know, I
11 was a gopher in the church. I did whatever grunt jobs
12 there needed to be done. At the time the church went
13 through a moving thing where they had to get out of a
14 built out warehouse, go to a Pleasanton middle school,
15 set up there. Then before they built their building,
16 one of my jobs during that season was just to move
17 equipment. I came in in the morning with a little --
18 few team of guys, set up the whole church. I'd leave;
19 they'd perform church; I'd come tear it all down while
20 they all went to lunch. I did these kinds of things.
21 And at the end of this process we finally moved
22 into the big building, which I was also instrumental in
23 design work there, designing the stage, working with all
24 this. And then they brought in all these new staff
25 people right as they're moving in. And they came to me

39
1 and they said, well after you've done all this, I guess
2 our new job for your restoration we'll make you the head
3 janitor. And I quit. I walked out. I just said this
4 process is stupid. This is going nowhere.
5 So that was in about March of '93. My daughter's
6 -- well, she was four months old. And so that's when I
7 just kind of walked out and started -- I'm still in
8 seminary. For the next four months until I graduated, I
9 just lived off of a student loan until I could just get
10 the degree.
11 And at the time during those few months I wasn't
12 even intending to go into ministry. I was done. I was
13 looking for -- I was going to move to education, go back
14 to education, which my undergraduate degree was in. But
15 I'd done five years worth of work and thousands of
16 dollars. I first started at Multnomah School of Bible;
17 then moved to Western Seminary to complete the degree.
18 So I thought, you know, I didn't want to waste all those
19 years and all those thousands of dollars and all that
20 time to be a few months shy of obtaining the master's.
21 So I stuck it out just to get the master's, but I didn't
22 intend on the staying in ministry.
23 Once I got the degree I couldn't find a job. It
24 was just weird. I wasn't looking into the ministry.
25 And the way I would phrase it is just God didn't want me

40
1 to get out of ministry, so he made it so it was
2 impossible for me to find another job so that I would be
3 there to accept the job that the same church offered me.
4 And from there on it exploded. Went really well.
5 Q. Do you know whether Dean Eckman or anyone else
6 from the school became aware that several months before
7 you -- your graduation, the process that you were going
8 through the church, which you called a restoration
9 process, had broken down?
10 A. I don't know. I don't remember discussing it
11 with him. But I might have. I just don't remember. I
12 think I had bigger issues on my mind than to talk to
13 David Eckman about my life at that time.
14 MR. DRESSER: I have no further questions. Thank
15 you.
16 MR. ADLER: Nor have I.
17 (Whereupon, at the hour of 3:48 p.m. the matter
18 was adjourned.)
19
20
21
22 ___________________________
23 Signature of Witness
24
25

41
1 CERTIFICATE OF REPORTER
2
3 I, ORA B. KOHN, hereby certify that said
4 proceedings were taken in shorthand by me, a Certified
5 Shorthand Reporter of the State of California, and were
6 thereafter transcribed by computer-aided transcription,
7 and that the foregoing transcript constitutes a full,
8 true and correct report of said proceedings which took
9 place.
10 That I am a disinterested person in the said
11 action.
12 IN WITNESS WHEREOF, I have hereunto set my hand
13 this 25th day of April, 2005.
14
15
16
17
18
19 ORA B. KOHN,
20 CSR # 11933
21
22
23
24
25

42
1 PIZZOTTI & JARNAGIN
Certified Shorthand Reporters
2 5776 Stoneridge Mall Road, Suite 178
Pleasanton, California 94588
3 (925) 416-1800
4
April 25, 2005
5
TO: Robert Bryceson
6 7052 Amadore Valley Blvd
Dublin, California 94568
7
IN RE: Chapel vs Western Seminary
8 Case No. 1-03-CV-814749
9
Dear Mr. Bryceson:
10
Your deposition in the above matter is now
11 available at this office. You may wish to discuss with
your attorney whether he or she requires that it be
12 read, corrected, if necessary, and signed before it is
filed with the court, if so ordered.
13
Since the original deposition may not be released
14 from our custody, if you wish to sign it, please
telephone this office. It is necessary that you bring
15 this letter with you.
16 In the alternative, you may wish to read your
attorney's copy of the deposition and notify this office
17 by letter of any changes that you desire to be made.
18
Very Truly Yours,
19
20
21 ORA B. KOHN, CSR NO. 11933
22
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24
25