What were the circumstances of that first encounter?
Was she a virgin?
Do you think your libido is average?
Was Ms. Ballman a nymphomaniac?
Was she a lesbian?
Did you once tell Ms. Homes that Ellen Ballman was a nymphomaniac and on another occasion that she was a lesbian?
Did your male friends also have girls on the side?
How many of them knew Ms. Ballman?
Did you worry that Ms. Ballman was sleeping with other men — your friends?
When your sexual relationship with Ms. Ballman began, how old was she?
What would prompt a teenage girl in the 1950s to leave her mother’s care and take up with a married man?
Did Ellen Ballman tell you that someone was molesting her?
You told Ms. Homes that Ms. Ballman told you something that would have indicated that something was happening in her mother’s home and that you probably should have listened better.
Did you take advantage of Ms. Ballman?
Did you use birth control?
Did Ms. Ballman meet your family — your mother?
Your children?
Your wife?
How did it happen that your eldest son spent time with Ms. Ballman?
When did you realize you were in love with Ms. Ballman?
So, were you or were you not in love with Ms. Ballman?
Did she believe you were in love with her?
On more than one occasion did you propose marriage?
Even though you were already married, Mr. Hecht, you proposed to Ms. Ballman when she was seventeen — you called her mother and asked for permission to marry her?
How did you think you would explain that to your wife?
Do you believe in polygamy, Mr. Hecht?
How and when did your wife find out that you and Ms. Ballman were having a relationship?
Did your wife know how old Ms. Ballman was?
And what did you say to your wife? Again I’d like to remind you that you are under oath and your wife will be answering the same question.
Did your wife contemplate divorcing you?
Is divorce in opposition to her faith?
Are you and your wife of the same faith?
Is adultery in opposition to your faith?
Are you a religious man, Mr. Hecht?
Do you believe in heaven, Mr. Hecht?
What was your nickname for Ms. Ballman?
Was “the Dragon Lady” one of them?
Where did that come from? Was it from something you shared?
Did Ms. Ballman have you arrested for deserting her?
When Ms. Ballman was pregnant, you sent her to Florida to live and said you’d be joining her there — but you never showed up?
And your wife was pregnant at the same time as Ms. Ballman?
You must have felt like an exceptionally fertile man?
Later in the pregnancy did you visit Ms. Ballman at her mother’s home?
Did you offer to take her shopping and buy things for the baby?
Did you have Ms. Ballman meet with you and your lawyer and together discuss the fact that “there are only so many slices of the pie”?
Did you ask either Ms. Ballman or your wife to consider an abortion?
Can you swim, Mr. Hecht?
I’m just wondering if at some point during all this you felt like you were going under. Drowning.
When was the last time you saw Ms. Ballman pregnant? What month was that?
How did you hear about the birth of your child with Ms. Ballman?
Were you ever asked to sign any legal documents relating to the child?
How long did your relationship with Ms. Ballman last?
Did Ms. Ballman ever marry?
Are you proud of your daughter, Mr. Hecht?
Are you proud of Ms. Homes?
Have you read her work?
Did you ask your daughter to meet you in hotels?
Why not coffee shops?
What is the nature of your thoughts about your daughter?
Did your wife know when and where you were meeting your daughter?
If you had been meeting one of your other children, would she have known?
Are you circumcised?
Is this common knowledge?
Does your other daughter know?
Why was this information that you shared with Ms. Homes?
How did your other children find out that they had a sister?
And what was their reaction to discovering that information?
Do you think of yourself as a good father?
Let’s backtrack a little bit…
In May of 1993 you read a review of Ms. Homes’s book in the Washington Post and called her in New York City?
What prompted you to call her on that day?
If Ms. Homes were not a successful, well-known figure, would you have ever called her?
You made a plan to meet in Washington several days later?
Was anyone else at the meeting? Was the meeting taped or otherwise recorded or monitored by anyone?
What was your reaction to meeting Ms. Homes?
When you met her, were you surprised by the degree to which she looks like you?
Does she look more like you than your other children?
Despite the physical similarity at that meeting, you asked Ms. Homes if she would consent to a paternity test — saying that you had no question as to the likelihood that she was your child, but that your wife was insisting, and that you would need that in order to be able to take her into your family. Is that correct?
What made you question Ms. Homes’s paternity?
After the blood was drawn, as you were walking out with Ms. Homes you told her you had something you wanted to give her — and yet you didn’t give her anything?
What did you want to give her?
Was it something of your mother’s? A family heirloom?
Several months later, you phoned Ms. Homes to say you had the results of the test, and you asked Ms. Homes to once again meet you in a hotel in Maryland?
At that meeting you told Ms. Homes that you were in fact her father — that the DNA test said it was 99.9 percent likely — and you asked, “What are my responsibilities?”
What did you envision as your responsibilities?
What were your intentions toward Ms. Homes when you asked her to submit to the test?
Did you follow through by “taking her into your family”?
Before you discussed the results with Ms. Homes, did you discuss them with anyone else?
Did you discuss them with your wife?
Why did you not offer Ms. Homes a copy of the test result?
What did you do with the test result?
When did you give a copy to your lawyer?
Did you keep a copy for yourself?
Do you typically give the one and only copy of an important document to your attorney?
Did you not put it in your safe deposit box because you didn’t want your wife to discover it?
But didn’t you tell Ms. Homes that it was your wife who insisted on Ms. Homes’s having the paternity test before you could “take her into your family”?
Was the reason your wife wanted Ms. Homes to have the DNA test that you had portrayed Ms. Ballman to your wife as a floozy to make it seem like you were Ms. Ballman’s victim?
You arranged for your eldest son to meet Ms. Homes?
How did that meeting go?
Was your son happy to have more information about something that had only been a dim memory from his childhood — the time he spent with Ms. Ballman?
Was there a lot of tension in your home when your eldest son was a boy?
What was the occasion of your wife meeting Ms. Homes?
Is there a reason why your wife wouldn’t like Ms. Homes?
Why did you say to Ms. Homes later that she and your wife didn’t hit it off?
Did Ms. Homes ever ask you for anything?
Do you have concerns about Ms. Homes making a claim on your estate?
Did she ever in any way indicate that she had any interest in your estate?
Did you have her take the paternity test in order that you might by name exclude her from your estate?
When did you last speak to Ms. Ballman?
And what was the substance of that call?
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