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.

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