0001
01 NO. 93-05258-G
01
02 JOHN DOE I, et al. ) IN THE DISTRICT COURT
02 )
03 )
03 VERSUS ) OF DALLAS COUNTY
04 )
04 REVEREND RUDOLPH KOS, et al. ) 134TH JUDICIAL DISTRICT
05
05 REPORTER'S RECORD
06 VOLUME____OF _____
06
07 APPEARANCES:
07
08
08 MR. WINDLE TURLEY
09 Attorney at Law
09 1000 University Tower
10 6440 N. Central Expressway
10 Dallas, Texas 75205
11
11 MS. SYLVIA M. DEMAREST
12 Attorney at Law
12 DEMAREST, SMITH, PRESLAR, JONES & GIUNTA
13 Cedar Maple Plaza
13 2305 Cedar Springs Road, Suite 350
14 Dallas, Texas 75201
14
15 FOR THE PLAINTIFFS
15
16 MR. RANDAL MATHIS
16 MR. DENNIS ROOSSIEN
17 Attorneys at Law
17 MUNSCH, HARDT, KOPF, HARR & DINAN, P. C.
18 4000 Fountain Place
18 1455 Ross Avenue
19 Dallas, Texas 75202-2711
19 FOR THE DIOCESE OF
20 DALLAS
20
21 On the 29th day of May 1997, the
22 above-entitled and numbered cause came on for a hearing
23 before the Honorable Anne Ashby, Judge presiding of the
24 134th Judicial District Court of Dallas County, Texas, and
25 a jury, at which time the following proceedings were had:
0003
01
01 W-I-T-N-E-S-S-E-S:
02
02 PAGE
03
03 REVEREND ROBERT WILLIAMS, JR.
04
04 Cross Examination
05 By Mr. Turley...........3161
05 Cross Examination
06 By Mr. Mathis...........3215
06 Redirect Examination
07 By Ms. Demarest.........3289
07 Recross Examination
08 By Mr. Turley...........3309
08 Recross Examination
09 By Mr. Mathis...........3319
09 Recross Examination
10 By Mr. Turley...........3327
10 Recross Examination
11 By Ms. Demarest.........3327
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12 (John Doe #8)
12
13 Direct Examination
13 By Mr. Turley...........3328
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0004
01
01 E-X-H-I-B-I-T-S:
02
02 Marked Offered Admitted
03
03 Plaintiff's Exhibit No. 101
04 Report on Rudy Kos
04 from St. Luke's
05 Institution...............3326 3326
05
06 Plaintiff's Exhibit No. 102
06 Father Kos's resignation..3326 3326
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07 Plaintiff's Exhibit No. 103.......3301
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08 Plaintiff's Exhibit No. 104.......3301
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04 P-R-O-C-E-E-D-I-N-G-S:
05
06 May 29, 1997
07
08 MS. DEMAREST: We aren't finished with our red flag
09 warnings, Your Honor.
10 The first one, Your Honor, is the
11 superintendent tells the kids were taking trips in '89 and
12 '90. And the -- the last one I put up is the twelve page
13 summary warning Bishop with Kos. And I pass the witness.
14 THE COURT: I don't know if what she --
15 MR. TURLEY: I'll go next next.
16 REVEREND ROBERT WILLIAMS, JR.
17 CROSS EXAMINATION
18 BY MR. TURLEY:
19 Q. Good morning, Father Williams.
20 A. Good morning.
21 Q. Father Williams, you told us yesterday that
22 you have a doctorate -- doctor's degree in psychology?
23 A. Yes.
24 Q. Ph.D in Psychology?
25 You took that degree before you started to
3162
01 study for the priesthood?
02 A. Yes. I technically finished it the first
03 year I was in the seminary.
04 Q. And in that area of psychology, I guess
05 you've had some occasions to look over reports from
06 psychologists?
07 A. Sure.
08 Q. And you understand what -- what they mean
09 when they're speaking with somebody or evaluating somebody
10 and a psychologist or a psychiatrist or a physician, I
11 suppose, is where the words, "Rule out", for example, rule
12 out mumps or rule out chickenpox or rule out depression or
13 schizophrenia", you understand what they mean by that?
14 A. In general. The degree was not a clinical
15 degree.
16 Q. I understand. But this is -- this is
17 pretty elementary, what we're talking about?
