IN
THE CIRCUIT COURT
FOR
THE SIXTH JUDICIAL CIRCUIT
CHAMPAIGN
COUNTY, ILLINOIS
JERRY
HIRSCH,
Plaintiff,
vs.
No. 92-L-1244
ROGER
PEARSON,
LLOYD
G. HUMPHRYS, and
SCOTT-TOWNSEND
PUBLISHERS,
jointly
and severally,
Defendants.
Note:
In this sworn deposition of 1994, Roger Pearson admits, under
oath that he uses the pen names, R. Peterson, James McGregor,
Edward Langford.
The
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.
APPEARANCES
ON
BEHALF OF THE PLAINTIFF:
JOHN
H. OTTO, ESQ.
Zimmerly,
Gadau, Selin and Otto
204
West White Street
P.O.
Box 3998
Champagin,
Illinois 61826-3998
(217)
352-7676
ON BEHALF
OF THE DEFANDANATS (ROGER PEARSON, SCOTT-TWONSEND PUBLISHERS):
WILLIAM
F. SONDERICKER, ESQ.
Carter,
Ledyard & Milburn
2
Wall Street
New
York, New York 10005
(212)
732-3200
ON
BEHALF OF THE DEFENDANT (LLOYD HUMPREYS):
MICHAEL
R. CORNYN, ESQ.
Thomas,
Mamer & Haughey
P.O.
Box 560
Champaign,
Illinois 61824-0560
(217)
351-1500
PROCEEDINGS
Whereupon
--
ROGER
PEARSON
a witness,
called for examination, haivng been first duly sworn, was examined
and testified as follows:
MR.
OTTO: Will you state your name and address for the record.
A. Roger
Pearson. 3589 South Ocean Boulevard, Number 8, Palm Beach, Florida.
Q. Have
you ever been involved in a deposition before?
A. No.
Q. This
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.
If there
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.
A. Yes.
Q. Are
you a citizen of the United States?
A. No.
Q. Of
what country are you a citizen?
A. United
Kingdom.
Q. What
is your date of birth?
A. 21
August 1927
Q. Under
what kind of visa are you in the United States?
A. Resident
alien.
Q. How
long have your lived in the United States?
A. Since
1965.
Q. Have
you ever used any names other than Roger Pearson?
A. Only
as literary names, pen names.
Q. And
can you tell me what other names have you used? /7/
A. I
couldn't remember tham all.
Q. Do
you remember any of them?
A. Peterson,
R. Peterson, which is not much of a change.
...
Are
there others you recall?
A. Allen
McGregor.
Q. Are
there any others?
A. Not
at this moment.
Q. Have
you ever used the name J.W. Jamieson?
A. Yes.
Q. What
about James McGregor?
A. Mayber
it is James McGregor rather than Allen McGregor.
Q. John
W. Richards?
A. I
don't think so. We have had him write for us, but I don't think
so.
Q. There
is some else who is John W. Richards? /8/
A. I
don't know offhand. My memory is not so good for all these things.
Q. Edward
Langford?
A. Yes.
Q. Any
others that you recall at the present time?
A. No.
Q. What
is the purpose for which you've used other names?
A. It's
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
edited.
Q. In
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/
A. Not
necessarily. No, I wouldn't say that now. I don't remember.
Q. Do
you recall other occasions when you've used pen names?
A. No,
I don't think so. But I don't remember.
Q. And
do you at this time recall other distinguished editors who have
used pen names when they have published in their own publications?
A. As
I say I couldn't say now, but I could give you an exmaple later.
Q. Have
you at times using one name quoted yourself using another name?
A. I
don't think so, but I don't remember.
Q. Would
that be considered something editors would commonly do?
A. By
whom? Considered by whom?
Q. By
you. Would you consider that something that editors commonly do?
A. If
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.
Q. Would
one normally identify or alert the reader to the fact that that
person is really the same person in the two instances?
A. I
don't think so.
Q. Is
Roger Pearson your real name?
A. Yes.
Q. That's
on you birth record?
A. Absolutely.
Q. Do
you know when the last time is that you used a different name
other than Roger Pearson?
A. I
can't remember now.