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Deposition of Cardinal Roger Mahony (continued)
November 23, 2004

[Note: This is Part 2 of a two-part HTML version of the Mahony deposition [see also Part 1] that BishopAccountability.org created from a Word document included with Cardinal Untruths: Mahony's Testimony in Sex Scandal Clashes with Earlier Statements and Reality, by Jeffrey Anderson, LA Weekly (12/15/04). See also Mahony in '80s Banned Two Priests: Deposition Reveals He Ousted Pair Accused of Molestation from U.S. While He Was Stockton Bishop, by Jean Guccione, LA Times (12/10/04); and Cardinal Mahony Accused of Perjury in Sex Abuse Case, by Don Lattin, San Francisco Chronicle (12/11/04). In his article, Anderson also provided four of the deposition exhibits: 2, 3, 4, and 8. For easier reading, we have formatted the list of exhibits and the list of questions that Mahony was instructed by his lawyer not to answer. We've displayed the page numbers in blue and adjusted the spacing, but otherwise this is the text of the deposition that accompanied Anderson's article.]

0122
  1            THE WITNESS: I'm not sure if the victims ever
  2   did go to the police. So I'm not sure whether our
  3   diocese attorney or myself was the first one who
  4   actually made that initial contact.
  5   BY MR. MANLY:
  6       Q. Was it your policy or practice or custom or
  7   or view that the appropriate thing to do if you found a
  8   priest violated the law in in the manner of sexually
  9   molesting a child, that the appropriate thing to do as
10   a first step is to report him to the police, prior to
11   1985?
12            MR. WOODS: First of all, I object that the
13   question is compound and that it asks custom and
14   practice, right thing to do, and half a dozen other
15   adjectives, all of which are separate issues.
16            MR. MANLY: All for let me try it again.
17       Q. Did you have a policy, a personal policy, that
18   employees in your diocese who molested children would
19   be reported to the police as a first step if you
20   believe the allegations to be true?
21       A. I don't think at that time we had a specific
22   policy.
23       Q. Was that your view prior to 1985?
24            MR. WOODS: Under any circumstances?
25            MR. MANLY: No.

0123
  1       Q. When you believed that priests had molested a
  2   child?
  3            MR. WOODS: Okay. That's more specific.
  4            THE WITNESS: If I recall, it was in 1984 that
  5   the mandated reporting laws of California began. And
  6   it was from that point on that a number of people
  7   became mandated reporters. So we were all more
  8   sensitive to that.
  9   BY MR. MANLY:
10       Q. Okay. Well, my question's a little different.
11   I'm not I'm really not asking a legal question.
12            What I'm asking you is I'm trying to find
13   you, Roger Mahony's, view as a supervisor of people who
14   had regular contact with people, educators, teachers,
15   kindergarten teachers, priests who taught CCD, if you
16   found out one of your employees, lay, religious, or
17   priest, had molested a child, and you believed they
18   molested a child, was it your view prior to 1985 that
19   the first thing you should do is call the police?
20            MR. WOODS: Object to the form of the question
21   asking for a policy. He hasn't established you
22   haven't established that he had a set policy to do
23   anything. So since your question assumes a policy,
24   which to me means a preestablished course of action as
25   opposed to a case by case approach, I object.

0124
  1            MR. MANLY: Are you going to object or are you
  2   just going to talk?
  3            MR. WOODS: I object. And I'll instruct him
  4   not to answer.
  5   BY MR. MANLY:
  6       Q. Do you think you should have if you found
  7   out, Eminence, that a priest had molested a child, and
  8   you believed it, you thought the right thing to do was
  9   to call the cops, right, prior to 1985?
10       A. That somebody should report this matter to the
11   police, correct.
12       Q. You you directed your staff and they
13   understood, because you wanted to protect kids, that
14   what they should do if that person molested a child is
15   you do exactly what you did with Father Munoz, which is
16   to call the police; right?
17       A. Yes.
18       Q. Okay. At any point prior to 1985 had, that
19   strike that. Move on.
20            Did you ever learn that there was any policy,
21   instruction, or document issued by the Vatican that
22   required you to keep sexual misconduct of priests
23   secret?
24       A. No.
25       Q. Have you ever seen such a document?

0125
  1       A. Not specifically, no.
  2       Q. How about generally, have you seen such a
  3   document?
  4       A. No.
  5       Q. Eminence, when did the California Catholic
  6   Conference come into existence?
  7       A. I'm sorry. I don't remember exactly when.
  8       Q. Do you remember what decade?
  9       A. I know it was in existence in the 1970s, but
10   exactly when it began, I just can't recall.
11       Q. Since the 1970s, have there been annual
12   meetings of the Bishops of California?
13       A. Up until '70 to '75, I don't know, because I
14   wasn't a Bishop. So I don't know whether they met or
15   didn't meet.
16       Q. After 1975, did you go to annual meetings of
17   California Bishops?
18       A. I believe by 1975 we were meeting annually.
19       Q. When is the first time you recall California
20   Bishops discussing the issue of the sexual abuse or
21   molestation of children by priests or religious?
22       A. Well, during our time frame here, which is
23   Fresno and Stockton, I do not recall that topic being
24   discussed.
25       Q. Did somebody keep minutes of those meetings?

0126
  1       A. In the early days, I'm simply not certain.
  2   Later on, when there was a full time executive
  3   director, minutes were kept.
  4       Q. Was there any policy or procedure or rule
  5   against priests molesting children while you were a
  6   priest of the Diocese of Monterey Fresno?
  7       A. Yes. It's called the Law of God.
  8       Q. Was there any specific policy in canon law or
  9   otherwise that you knew about that that existed
10   during those years?
11            MR. WOODS: You mean other than, like, the Ten
12   Commandments, stuff like that?
13            MR. MANLY: You know, if we'd follow the
14   ten Commandments in this case, we'd probably be a lot
15   better off. But no, I don't mean the Ten Commandments.
16            MR. WOODS: Are you talking about a
17   specific it's so vague.
18   BY MR. MANLY:
19       Q. I'm talking about a policy, procedure,
20   anything like that, that you knew existed while you
21   were a priest in the Diocese of Fresno Monterey.
22       A. Between 1962 and 1967?
23       Q. Yes, Eminence.
24       A. Other than we discussed this morning, that is
25   what it says in canon law.