18 A. Yes.
19 Q. I think I even understand it.
20 A. Okay.
21 Q. Very elementary.
22 Tell the jury what that means when somebody
23 is -- when a psychiatrist or psychologist would write,
24 "rule out" something.
25 A. I would take it to mean that they saw no
3163
01 evidence for that, that they were probably -- saw evidence
02 that would definitely take them in a different direction,
03 and narrowed down to what they thought was the problem and
04 kind of weeding out other things.
05 Q. That is what it means is to weed out, rule
06 out?
07 A. That's what I understand, yes.
08 Q. And it means weed out or rule out those
09 things that are listed?
10 A. Yes --
11 Q. Whether it's measles or mumps or chickenpox
12 or schizophrenia or something else.
13 A. That's the way I understand it.
14 Q. So if we -- if we look at the report on Rudy
15 Kos from St. Luke's Institute, which we will now mark as
16 Exhibit No. 101. And I'll put it on the screen there for
17 you so we can look at it together.
18 MR. MATHIS: I object to it being on the screen
19 now. That report is not yet in evidence. That was
20 written by somebody else, not Father Williams. Besides,
21 Ftaher Williams has already testified about it just a
22 second ago. So this is premature.
23 MR. TURLEY: We --
24 MR. MATHIS: No foundation.
25 MR. TURLEY: -- will prove this up, Your Honor,
3164
01 by another witness, which we've already proven it up in a
02 deposition. We can get that deposition out and read a
03 little bit of it right now, if necessary. But it has been
04 proved up, Mr. Mathis will tell the Court.
05 MS. DEMAREST: It's part of the Diocese's personnel
06 file.
07 MR. TURLEY: That's true.
08 MS. DEMAREST: It's stipulated, isn't -- we've
09 established it as a business record --
10 THE COURT: Let me see the attorneys up here,
11 just a second.
12 (Whereupon there was a sidebar conference, out of
13 the hearing of the jury, and thereafter the following was
14 had, in the hearing of the jury, as follows:)
15
16 THE COURT: Okay, the objection is sustained at
17 this time.
18 Q. (BY MR. TURLEY) Anyway, Father, without
19 going into that report at this time, it is your thinking,
20 when you see the term, "rule out" written by a physician or
21 a psychologist, it -- what it means is that is one of the
22 things that needs to be weeded out --
23 MR. MATHIS: Objection --
24 MR. TURLEY: -- as explained to us.
25 MR. MATHIS: Objection; asked and answer.
3165
01 MR. TURLEY: No speaking objection.
02 MR. MATHIS: Objection -- Objection; asked and
03 answered.
04 THE COURT: Response.
05 MR. TURLEY: Cross-examination.
06 THE COURT: Okay. Overruled.
07 Q. (BY MR. TURLEY) Father, one of the things
08 that I think you've told us is that when you see the words
09 "rule out", you've explained to us that means that whatever
10 things you see listed there, those are things that needed
11 to be, in effect, weeded out of a working or pending
12 diagnosis.
13 A. Yes, I would think so.
14 Q. All right.
15 Now did I understand you yesterday -- and I
16 may have just not heard exactly what you said, but did I
17 understand you to say yesterday that Bishop Grahmann or
18 Bishop -- or Monsignor Rehkemper, one or both presented to
19 you that Dr. Jaeckle, the first psychiatrist to whom they
20 had sent Rudy Kos, had somehow given him a clean bill of
21 health?
22 A. That -- not that he had -- had a clean bill
23 of health, he was treating -- he had some kind of a problem
24 that needed treating, but it was not pedophilia.
25 Q. They told you Jaeckle had said -- that --
3166
01 yes, Jaeckle told them, "This man is not a pedophile"?
02 A. Yes. Monsignor Rehkemper told me that, I
03 guess, at the meeting in February. And the Bishop, I
04 talked to him in August, I had asked him again, and he had
05 told me again.
06 Q. Okay. Let me get this straight: Both
07 Bishop Grahmann and Monsignor Rehkemper told you that
08 Dr. Jaeckle had said, "Rudy Kos is not a pedophile"?
09 A. Yes.
10 Q. Of course, you haven't talked to Dr. Jaeckle
11 and you a don't know what his testimony is in that regard.
