Marvin Threatt

Witness for the Defendant:  Penalty Phase

December 6, 2004

Direct Examination by Mark Geragos

GERAGOS: Call you Doctor Threatt, because you have a PhD in education, correct?

THREATT: Yes.

GERAGOS: And can you tell me a little bit about your background?

THREATT: Born in Birmingham, Alabama. I joined the Navy at eighteen years old and spent 22 years in the Navy. I'm a Vietnam veteran. I left the military, and I became, I began teaching. I finally retired from teaching.

GERAGOS: During the course of your career, at some point were you located down in San Diego, and head of, Dean of Students for a particular school?

THREATT: From 1985 to 1992 I was Dean of Students at the University of San Diego High School. That's where I knew Scott.

GERAGOS: What did, as Dean of Students, what is your job?

THREATT: My job as Dean of Students was to keep order and discipline on the campus. The school was approximately 1500 students. My job was to make sure that everyone did what they were supposed to do.

GERAGOS: And you didn't teach at the school. You were basically in charge of law and order, is that correct?

THREATT: I taught for one semester, and they made me Vice Principal after the first semester, so I only taught very briefly.

GERAGOS: Scott was a student when you were there?

THREATT: Yes.

GERAGOS: And you left shortly after he graduated, is that correct?

THREATT: I left in 1992, yes.

GERAGOS: During the three years that he attended high school, you were the Dean of Students, is that correct?

THREATT: Yes.

GERAGOS: You remember him from when he was there?

THREATT: I remember him in passing. As Dean of Students, did not necessarily come to me to talk, to have coffee with me. But my job was to stand in the middle of the school to make sure everyone knew that I was there. In that process I saw him passing many times. I saw hum frequently during the school year, yes.

GERAGOS: If he had been in trouble or a troublemaker, things like that, would it have been more likely that you would have encountered him?

THREATT: That is the most significant thing. The fact is, during his junior year, I don't remember him at all. In his senior year, I do remember him quite well. If there had been any problems, he would have been in my office. The factor that I can say most significant, the whole time that I was there, he was never in my office for any disciplinary purposes.

GERAGOS: You know a nun by the name of Sister Joan?

THREATT: Yes. She was in charge of the Christian Service Project there.

GERAGOS: Okay. And as part of that Christian Service Project, did that entail going to work at orphanages in Tijuana?

THREATT: Exactly.

GERAGOS: Things like Habitat for Humanity and such kind of charitable endeavors?

THREATT: Exactly.

GERAGOS: In talking with you, you are aware that Scott participated in those activities?

THREATT: Yes. I knew at the school we gave the students time to go to do the Christian service during the school day. It was significant that in that time many students would not come back to school on time. They would leave at maybe 10:00 o'clock in the morning and required to be back at 1:00 o'clock. Many students would come back late. But the things I recall mostly about Scott is that he did always come back on time. He was never late. He was punctual. He was reliable. He was responsible, yes.

GERAGOS: Would that would require at that point high schoolers actually crossing the border to go over to Mexico?

THREATT: Actually went into Tijuana. And they would spend maybe four or five hours there. In addition to that, Scott not only worked with the orphanage in Tijuana, he worked locally with the mental retarded in the beach communities in San Diego on his own time beyond the allotted hours in Tijuana.

GERAGOS: Is that a home or a residential area for the,

THREATT: Mental retarded. I think they were young children who needed help. And I think that as Scott, on the weekends, would spend time helping them after he had finished his school work and done his Christian service hours in Tijuana. To graduate from the school, every student was required to do 100 hours of Christian service. So he did his Christian service hours in Tijuana. And he would do his own volunteering outside of there in San Diego.

GERAGOS: Is that one of the reasons that you do have a memory of him?

THREATT: Yes.

GERAGOS: Did you, during the time that you were there, was Sister Joan, the nun, particularly close with Scott that you are aware of?

THREATT: Exactly. I think that he worked very closely in the Christian Service Project. And she was director of the project, the Christian Service Program, as well as the athletic program. The attendance programs were supervised under my office. That's why I knew her and knew of him. Sister Joan knew him quite well, because she saw him in that capacity more readily than anyone else, I think.

GERAGOS: Was the other person that you could say that he was closest to, you mentioned that you supervised, I guess you kind of held the title of Athletic Director?

THREATT: Yes.

GERAGOS: The other person that spent the most time with him, at least in authority figure, would have been David Thoennes?

THREATT: His coach, golf coach, yes.

GERAGOS: Thank you. I have no further questions.