0127
  1       Q. Okay. So the policy between those year was
  2   canon law; is that right?
  3       A. Yes.
  4       Q. Okay. Is there all right.
  5            When you became a priest of the Diocese of
  6   Fresno up until the time you left, what was the policy
  7   and procedure with regard to the sexual abuse of
  8   children, if any, for the Diocese of Fresno?
  9       A. If you recall this morning, I testified that
10   we did not have any actual specific written policies or
11   procedures.
12       Q. Okay. Were there any rules, regulations,
13   instructions, canon law, or otherwise that dealt with
14   the sexual molestation of children by priests during
15   the years you were at Fresno?
16       A. I'm sorry. Could you give me the list again?
17   He was moving things behind you there.
18            MR. MANLY: Sure. Why don't you read it back.
19            THE WITNESS: I got distracted.
20            (The record was read as follows:
21            "Were there any rules, regulations,
22            instructions, canon law, or otherwise
23            that dealt with the sexual molestation
24            of children by priests during the years
25            you were at Fresno?")

0128
  1            THE WITNESS: If I understand the four nouns
  2   you used, I think canon law would probably be the
  3   the accurate one.
  4   BY MR. MANLY:
  5       Q. So canon law was the only thing you had?
  6       A. To the best of my recollection, yes.
  7       Q. And in Fresno, who was in charge of enforcing
  8   the canonical law on that issue?
  9            MR. WOODS: I'm going to object to the
10   question as assumes there's some prosecutor or
11   enforcement agent
12            MR. MANLY: Yeah, it's called the Promoter of
13   Justice.
14   BY MR. MANLY:
15       Q. There is; right?
16            MR. WOODS: I'm going to object and instruct
17   him not answer.
18   BY MR. MANLY:
19       Q. Is the Promoter of Justice in charge of
20   enforcing the canon law?
21       A. Yes.
22       Q. Okay. Thank you.
23            All right. Who was the Promoter of Justice
24   when you were there, do you remember, Eminence, sir, or
25   do we have to go to the Catholic Directory?

0129
  1       A. I simply don't know.
  2       Q. Who was the Promoter of Justice in Stockton
  3   when you were there, Eminence?
  4       A. I don't recall, because we had several
  5   canonist priests, and I honestly don't remember which
  6   one was Promoter of Justice.
  7       Q. If the office of Promoter of Justice was
  8   vacant, who was in charge of enforcing the canon law as
  9   to priests violating children?
10            MR. WOODS: Is this an expert opinion on his
11   understanding of the canon law or how it was actually
12   done when he was the Bishop?
13            MR. MANLY: I want to know, actually, how it
14   was done when he was the Bishop.
15            MR. WOODS: Okay.
16   BY MR. MANLY:
17       Q. You can answer the question, Your Eminence.
18       A. Well, if there was not an incumbent Promoter
19   of Justice and there was a case that needed the
20   appointment, then the Bishop could simply appoint
21   someone ad hoc for that case to be the Promoter of
22   Justice.
23       Q. Did the policies you enforced in Stockton
24   prior to the Collegeville meeting differ in any way 25   let me let me strike that.

0130
  1            Did the way you handled or were supposed to
  2   handle strike that.
  3            When you handled the Munoz case and the
  4   Camacho case, did you use canon law in any way in those
  5   cases?
  6       A. Yes.
  7       Q. Okay. How did you use it?
  8       A. I exercised my prerogative as the Bishop to
  9   terminate their faculties and their assignment.
10       Q. Okay. And you had that absolute right;
11   correct?
12       A. Yes.
13       Q. And you had the right you have the right to
14   suspend the faculties of any priest serving in your
15   diocese; correct?
16       A. Yes.
17       Q. And you have the right, prior to 1985, as the
18   Bishop of Stockton, to remove any priest serving in
19   your diocese, whether they're religious, diocesan,
20   extern, or otherwise from ministry; correct?
21       A. Well, with cause.
22       Q. Well, molesting kids is cause; fair?
23            MR. WOODS: And "from ministry," you mean from
24   ministry in his diocese?
25            MR. MANLY: That's right. Okay.

0131
  1       Q. Right?
  2       A. Yes, from ministry in the diocese of Stockton,
  3   correct.
  4       Q. Okay. Can you could you have removed
  5   Father O'Grady because he had urges towards young
  6   people, if that had come to your attention?
  7       A. No, that was not the the course of action
  8   that would have been taken at that time.
  9       Q. My question's a little different than that.
10            If if it had come to your attention that
11   Father O'Grady told a your Vicar General that he had
12   sexual urges towards a 9 year old or a 10 year old or
13   an 11 year old, is that cause to remove him from
14   ministry?
15       A. No.
16       Q. Okay.
17            MR. MANLY: Why don't we take a break.
18            THE VIDEOGRAPHER: We're off the record. Time
19   is 1:22.
20               (A brief recess was taken.)
21            THE VIDEOGRAPHER: We're back on the record.
22   The time is 1:36.
23   BY MR. MANLY:
24       Q. Eminence, do you remember testifying in a
25   civil trial in 1998, involving Father O'Grady?

0132
  1       A. Yes.
  2       Q. Did you testify truthfully in that case?
  3       A. Yes.
  4       Q. Let me show you a document that's two pages.
  5   I'm going to represent it's from your trial testimony,
  6   page 792 and 793. And I'd like you to begin at line
  7   22, and then continuing.
  8            MR. MANLY: If you want me, Counsel, I'll mark
  9   where I want him to start.
10            MR. WOODS: Yeah, but we're going to have the
11   context before and after that in order to have an
12   understanding.
13            MS. SOLTAN: We brought the entire deposition
14   transcript if you'd like to look at it.
15            MR. WOODS: Yeah, I'd like to see it.
16            MR. HENNIGAN: I'm sorry. Is this trial
17   transcript that he said?
18            MR. MANLY: Trial transcript.
19            MS. SOLTAN: I'm sorry. That's what I meant
20   to say. I misspoke.
21            MR. WOODS: I'd like an opportunity to read a
22   little bit of before and after, just to make sure we're
23   in context.
24            MS. SOLTAN: We would never misrepresent the
25   status.