12 A. No, I do not.
13 Q. Now it's my understanding that it was your
14 expectation that in the spring of 1992, around Easter,
15 Father Rudy was going to be removed from his access to
16 children.
17 A. Yes.
18 Q. But he wasn't.
19 A. Correct.
20 Q. And then you presented your summary report.
21 Now Exhibit 98, which we -- Ms. Demarest talked to you all
22 about a long time yesterday, went all through it, twelve
23 pages long, you presented that summary report, I believe,
24 on June 5th, 1992?
25 A. Yes.
3167
01 Q. Because he still hadn't been removed.
02 A. Yes.
03 Q. And it was my impression that once you
04 presented the report, it was your impression that he was
05 likely to be removed that week?
06 A. He was leaving the next week to be
07 evaluated.
08 Q. All right.
09 A. And I assumed that the hospital, after the
10 evaluation, would recommend he removal.
11 Q. All right.
12 And that was the St. Luke's report that we
13 looked at a minute -- or that I started to talk to you
14 about a minute ago?
15 A. Yes.
16 Q. And what did the Bishop or
17 Monsignor Rehkemper tell you that St. Luke's had concluded
18 about Rudy Kos?
19 A. That he was not a pedophile. When I talked
20 to the Bishop I -- he told me he had called them up, the
21 physician who had examined him.
22 Q. That's all right. I don't want to -- I
23 don't want to go into what somebody else said.
24 A. Well, I'm telling you what the Bishop told
25 me.
3168
01 Q. Okay. The Bishop told you?
02 A. That he had talked to --
03 Q. No, I just want to ask you: Did the Bishop
04 tell you, or not, that after that report it was his
05 understanding that Rudy Kos was not a pedophile?
06 A. Yes.
07 Q. And did Monsignor Rehkemper also tell you
08 after this report that Rudy Kos was not a pedophile?
09 A. Yes.
10 Q. So we've got Monsignor -- Bishop Grahmann --
11 Bishop Grahmann now you're dealing with, right?
12 A. Yes.
13 Q. Bishop Grahmann telling you twice?
14 A. Well, I talked with him one time.
15 Q. One time at St. Luke's, one time before
16 with Dr. Jaeckle?
17 A. The same conversation.
18 Q. Okay. He told you that both of these people
19 said Rudy Kos is not a pedophile?
20 A. Yes.
21 Q. And Monsignor Rehkemper told you that Rudy
22 Kos was not a pedophile and that somebody had told him
23 that?
24 A. Yes.
25 Q. When did -- and these conversations took
3169
01 place from the Diocese in the summer of 1992?
02 A. Yes.
03 Q. Did you ever yourself personally see that
04 report from St. Luke's Institute in Maryland?
05 A. No, I did not.
06 Q. I think you said yesterday you asked for it,
07 but you didn't expect them to give it to you?
08 A. I asked Rudy to let me see it, and he said
09 no.
10 Q. So to this day you don't know what was
11 really said to the Bishop.
12 A. No, no, I do not.
13 Q. So the Bishop did not remove Rudy Kos the
14 week of June 5th. In fact, he didn't remove him in June,
15 at all, did he?
16 A. No.
17 Q. And he didn't remove him in July.
18 A. No.
19 Q. He didn't remove him in August.
20 A. No.
21 Q. And it was the very next-to-the-last day, I
22 think, of September before he was finally removed, isn't
23 it?
24 A. Either the last day of September or October
25 1st.
3170
01 Q. And Kos, for those intervening June, July,
02 August, September, four months, less a day or two, for
03 those four months Rudy Kos continued to have access to
04 children?
05 A. Yes, he continued to be pastor of the
06 parish.
07 Q. Continued to have children, in fact, in the
08 rectory?
09 A. Not too many, because I was bugging him
10 about it. They occasionally would come into his office.
11 And when that happened, I would tend to go in and watch and
12 see where they were going. And I tried to keep boys out
13 and away from him.
14 Q. But he had access to them?
15 A. Yes.
16 Q. Continued to babysit, go to people's homes?
17 A. That was my impression, yes.
18 Q. By the way, Father, where are you pastoring
19 now?
