THE CIRCUIT COURT
THE SIXTH JUDICIAL CIRCUIT
G. HUMPHRYS, and
In this sworn deposition of 1994, Roger Pearson admits, under
oath that he uses the pen names, R. Peterson, James McGregor,
deposition of ROGER PEARSON was taken on Thursday, June
23, 1994, commencing at 10:30 a.m., at the office of Carter, Ledyard
& Milburne, 1350 Eye Street, N.W., Suite 870, Washington,
D.C. before Doreen M. Dotzler, Notary Public.
BEHALF OF THE PLAINTIFF:
H. OTTO, ESQ.
Gadau, Selin and Otto
West White Street
OF THE DEFANDANATS (ROGER PEARSON, SCOTT-TWONSEND PUBLISHERS):
F. SONDERICKER, ESQ.
Ledyard & Milburn
York, New York 10005
BEHALF OF THE DEFENDANT (LLOYD HUMPREYS):
R. CORNYN, ESQ.
Mamer & Haughey
called for examination, haivng been first duly sworn, was examined
and testified as follows:
OTTO: Will you state your name and address for the record.
Pearson. 3589 South Ocean Boulevard, Number 8, Palm Beach, Florida.
you ever been involved in a deposition before?
is what we call under Illinois rules a discovery deposition. My
name is Hon Otto and I represent the plaintiff and I will be asking
you certain questions regarding the lawsuit and /p6/ facts that
might lead to relevant information.
is anything that I don't ask you clearly or you don't understand,
please ask me to rephrase and I will be happy to do that.
you a citizen of the United States?
what country are you a citizen?
is your date of birth?
what kind of visa are you in the United States?
long have your lived in the United States?
you ever used any names other than Roger Pearson?
as literary names, pen names.
can you tell me what other names have you used? /7/
couldn't remember tham all.
you remember any of them?
R. Peterson, which is not much of a change.
there others you recall?
there any others?
at this moment.
you ever used the name J.W. Jamieson?
about James McGregor?
it is James McGregor rather than Allen McGregor.
don't think so. We have had him write for us, but I don't think
is some else who is John W. Richards? /8/
don't know offhand. My memory is not so good for all these things.
others that you recall at the present time?
is the purpose for which you've used other names?
not unconstomary for an editor of a journal to refrain from publishing
too frequently under his own name in his own journal. There are
good precedence for that, and rather than appear to be publishing
one's own views, I can cite your, not offhand now but names of
distinguished scholars who were editors of well-know publications
and who used pen names when writing in their publications they
each instance where you've used so-called pen names it has been
where you've published in a publication that you have been editor
of; is that correct? /9/
necessarily. No, I wouldn't say that now. I don't remember.
you recall other occasions when you've used pen names?
I don't think so. But I don't remember.
do you at this time recall other distinguished editors who have
used pen names when they have published in their own publications?
I say I couldn't say now, but I could give you an exmaple later.
you at times using one name quoted yourself using another name?
don't think so, but I don't remember.
that be considered something editors would commonly do?
whom? Considered by whom?
you. Would you consider that something that editors commonly do?
you are referring to an article published under another name,
whether it is your /10/ own, one would tend to use the name under
which the author referred when referring to it.
one normally identify or alert the reader to the fact that that
person is really the same person in the two instances?
don't think so.
Roger Pearson your real name?
on you birth record?
you know when the last time is that you used a different name
other than Roger Pearson?
can't remember now.