0133
  1   BY MR. MANLY:
  2       Q. Would you look at 792 and 793, beginning at
  3   line 22.
  4            MR. HENNIGAN: Do you have a copy for us?
  5            MR. MANLY: I just gave you one.
  6            MR. HENNIGAN: You did?
  7            MR. WOODS: So this is his full testimony?
  8            MS. SOLTAN: That is his full testimony. And
  9   we're referring with to page 792 and 793 is that
10   correct, John?
11            MR. MANLY: Yes.
12            MS. SOLTAN: of the transcript.
13            MR. WOODS: Do you have an extra copy of this?
14            MS. SOLTAN: Of the two pages?
15            MR. WOODS: Yeah.
16            MS. SOLTAN: Yes, I'm sure I can get that for
17   you.
18            MR. WOODS: I'm going to read it first, and
19   then I'll give it to you.
20            MS. SOLTAN: I'm sorry. Mr. Hennigan, were
21   you the person who asked me for another couple of pages
22   or...
23            MR. WOODS: I I need them.
24            MS. SOLTAN: That was you?
25            MR. WOODS: We'll I'll give this one to the

0134
  1   witness so he can read it. I'm reading it
  2            MS. SOLTAN: Oh, all right. Tell me when
  3   you're ready, so you have one.
  4            MR. WOODS: Well, give it to me. I'll give
  5   him he can start reading.
  6            MS. SOLTAN: That's a good idea.
  7            MR. WOODS: Just trying to save time.
  8            MS. SOLTAN: I'm so glad you're here.
  9            MR. WOODS: Start up here (indicating) and
10   read down and get the flow.
11             Okay. Do you want to mark these pages as an
12   exhibit?
13            MR. MANLY: Yeah, next in order.
14               (Plaintiffs' Exhibits 7 and 8 were
15                marked for identification.)
16   BY MR. MANLY:
17       Q. Cardinal, beginning at line 22 on page 792,
18   can you read the testimony into the record, please?
19            MR. WOODS: The highlighted testimony?
20            MR. MANLY: Well, I don't think it's I

21   don't know if it's
22            I can't see if it's highlighted on his page,
23   but it begins at line 22, beginning, question, "Was
24   during a period of time."
25            THE WITNESS: Who is Q?

0135
  1   BY MR. MANLY:
  2       Q. That's Mr. Diepenbrock, the diocese attorney.
  3       A. Question
  4       Q. He's also a character in James Bond, but we'll
  5   save you the go ahead.
  6       A. "Was during a period of time you
  7            were the Bishop of Stockton, were there
  8            any other priests that were involved in
  9            any kind of sexual misconduct with children?
10                "Mr. Drivon: Your honor, that calls
11            for speculation.
12                "The Court: If the witness has
13            personal knowledge, he can answer. But
14            I will ask you not to speculate, Cardinal.
15                "The Witness: Again, during my
16            period of time, I cannot recall another
17            Case.
18                "Mr. Diepenbrock: Question: Well,
19            if there had been any other cases
20            when you were the Bishop of Stockton,
21            you certainly would have heard about it,
22          wouldn't you?
23                "Answer: "Oh, yes. But I can't
24            recall another case.
25                "Question: "Were there any other

0136
  1            cases.
  2                "Answer: Not that I know of.
  3                "Question: This was the only one?
  4                "Answer: Yes."
  5   BY MR. MANLY:
  6       Q. Okay. And you gave that testimony on June
  7   12th, '98, Your Eminence?
  8       A. Yes.
  9       Q. Okay. And is that testimony truthful?
10       A. Yes.
11       Q. You don't mention Father Camacho or
12   Father Munoz, do you?
13       A. I do not.
14       Q. But Father Camacho and Father Munoz molested
15   children while you were the Bishop of Stockton;
16   correct?
17       A. Yes.
18       Q. Do you have an explanation for that?
19       A. This trial was some 13 years after I had left
20   the Diocese of Stockton. We had many events in the
21   Archdiocese of Los Angeles, and I was very preoccupied.
22   We had the visit of the Holy Father. We had the
23   earthquakes. We had riots. We had everything. And I
24   simply did not remember everything that happened many
25   years ago in Stockton.

0137
  1       Q. So your testimony is you forgot that
  2   Father Camacho and Father Munoz molested children while
  3   you were the Bishop; is that accurate?
  4       A. That is accurate.
  5       Q. Okay. Do you remember testifying about this
  6   issue in your deposition in that case?
  7       A. The deposition prior to the trial?
  8       Q. Yes. Yes, sir, about a year before.
  9       A. I actually don't recall.
10       Q. Do you know if that question was asked in your
11   deposition?
12       A. Again, I don't recall whether it was or not.
13       Q. Were you you were not attempting to mislead
14   the jury; is that right?
15       A. On the contrary.
16       Q. So you forgot about your the police
17   investigation of your priests, Father Camacho and
18   Father Munoz; is that your testimony?
19       A. I had forgotten about those incidents.
20       Q. Okay. Prior to was Vicar General Cain in
21   the courtroom when you testified?
22       A. I don't recall.
23       Q. Did at any point Vicar General Cain come to
24   you and remind you that this was incorrect?
25       A. No.

0138
  1       Q. When did you first remember that Camacho and
  2   Munoz cases?
  3       A. I don't recall exactly. But at some point I
  4   was given all the files involving those three priests.
  5       Q. Are there any other priests you've forgotten
  6   about, you think, or just those two?
  7       A. Just those two.
  8       Q. Eminence, do you remember in Fresno, a priest
  9   molesting mentally ill people?
10            MR. WOODS: Before 1985?
11            MR. MANLY: Yeah.
12            THE WITNESS: There was a case, but I don't
13   recall the time frame.
14   BY MR. MANLY:
15       Q. Do you remember a priest molesting mentally
16   ill people when you were the Bishop of Fresno I'm
17   sorry, when you were the Auxiliary Bishop in Fresno?
18       A. I don't recall the time period when that
19   actually occurred.
20       Q. Do you recall at any point becoming aware of a
21   priest sexually exploiting mentally ill people in
22   Fresno?
23       A. I remember at some point.
24       Q. Okay. When did you learn that?
25       A. I honestly don't recall.