20 A. I am in Immaculate Conception Parish in
21 Corsicana.
22 Q. In Corsicana. Is that in the Dallas
23 Diocese?
24 A. Yes.
25 Q. When Rudy Kos was finally sent away the
3171
01 first of October, 1992, did the Diocese tell you, the
02 priest in the parish from where he had been removed, the
03 truth about why he was being sent away?
04 A. No.
05 Q. If they had told you the truth about why he
06 had been sent away, could you have warned the parish that
07 there had been a predator there, that Rudy Kos was a
08 predator?
09 A. Yes.
10 Q. Did you -- did I understand you yesterday to
11 say -- and I don't remember your exact words, but more or
12 less suggested to us, as I heard it, that Monsignor
13 Rehkemper was suggesting that you sort of butt out of this
14 and leave Kos alone, at least one time in the progression
15 of things?
16 A. He never told me that.
17 Q. Didn't use those words, I understand --
18 A. No, he did not.
19 I would go to him and say, "Rudy -- Rudy was
20 telling me that. And his response would be more along the
21 lines of, "I don't know what else we can do."
22 Q. And sort of, "Well, maybe Rudy is right.
23 Maybe you ought to butt out"?
24 A. Well, it was kind of like, "I don't see
25 anything else I can do. It's up to you what you want to
3172
01 do."
02 Q. One of the families over at St. John's in
03 Ennis was the (John Doe #3) family; were they not?
04 A. Yes.
05 Q. Tell us about them and their work in the
06 church.
07 A. When I got there they were involved in the
08 church. I'm not sure of exactly, when I got there or if
09 it was afterwards, (Father to John Doe #3) was on the parish council. I
10 think at some point he was president of it.
11 (mother to John Doe #3) helped Rudy set up a day care center while he
12 was there. They were a family he was extremely close to.
13 He was very-- very explicit they were, in a, sense his
14 favorite family in the parish. And it was very public they
15 were very close friends with him.
16 Q. And this favorite family of his in the
17 parish had a son?
18 A. Had three sons.
19 Q. Had three sons, correct.
20 And one of them was named (John Doe #3)?
21 A. Yes.
22 Q. I'm sorry, (John Doe #3)?
23 A. Yes.
24 Q. (John Doe #3)?
25 A. Yes.
3173
01 Q. And (John Doe #3) is now eighteen, but at that time
02 he was, what, about twelve or thirteen?
03 A. I would think so, yes.
04 Q. Did you notice that (John Doe #3) was one of the
05 young boys that Father Kos treated as kind of a favorite?
06 A. He was very publicly a favorite. He gave
07 him, in essence, an award for altar boy of the year, things
08 like that. He was not one of the ones I was most concerned
09 about.
10 Q. No question but that Kos and the (John Doe #3)
11 family were very close?
12 A. They vacationed together, things like.
13 Q. Kos went to their home often?
14 A. Especially in the spring once the boys were
15 not coming around the rectory as much.
16 Q. Babysat with their younger children?
17 A. I presumed that. I don't remember exactly.
18 I couldn't -- I don't know for sure.
19 Q. Father Williams, yesterday you also
20 mentioned something about the parish at Ferris?
21 A. Yes.
22 Q. Tell the jury the relationship between the
23 parish at Ferris, which was Corpus Christi?
24 A. Corpus Christi.
25 Q. Corpus Christi Church. And
3174
01 St. John's is in Ennis?
02 A. It was a mission church established in the
03 seventies. And that meant the pastor of Ennis was also
04 pastor of that parish. We had responsibility for it. It
05 was small. They had two masses on Sunday, one English,
06 one Spanish. And there was a Wednesday night Spanish mass
07 as well.
08 They had -- the church building and office
09 and a house next to it. It could have been a rectory, but
10 no one lived there. And most of the time I would go over
11 there -- I went every Wednesday night to do that mass.
12 And at least three out of four Sundays I would go over and
13 do the masses there, as well.
14 Q. Now perhaps before you were associate pastor
15 or assistant pastor in Ennis, there was a pastor who lived
16 at the rectory, wasn't there, at least part of the time?
17 A. An assistant, I think, at one time and one
18 of the assistants at Ennis had lived there, yes.
19 Q. At one time it was Father Saldana?
20 A. Father Saldana, yes.
21 Q. When was Father Saldana at Ferris?
22 A. Sometime in the eights. I don't know
23 exactly. He was a couple of assistants, at least, before
24 me, so I did not know for sure.