0139
  1       Q. Do you remember what decade?
  2            MR. WOODS: I'm sorry?
  3   BY MR. MANLY:
  4       Q. Do you remember what decade?
  5       A. No, I don't.
  6       Q. Okay. Let me read to you a portion of your
  7   deposition testimony in 1978. I'd be happy to show it
  8   to you after I read it.
  9       A. Excuse me. What year?
10       Q. I'm, sorry 1980 1997?
11            MR. WOODS: Can we have the transcript?
12            MR. MANLY: Yeah. I'll show it to you when
13   I'm done.
14            THE WITNESS: Excuse me. 1997?
15            MR. MANLY: Yes, Eminence.
16            MR. WOODS: This is the transcript in the?
17   BY MR. MANLY:
18       Q. In the Howard case.
19            Beginning at page 73, line 1:
20            "Okay. And you knew Father O'Grady
21            was a priest of the diocese over whom
22            you had control, at least as it pertains
23            to his faculties and assignments?
24                "Answer: "Yes.
25                "And if you had known he

0140
  1            admitted to having criminal sexual
  2            contact with a 9 year old boy, you
  3            would have not placed him in the parish
  4            at St. Andrews?
  5                "Answer: Had I known all of what's
  6            in this report, I probably would have
  7            taken him out of any assignment and
  8            sent him off for a full evaluation
  9            and some determination to be made.
10            He would never have been transferred,
11          especially to a place where the pastor
12            who was there, wasn't there sometimes and
13            not sometimes, never, never, never
14            done it."
15            Okay. Do you want to see the testimony?
16            MS. SOLTAN: What page is that?
17            MR. MANLY: 73 and 74.
18            MR. WOODS: We'll wait for the question, and
19   we may need to see the rest.
20   BY MR. MANLY:
21       Q. My question is do you remember giving that
22   testimony?
23       A. Yes, I do.
24       Q. My question is: Where would you have sent him
25   off to treatment to if you didn't know treatment

0141
  1   existed?
  2       A. Well, at this time, I probably would have
  3   consulted with the Bishops' conference to find a place.
  4   There were a number of psychological places in
  5   California that dealt with psychological problems, in
  6   the Bay area.
  7       Q. What was he going to be treated for?
  8       A. I believe to be evaluated.
  9       Q. Well, you said, "Send him off for a full
10   evaluation." Okay?
11            What was he going to be evaluated for?
12       A. He would be evaluated for whatever the
13   allegation was.
14       Q. Okay. Let me show you a document, Eminence.
15   I'll show you the Latin version and the English
16   translation.
17            MR. WOODS: Are you going to mark them?
18            MR. MANLY: Yeah. We'll mark them as
19            MS. SOLTAN: Are we at 9 and 10?
20            MR. MANLY: Why don't we mark them as 9 and
21   10.
22            MR. WOODS: Go ahead and mark them so when
23   they arrive here, they're marked. Because we're losing
24   stuff left and right.
25            MS. SOLTAN: Exhibit 9 is going to be the

0142
  1   Latin version, and Exhibit 10 is going to be the
  2   translation. This is the 1962 document. Is that what
  3   we're calling this?
  4            MR. MANLY: Yeah.
  5            MS. SOLTAN: The 1962
  6            MR. MANLY: 1962 instruction.
  7               (Plaintiffs' Exhibits 9 and 10 were
  8               marked for identification.)
  9            MS. SOLTAN: Here you go, Cardinal.
10   BY MR. MANLY:
11       Q. Have you ever seen that document before,
12   Your Eminence?
13            MR. WOODS: Do you have a copy for me?
14            MS. SOLTAN: I beg your pardon?
15            MR. WOODS: Copy for me?
16            MR. MANLY: Oh, I'm sorry.
17            MS. SOLTAN: It's in reverse order. The Latin
18   is at the back.
19            MR. WOODS: Okay. So the English is 10, and
20   the Latin is 9.
21            And your representation is that one is the
22   correct translation of the other?
23            MR. MANLY: Right.
24            MR. WOODS: And who translated 10?
25            MS. SOLTAN: I think the document reflects it.

0143
  1            MR. WOODS: I'm sorry. The document what?
  2            MS. SOLTAN: I think the document reflects the
  3   name of the translator and what it is a translation of.
  4            MR. WOODS: Can you show that to me?
  5            MS. SOLTAN: You might look at the very end,
  6   where it's indicated. No. Is that is that wrong?
  7   Is that the author? I'm sorry. I misspoke.
  8            MR. MANLY: I'll represent to you that's an
  9   accurate translation. You can take issue with it if
10   you want to.
11            MR. WOODS: Is this the Doyle translation?

12            MR. MANLY: I'll represent it's an accurate
13   translation.
14       Q. Have you ever seen anything like that
15   document, Your Eminence?
16            MR. HENNIGAN: What would be the basis upon
17   which you represent it's an accurate translation?
18            MR. MANLY: That it's been examined by a Latin
19   scholar, and I've been told it's an accurate
20   translation.
21            MS. SOLTAN: You can reserve all rights,
22   Counsel. We have no problem. If you find that it
23   isn't an accurate translation, you can certainly do
24   whatever you think is appropriate.
25            MR. WOODS: I just want to identify a source.

0144
  1   This is the Doyle translation of the 1962 instruction?
  2            MR. MANLY: No, I'm not saying that.
  3            MR. HENNIGAN: Is it not that, or is it
  4            MR. MANLY: I don't I don't know that it's
  5   him. I know it's a Latin scholar.
  6            MR. WOODS: Okay. Well, it looks very
  7   similar. And I don't proclaim
  8            MR. MANLY: Maybe it is and maybe it isn't. I
  9   don't know.
10            MR. WOODS: that I can go through 50 pages
11   and tell you. But it looks very similar to one that he
12   made. Now, it may just be the format is the same. I
13   can't tell for sure.
14            MS. SOLTAN: Well, if you prefer, the Cardinal
15   perhaps could translate paragraph 73 from the Latin to
16   English for us on the record. Would you prefer that?
17            MR. MANLY: Why don't you do that, Cardinal?
18            MR. WOODS: I'm not sure that the Cardinal is
19   qualified to translate; although I'm sure he knows
20   quite a bit of Latin.
21   BY MR. MANLY:
22       Q. Have you ever all I'm trying to
23   establish I'm not going to ask you about the
24   document yet.
25            Have you ever seen anything like that before?

0145
  1       A. Yes.
  2       Q. When did you see it for the first time?
  3       A. I believe in the last year or so this document
  4   came to my attention.
  5       Q. Okay. So your testimony is your sworn
  6   testimony is you've never seen anything like that
  7   document, that instruction, prior to 2003?
  8            MR. WOODS: I object to the vague expression,
  9   "something like that." I mean, this is the
10   BY MR. MANLY:
11       Q. Did you ever see that instruction before 2003,
12   Your Eminence?
13            MR. WOODS: This particular one, crimine
14   sollictationis?
15            MR. MANLY: That's right.
16            MR. WOODS: Have you seen this one before?
17            MR. MANLY: That's right.
18            MR. WOODS: Okay.
19            THE WITNESS: I simply don't recall seeing
20   this ever before.
21   BY MR. MANLY:
22       Q. Okay. Do you know what it says about
23   pedophilia, Eminence?
24       A. No, not specifically.
25            MS. SOLTAN: Page 22.