25 Q. He was there before you were in Ennis?
3175
01 A. Yes.
02 Q. Now you said yesterday that you had been
03 over to Ferris or you had talked to the parishioners at
04 Ferris and you had discovered they had also written to the
05 Bishop about some possible sexual improprieties?
06 A. Yes. The Allens, who told me they had
07 written to the Diocese, they lived in Ennis, but they were
08 going to the church there in Ferris. And that summer of
09 '92 there were several people that told me they were
10 concerned. And I don't remember what -- they had also
11 written a letter, but they were complaining in general.
12 Q. Was it also your -- I'm sorry.
13 Was it also your impression, Father
14 Williams, they had not written about Rudy Kos in the Ferris
15 parish --
16 MR. MATHIS: Objection -- objection, Your Honor.
17 First of all, hearsay; second, the Objection A, what we've
18 designated A.
19 THE COURT: Response as to hearsay.
20 MR. TURLEY: I'm not offering it for the truth
21 of the matter, but rather for his state of mind, the state
22 of mind of the --
23 MR. MATHIS: Can we approach the bench, too, on
24 that?
25 THE COURT: Sure.
3176
01 (Whereupon there was a sidebar conference, out of
02 the hearing of the jury, and thereafter the following was
03 had, in the hearing of the jury, as follows:)
04
05 THE COURT: Ladies and gentlemen you, all excuse
06 us just a minute. We need to put something on-the-record,
07 outside of your presence.
08
09 (Whereupon the jury was excused from the
10 courtroom, and thereafter the following was had in Judge's
11 chambers, out of the presence of the jury, as follows:)
12
13 MR. MATHIS: We're on the record, in chambers.
14 And let me -- let me repeat some of what I was saying there
15 at the bench. Mr. Turley's questions directed to
16 Father Williams have just begun asking about Father Jose
17 Saldana. Father Saldana is a priest of the Dallas Diocese
18 and is one of the people that was an in camera submission
19 that Judge Andrews ruled on earlier.
20 The -- our objection to any questioning with
21 regard to that subject, with this witness, is, number one,
22 hearsay as to this witness. I don't even know that he
23 knows Saldana, for that matter. That hasn't been asked
24 yet. But number one is hearsay, whatever he has -- has
25 heard or been told, and that was -- basically that question
3177
01 called for hearsay.
02 But beyond that, I object to any questions
03 with respect to him on that basis, and also on the basis of
04 things that we listed on our -- earlier in the case that
05 applied to anything about any other priest designated as
06 exhibit -- or, rather, as Objection A.
07 So we have a relevancy and materiality
08 objection to it. It's improper collateral evidence of
09 other collateral matters. It clearly is a 403 situation,
10 of the risk of confusion and prejudice outweighing any
11 relevance. And then there is the whole United States First
12 Amended and Texas parallel provision of the Texas
13 Constitution problem, because how priests with the Diocese
14 are handled, whether it is their hiring, their recruiting
15 in the seminary, their training in seminary, the ordination
16 or supervision, is governed by Canon law of the Roman
17 Catholic Church. And as such, this is not a proper area of
18 inquiry with respect to that.
19 This is particularly true -- I've made this
20 objection repeatedly with respect to the Peebles and Hughes
21 matters and with regard to the Brown matter. This is
22 particularly true of the Father Saldana's situation where
23 they cannot prove, because I don't think there is any
24 evidence to indicate, that he did anything.
25 Now was there a concern and was there an
3178
01 investigation about Saldana? Yes. But beyond that, I
02 don't think I'm obligated or do that it's proper for me to
03 go into the details of that. Judge Andrews has ruled on
04 that matter. That material has been reviewed by Judge
05 Andrews and has been ruled upon previously.
06 As the Court can see now, this is going to
07 grow ever more complicated by the day, depriving us of the
08 opportunity, the ability to have a fair trial on the issues
09 related to Kos and unemcumbered by issues of other priests.
10 And now we have already gone past the Dallas Diocese into
11 other dioceses in other parts of the country that have
12 nothing to do with us in conjunction with the Servants of
13 the Paraclete evidence that was admitted over objection.