0146
  1            MR. WOODS: Page 22 of the translation,
  2   Exhibit 10? The pages aren't numbered.
  3            MS. SOLTAN: Actually, if you go to the very
  4   end of the translated document, it's the last two full
  5   pages of the document, starting with what is entitled
  6   "Title IV," in Roman numerals, and "Title V." And
  7   under the section entitled "The Worst Crime" is the
  8   section that we're talking about.
  9            MR. HENNIGAN: And where is that? Is there a
10   numbered paragraph?
11            MS. SOLTAN: The second second to the last
12   page of the document in English, before the appendix.
13            MR. WOODS: Before the appendix.
14            MR. HENNIGAN: Is there a paragraph number?
15            MS. SOLTAN: Paragraph 71, 72, 73 is what
16   we're directing inviting your attention to.
17            MR. WOODS: Paragraph 71.
18            MS. SOLTAN: Would you like me to find it for
19   you?
20            MR. WOODS: Yeah. Oh, page 22 at the top.
21   Okay. The Cardinal's got it.
22            MS. SOLTAN: Here you are.
23            Can I find it for you?

24            MR. HENNIGAN: I found it.
25            MS. SOLTAN: Cardinal, may I assist you?

0147
  1            THE WITNESS: Okay. You're looking at
  2   paragraph 73?
  3   BY MR. MANLY:
  4       Q. Yes.
  5            MR. WOODS: So we should just look at 73?
  6            MR. MANLY: Right.
  7            MS. SOLTAN: No. It's
  8            MR. MANLY: 66.
  9            MR. WOODS: 66?
10            MR. MANLY: No. 66.
11            MR. WOODS: 66.
12            MR. MANLY: Right.
13       Q. "Whenever an Ordinary immediately accepts
14       a denunciation of the crime of solicitation,
15       he should not omit telling this to the Holy
16       Office."
17            Do you see that?
18       A. Yes.
19       Q. Prior to 1985, did you ever report a priest to
20   the Holy Office of the Vatican for abusing a child?
21       A. Well, that's a different question than
22   paragraph 66.
23       Q. My question stands.
24            Did you?
25       A. No.

0148
  1            MR. HENNIGAN: No, you don't get to do that.
  2   You don't get to throw in paragraph 66
  3            MR. MANLY: Did you
  4            MR. HENNIGAN: and act like
  5            MR. MANLY: Okay. Fine.
  6       Q. Forget paragraph 66 exists.
  7            Did you ever report to the Holy Office or to
  8   any official of the Vatican, prior to 1985, that a
  9   priest had molested a child?
10       A. Aside from this document?
11       Q. Right.
12       A. No, not to the best my recollection.
13       Q. Okay. Can you read paragraph 73 into the
14   record?
15            MR. HENNIGAN: Look, without knowing what this
16   document is, if you want it read into the record, you
17   read it.
18            MR. MANLY: Okay. I'll read it into the
19   record.
20            "To have the worst crime, for the penal
21       effects, one must do the equivalent of the
22       following: Any obscene, external act,
23       gravely sinful, perpetrated in any way by a
24       cleric or attempted by him with youths of
25       either sex with brute animals (bestiality )."

0149
  1            MR. WOODS: "Or with brute animals."
  2   BY MR. MANLY:
  3       Q. Have you ever seen that before, Eminence?
  4            MR. WOODS: Have you seen this?
  5            MR. MANLY: That paragraph.
  6            MR. WOODS: In this document?
  7            MR. MANLY: Right.
  8            THE WITNESS: I'm not sure which translation I
  9   had seen before. I had seen this document in in
10   Latin, and I think maybe a translation. I'm not sure I
11   have seen this translation of it.
12   BY MR. MANLY:
13       Q. Did you know prior to 1985 that that
14   instruction existed on that issue?
15       A. No, I did not.
16       Q. Okay. Let me show you a document and
17   paragraph 70, let me read that into the record.
18            "All these official communications shall
19       always be made under the secret of the Holy
20       Office. And since they concern the common
21       good of the church to the greatest degree,
22       the precept of doing these things obliges
23       under serious sin (subgravi)," G R A V I.
24            What is the secret of the Holy Office,
25   Your Eminence?

0150
  1       A. Well, if you have to go up to paragraph 66
  2   to understand the context of of those paragraphs.
  3   It all has to do with solicitation and confession.
  4       Q. Do you know if Father O'Grady ever solicited
  5   sex in the confessional?
  6       A. No, I do not.
  7       Q. Prior to 1985, did you ever have occasion to
  8   deal with a priest who solicited sex in the
  9   confessional?
10       A. Prior to 1985, no, I can't recall any case.
11       Q. Let me show you a document entitled "Gravoria
12   Delicta: The Apostolic Letter, M.P." by Brian Edward
13   Ferme.
14            Do you know Dr. Ferme?
15       A. Yes.
16       Q. Okay. Who is he?
17       A. He is a priest, I think from England, who is a
18   canon lawyer.
19       Q. Is he the dean of the canon law school at
20   Catholic University of America?
21       A. I believe presently he is.
22       Q. Okay. Is he an extremist, as far as you know,
23   you know, crazy in any way?
24            MR. WOODS: Object. Instruct the witness not
25   to answer.

0151
  1   BY MR. MANLY:
  2       Q. You said he's a he's a priest in communion
  3   with Rome; correct, as far as you know?
  4       A. As far as I know.
  5       Q. Okay. Have you ever known him to do anything
  6   heretical or or out of the ordinary that would cause
  7   you to to question his competence as a canon lawyer
  8   and a priest?
  9       A. I have so little contact with Father Ferme, I
10   simply couldn't answer your question.
11       Q. Okay. Can you look at Page 368, starting
12   with
13            MR. WOODS: You haven't given it to us yet.
14            MR. MANLY: I will.
15       Q. starting with, "We do Know"?
16            MR. WOODS: Is this Exhibit 11 now?
17            MR. MANLY: Yes.
18            THE WITNESS: So this is not these other
19   documents now?
20            MR. MANLY: That is a new exhibit, right.
21            MR. WOODS: So this what do we have here?
22   Two documents? The first one, "Il Processo," that's
23   Exhibit 11.
24            MR. MANLY: That's that's the journal, and
25   this is an article out of the journal. I don't know

0152
  1   what you've got on the pad there.
  2            MR. WOODS: And the article by Father Doyle is

  3   Exhibit 12?
  4            MR. MANLY: No. That's that's wrong. I
  5   didn't mean to give that to you. I'm sorry.
  6            MR. WOODS: Okay. So Exhibit 11 is a journal
  7   cover and a title page, and then it starts on Page 365
  8   with an article.
  9               (Plaintiffs' Exhibit 11 was marked for
10                identification.)
11            MR. WOODS: Do you want him to read this
12   article?
13            MS. SOLTAN: Page 368, please.
14            MR. WOODS: Page what?
15            MR. MANLY: 368.
16            MS. SOLTAN: 368, last full paragraph.
17            MR. WOODS: 368. Which paragraph?
18            MS. SOLTAN: Last full paragraph.
19            MR. WOODS: We do not know?
20            MR. MANLY: Beginning "We do know."
21            MR. WOODS: Oh, "We do know."
22            MR. MANLY: Right.
23            MR. WOODS: Okay. So you go ahead and read
24   it, and the
25            MR. MANLY: No. I want the Cardinal to read

0153
  1   it.
  2            MR. WOODS: Out loud?
  3            MR. MANLY: Right.
  4            MR. HENNIGAN: No.
  5            MR. MANLY: Why not?
  6            MR. HENNIGAN: It's not his document. You're
  7   not going to put these word in his mouth. If you want
  8   to read them
  9            MR. MANLY: All right.
10            MS. SOLTAN: you read them.
11            MR. MANLY: "We do know that in 1962,
12            the Holy Office issued an instruction,
13          Crimen Sollicitantionis. As the title
14          suggests, these norms specifically
15            concerned the delict of solicitation
16            in order to commit a sin against the
17            sixth commandment on the occasion of
18          confession. The instruction was sent
19            to all the patriarchs, archbishops,
20            Bishops, and other ordinaries and was
21            based on the general norm found in
22            Canon 247, Section 2.
23                "The CDF could directly judge
24            this delict though if the Ordinary
25            judged the case, he had to proceed

0154
  1            according to the instruction and had
  2            to inform the congregation of the result.
  3                "While the instruction dealt
  4            specifically with the solicitation
  5            and the procedural norms to be applied
  6            in judging this crime, the fifth
  7            chapter stated that the same norms
  8            were also be observed for crimen
  9            pessimum, Article 71, which was also
10            understood to included paedophilia."
11            Do you see that, Cardinal?
12            THE WITNESS: Yes. I'm trying to find out the
13   date of this article.
14   BY MR. MANLY:
15       Q. It's 2004, I believe.
16       A. Do you see where that says 2004?
17       Q. 2003.
18            MS. SOLTAN: I have a document with a
19   copyright of 2003, Cardinal.
20            MR. WOODS: 2003?
21            MS. SOLTAN: 2003.
22            THE WITNESS: 2003?
23            MS. SOLTAN: Yes.
24   BY MR. MANLY:
25       Q. So my question to you is: Did you prior to

0155
  1   1985, did you know that this instruction existed for
  2   handling cases of solicitation that involved
  3   pedophilia?
  4       A. I did not.
  5       Q. Did you ever have a Bishop or anybody else
  6   tell you that this instruction existed?
  7       A. No, not except the last year or so.
  8       Q. Do you accept, Eminence, based on this
  9   article, given Mr. Ferme is the head of canon law at
10   Catholic University, that his statement is accurate?
11   Or do you take issue with it?
12            MR. WOODS: Calls for speculation. Calls for
13   an expert opinion. Instruct the witness not to answer.
14   BY MR. MANLY:
15          Q. Let's go back to your deposition in 1997 and
16   let me read to you from Page 89. I'd be happy to show
17   it to you. Actually, take that back, Page 88,
18   beginning at line
19            MR. HENNIGAN: Are we going to see a copy of
20   it?
21            MR. MANLY: Yeah. I'm going to read it,
22   though, so he can hear it.
23            MR. WOODS: Yeah. Is this the Howard trial or
24   depo?
25            MR. MANLY: Deposition.

0156
  1            MR. WOODS: And page?
  2            MR. HENNIGAN: We don't have that.
  3            MR. WOODS: I've got it right here.
  4            Is this the trial?
  5            MR. MANLY: It's no. It's the deposition.
  6            MR. HENNIGAN: We don't have it.
  7            MR. WOODS: We don't have it.
  8            MR. MANLY: Okay. I'd be happy to share it
  9   with you.
10            MR. HENNIGAN: It would be efficient if we
11   could look at it in context.
12            MS. SOLTAN: Is that what I have?
13            MR. MANLY: Yeah. It's the '97
14            MR. WOODS: Oh, this is the deposition?
15            MR. MANLY: Yeah.
16            MR. WOODS: Oh, okay. Okay. I've got it.
17   This is I thought this was the trial.
18   BY MR. MANLY:
19       Q. So go to Page 88.
20            MR. WOODS: Page 88.
21            MR. MANLY: Actually, I think it would be
22   easier just for him to read it into the record.
23            MR. WOODS: No, no. Go ahead.
24            MR. MANLY: No, I'd like him to read it.
25            MR. WOODS: Okay. Where do you want him to

0157
  1   read? From where to read to yourself.
  2            MR. MANLY: Line 24:
  3            "And are you aware there has been a
  4       practice that has at least been noted, where
  5       they were moved because there was interest
  6       to avoid scandal in the church."
  7            And then his answer beginning, "My

  8   understanding."
  9            MR. WOODS: Who is "they"?
10            MR. MANLY: Do you want to start from the
11   prior question? That's fine.
12            Let me know when you're done.
13            MR. WOODS: We're down to 89, line 17. Is
14   that where you want us to stop?
15            MR. MANLY: Yep.
16            MR. WOODS: That's where the highlighting
17   stops.
18            MR. MANLY: That's what I that's what I
19   want him to read.
20       Q. So beginning at line 24, "And are you aware."
21       A. Okay. So we're on Page 88, line which
22   which line do you want me
23       Q. It's it's confusing, because it's the
24   pages
25       A. Two pages are...

0158
  1       Q. Yeah. So beginning at line 24, saying, "And
  2   are you aware there has been a practice that has at
  3   least been noted, where they were moved because"
  4       A. Oh, all right.
  5       Q. Okay.
  6            MR. WOODS: So what's the question?
  7            MR. MANLY: I want him to read it.
  8            MR. WOODS: We're not going to do that.
  9            MR. MANLY: He won't read it into the record,
10   his own testimony?
11            MR. WOODS: You read it.
12            MR. MANLY: Okay.
13            "Are you aware there's been a
14            practice that has at least been
15            noted, where they were moved because
16            there was an interest to avoid
17            scandal in the church.
18                "Answer: My understanding in
19            those earlier years was that church
20          authorities were unaware, really,
21            of the extent of this disease and
22            illness, and as was psychology and
23            psychiatry, actually, and that what
24            we have come to know today has come
25            more through evolution. And it's

0159
  1            like alcoholism among priests, it
  2            was considered to be some kind of
  3            a moral thing; and then if you
  4            decided not to drink, you wouldn't
  5            drink. And so treatment in that,
  6            it was simply not part of the reality
  7            of the time. And so I think it's why
  8          evolution we have come to realize
  9            today what we did not know as clearly
10            in those earlier years.
11                "But my only recollection as
12            a priest, or anyone, since ordination
13          was that we had a case in Fresno
14            when I was there of a priest
15            chaplain at a state hospital of
16            adults, though this was not children,
17            who was accused of molesting some
18            of these they were mentally retarded.
19                "And so we pulled him out
20            immediately and sent him I can't
21            recall where for evaluation.
22            But he was never allowed to serve
23            again, in fact, left the priesthood.
24            In fact, he went to jail eventually,
25            I believe, and left the priesthood.

0160
  1                "But my only recollection of
  2            dealing with one of those cases in
  3            those years is we didn't there
  4            was no tolerance for this.
  5                "Question: Actually, your answer
  6            in part leads me to my next question.
  7            And that is: Before 1984, as in the
  8            capacity of Bishop or Auxiliary Bishop,
  9            had you ever had cause or occasion
10            to deal with the issue of a priest
11            of a diocese being accused of the
12            molestation of a child or parishioner.
13                "Answer: Not of a child, although
14            one could, I believe, say at
15            Porterville State Hospital, whether
16          chronologically older, they are
17            mentally, maybe, children. But that
18            was the only case I was aware of
19            And we pulled him out of there immediately."
20       Q. Did you testify truthfully in that deposition,
21   Cardinal?
22            THE WITNESS: With the knowledge I had at the
23   time, yes.
24            MR. MANLY: I'll turn it over to Mr. Simons.
25            MS. SOLTAN: Actually, I would like to just

0161
  1   follow up with a few things, if I may. Is that all
  2   right?
  3            MR. SIMONS: That's fine with me.
  4            MS. SOLTAN: Apparently, the hardest part of
  5   this is going to be figuring out the microphone.
  6   
  7                      EXAMINATION
  8   BY MS. SOLTAN:
  9       Q. Cardinal, you were at the diocese of
10   Fresno Monterey, which became the diocese of Fresno and
11   Monterey, from 1962 until 1980; correct? I understand
12   that correctly, yes?
13       A. 1962 to 1980, correct.
14       Q. Right. You were incardinated in 1962 and
15   remained incardinated at that diocese until you left to
16   go to Stockton?
17       A. Yes, that would be correct.
18       Q. And during that time period, you held just
19   about every office, didn't you? I mean, you were a
20   pastor and an administrator; that's correct?
21            MR. WOODS: Okay. I'm going to object.
22   There's several questions pending. Which one do you
23   want him to answer?
24            MS. SOLTAN: Well, let me do it this way,
25   because I'm trying to just expedite a little bit.

0162
  1       Q. I understood that you were a pastor, you were
  2   an administrator, you were a Vicar General, were you an
  3   Auxiliary Bishop, you were a Chancellor. Did I did
  4   I hit them all?
  5       A. I think, except for director of
  6   Catholic Charities.
  7       Q. And director of Catholic Charities.
  8            So you had a wide range of roles during the
  9   time that you were at Fresno; yes?
10       A. That's correct.
11       Q. Okay. Did any of those roles involve
12   establishing policy on behalf of the diocese with
13   regard to the protection of children?
14            MR. WOODS: Object to the word "involve."
15   Does that mean occur?
16   BY MS. SOLTAN:
17       Q. Do you understand what I mean by the word
18   "involve"?
19       A. Actually, I'm more confused what you mean by
20   "developing policies." Are you talking about written
21   handbooks?
22       Q. No. I'm talking about did you feel that
23   you it was one of your responsibilities to protect
24   the children of the diocese in any of those roles?
25       A. Well, obviously, as a priest, in any role

0163
  1   you're anxious to protect everybody.
  2       Q. Right. And that it also involved protecting
  3   children, of course?
  4       A. I'll wait till there there's a lot of
  5   movement goes on over there behind you, and I find it
  6   very distracting.
  7            MR. WOODS: Could everyone sit down, please?
  8            MS. SLOAN: My back hurts.
  9            MR. WOODS: Could you stand over there, then,
10   please.
11            THE WITNESS: See, what happens is you're
12   right behind the person moving. And it's
13            MS. SLOAN: I wasn't moving until your lawyer
14   asked me to. I'm sorry.
15            MR. WOODS: I'm finding it distracting. I'm
16   sorry.
17            THE WITNESS: It would be very helpful if over
18   by that wall, then I wouldn't in my frame of view, I
19   wouldn't have anyone moving in the background.
20            MS. SOLTAN: Would you like me to move to the
21   other side of the camera? Would that help?
22            MR. WOODS: No. You're fine. You're fine
23   now.
24            MS. SOLTAN: I forgot my question. Can we
25   have that back, please?

0164
  1            (The record was read as follows:
  2            "And that it also involved protecting
  3            children, of course?")
  4            THE WITNESS: Yes, protecting everyone.
  5   BY MS. SOLTAN:
  6       Q. Is it true to say that that was true of every
  7   single one of those roles that you had at the Diocese
  8   of Fresno?
  9       A. Well, there would be various emphasis
10   according to the specific job at hand.
11       Q. Okay. Could you please describe for me, in
12   your capacity as a priest, what did you do to protect
13   children at the diocese.
14       A. Well, as priests, we were very concerned with
15   making sure that parents were taking care of their
16   children and they were being properly nourished and
17   fed, and all the other obligations that that you
18   would have.
19       Q. What about physical abuse, if you saw evidence
20   of physical abuse, would you have done something?
21            MR. WOODS: Calls for speculation. Calls for
22   an opinion.
23   BY MS. SOLTAN:
24       Q. Well, you indicated that you looked to see if
25   they were nourished and fed.

0165
  1            Did you also look to see if they were being
  2   beaten, for example?
  3       A. Well, in the parishes I served, there were a
  4   lot of poor people. And so a lot of them couldn't
  5   afford food and that. So we were always concerned to
  6   make sure that they had adequate food, or whatever
  7   clothing, whatever they needed.
  8       Q. Did you also look for signs of physical abuse,
  9   like if they were being beaten, for example?
10       A. I did not personally look for abuse, no.
11       Q. Why not?
12            MR. WOODS: Are you saying is it a conscious
13   thing, I'm looking for abuse? Is that what
14            MS. SOLTAN: Absolutely.
15            MR. WOODS: Okay.
16            MS. SOLTAN: Cardinal, I
17            MR. WOODS: A a conscious awareness at that
18   time?
19            MS. SOLTAN: That's right.
20            MR. WOODS: Okay.
21            THE WITNESS: Probably not conscious, but
22   there.
23   BY MS. SOLTAN:
24       Q. If you had seen evidence of physical abuse of
25   a child in your parish or where where you were,

0166
  1   would you have done something about it?
  2            MR. WOODS: Calls for speculation. Calls for
  3   opinion. Instruct the witness not to answer.
  4   BY MS. SOLTAN:
  5       Q. Are you taking the advice of your counsel,
  6   sir?
  7       A. Yes.
  8       Q. During the time that you were a priest
  9   actually, in any capacity at Fresno, did you ever have
10   occasion to see what you considered to be a possibility
11   of physical abuse of a child of any kind?
12       A. No, I simply don't recall anything specific.
13       Q. All right. Did you view, in in all of your
14   various roles during at Fresno, did you supervise
15   other employees of the diocese?
16       A. Yes.
17       Q. Would that include other priests?
18       A. At times, yes.
19       Q. And lay employees as well?
20       A. Yes, at times.
21       Q. Is it fair to say that you had a supervisory
22   role in every single one of your capacities while you
23   were working at Fresno?
24       A. Some to some extent.
25       Q. All right. Did you have more of a supervisory

0167
  1   capacity as you went up the ranks, if you will? I
  2   don't know if that's the correct phrase, but advanced
  3   in the hierarchy of the church. Did your role of
  4   supervision increase?
  5       A. I don't think so.
  6       Q. Okay. In terms of so you felt that you had
  7   a consistent role, requiring you to supervise the
  8   employees of the diocese from the time you were a
  9   priest all the way until the time you were a Bishop?
10       A. Well, "supervise" means a lot of things.
11       Q. That that's my next question.
12            What does that mean to you? What did you
13   understand that to mean when you were there?
14            MR. WOODS: In each role? Take each role and
15   explain? Okay.
16            So starting as a parish priest, each of the
17   roles.
18            THE WITNESS: Well, we'll go back to my first
19   assignment. When I was first ordained, I was at
20   St. John's Cathedral. And most of my ministry was
21   there in the parish, but also taking care of two big
22   hospitals, the county hospital and the community
23   hospital. So we were dealing primarily with trauma
24   patients and people ill, and ministering to the sick,
25   primarily, in those first four month.

0168
  1            And the next two years, I was in Washington,
  2   D.C., so I wasn't in the diocese.
  3   BY MS. SOLTAN:
  4       Q. Before you go on, sir, let me ask you: Were
  5   the employees of the hospital employees of the diocese?
  6       A. No.
  7       Q. Were any of the employees of the hospital
  8   employees of the diocese?
  9       A. No.
10       Q. Were any procedures taken when when you
11   say, then, you were working in connection with the
12   hospital, what does that mean? What were you doing?
13       A. That means when Catholic patients were there,
14   we visited them; when there was an accident and someone
15   needed the anointing of the sick, the sacrament, then
16   we went to anoint them; we had to oftentimes comfort
17   families of sick and injured persons and, quite
18   frequently, of people who had died in an accident or an
19   injury.
20       Q. Okay. So I started out this question in terms
21   of your supervision. And you talked about the
22   hospital.
23            Were you supervising someone at the hospital?
24       A. No. But you asked me what I did in each of
25   the roles I had in the diocese. So I just started at

0169
  1   the beginning.
  2            MS. SOLTAN: Okay. Great.
  3            MR. WOODS: She wants to know what your
  4   supervisory
  5            THE WITNESS: Yes.
  6            MR. WOODS: role was in each job.
  7            THE WITNESS: I know.
  8   BY MS. SOLTAN:
  9       Q. Okay. So when you were at St. John's, sir,
10   what was your supervisory role?
11       A. Minimal. I was there for four months.
12       Q. Okay. And your position, then, was a a
13   priest? That's the best
14       A. Yes.
15       Q. Okay. With regard to two things now, one is
16   the protection of children and the other is the
17   possible of sexual misconduct of priests, could you
18   please indicate to me what you did to ensure, number
19   one, that children were protected when you were a
20   priest at St. John's. What did you do?
21            MR. WOODS: I'm going to object that he has
22   any obligation to ensure or guarantee or affirmatively
23   protect anybody at any time, okay, as a matter of legal
24   obligation. That's not what you mean, I don't think.
25            MS. SOLTAN: Well, I'm not really sure what

0170
  1   your comments are, because this is an oral argument.
  2   So, I mean, is that an objection of some nature?
  3            MR. WOODS: Yeah. Are you asking for an
  4   expert opinion?
  5            MS. SOLTAN: No. I'm asking for this
  6   gentleman's factual recollection
  7            MR. WOODS: Okay.
  8            MS. SOLTAN: of what he did to supervise
  9   people at St. John's in the interest of protecting
10   children.
11       Q. Which you indicated to me to be something that
12   you felt was your responsibility consistently in every
13   position you had.
14            MR. WOODS: Well, you're asking for a
15   conscious effort, something he did consciously at that
16   point in time to protect children. Okay.
17            THE WITNESS: I I'm confused by your
18   question. I'm sorry. During those four months
19   BY MS. SOLTAN:
20       Q. Yes.
21       A. I celebrated masses and weekdays and heard
22   confessions, said mass on Sundays, preached, and helped
23   take care of the Catholic patients at two hospitals. I
24   really didn't have any supervisory role
25       Q. Well, did you have a

0171
  1       A. of people.
  2       Q. Did you have a parish secretary?
  3       A. The parish had a parish secretary.
  4       Q. Did she work for you?
  5       A. Worked for the pastor, actually.
  6       Q. Was that you?
  7       A. No.
  8       Q. Okay. Did anyone work under you?
  9       A. Not really. I was only there four months,
10   brand new priest.
11       Q. All right. So you didn't you believe that
during the time you were at St. Johns, you didn't
13   supervise anyone?
14       A. I can't recall during those four brief months.
15   This is 1962. I simply can't recall. That wasn't my
16   job.
17       Q. Okay. Did you have any instruction during the
18   time that you were a priest at St. John's from anyone
19   else as to what you should do if something untoward
20   happened, for example, you found out there was sexual
21   misconduct by another priest?
22            MR. WOODS: Okay