14 And so every step we take, every other thing
15 we introduce outside of Kos further emphasizes that
16 problem, further complicates the case and creates further
17 confusion and prejudice with respect to the jury and makes
18 it impossible, effectively, for us to -- to defend the
19 Diocese on these claims.
20 So that is our objection.
21 MR. TURLEY: Contrary to what Mr. Mathis
22 suggests, this case has never been only about Rudy Kos, and
23 it is less and less about Rudy Kos. This case is about
24 the Catholic Diocese, how it responds to allegations of
25 sexual impropriety, how it polices its priests with respect
3179
01 to sexual misconduct.
02 In this regard the particular evidence is
03 relevant and should be admitted, Your Honor, because we can
04 show that the Diocese had notice of sexual improprieties
05 alleged by the parishioners against this particular --
06 Saldana. I want to show that the Diocese did not act
07 aggressively in the matter. They acted just like they
08 acted with Kos. There just wasn't any follow-up of the
09 type that we had with Kos, so nothing was ever done.
10 Mr. Mathis has secreted away the
11 investigative file for Saldana. We have never had a chance
12 to see it. We do not know what is in it. Now he wants to
13 hide behind that investigation and say there wasn't
14 anything to it. Who knows whether there was anything to
15 it? Who knows what is in it? I am, right now, asking that
16 that file be produced and that we have a chance to see it,
17 because it's relevant. And I am to you, right now,
18 appealing Judge Andrews' prior ruling on that matter and
19 asking that the Court look into it and let us have that
20 investigative file. I'm also asking that we be permitted
21 to interrogate Father Williams to show that he knew that
22 there had been complaints made about Saldana by the
23 parishioners at Ferris.
24 MS. DEMAREST: Your Honor, what is relevant about
25 this is there has never been any question, because the
3180
01 Court ordered them produced, that written complaints that
02 the Diocese received about priests concerning sexual abuse
03 be produced. It is our understanding that there are such
04 complaints about Father Saldana.
05 MR. MATHIS: No, that is mischaracterizing what
06 I'm saying.
07 MS. DEMAREST: They have not been produced.
08 MR. MATHIS: That is mischaracterizing -- no.
09 MS. DEMAREST: That is not part of the in camera
10 submission, Randy.
11 MR. MATHIS: Wait a second.
12 MS. DEMAREST: It's not part of the in camera
13 submission, Randy.
14 MR. MATHIS: No, Father Saldana is one of the
15 ones submitted to the in camera submission, if I remember
16 right. It's been months since I've looked at it.
17 MS. DEMAREST: But the complaints -- but the
18 complaints were not --
19 MR. MATHIS: That's right, right.
20 What I'm saying -- you're mischaracterizing what
21 I'm saying. You see, this is why it gets so complicated.
22 Mr. Turley is --
23 MR. TURLEY: It's not complicated. It's very
24 simple. It couldn't be simpler.
25 MR. MATHIS: If this kind of thing is going to
3181
01 be admissible, then I'm going to have to effectively,
02 within this case, try Father Saldana, just like now we're
03 having to try Peebles and Hughes and Brown, ultimately,
04 with regard to the case. A request to the Diocese from
05 someone that effectively says, "I don't know whether
06 anything happened or not", is not a complaint of sexual
07 abuse. And that is why Father Saldana -- you remember,
08 Your Honor, I had been raising cane about Saldana for a
09 long time. And that's why his material was submitted -- I
10 think he was one of the ones for the in camera submissions,
11 and why Andrews ruled on that, whether it was or was not
12 subject to production.
13 MS. DEMAREST: We're talking about a different
14 thing, Randy.
15 MR. MATHIS: And it was not.
16 MS. DEMAREST: We're talking about written
17 complaints that we now have evidence that this Diocese
18 received --
19 MR. MATHIS: No, that is not right.
20 MS. DEMAREST: -- that were not produced in this
21 case.
22 MR. MATHIS: No, that is not right. That is not
23 right. What there is on Saldana is what there is that was
24 submitted in camera.
25 MR. TURLEY: That's all there is?
3182
01 MS. DEMAREST: You're saying that's all there is.
02 You're saying on-the-record, right now, that's all there
03 is?
04 MR. MATHIS: I don't know what else there is.
05 Now I have to go back and study it. It's been months since
06 I looked at it.
07 MR. TURLEY: Mr. Mathis, you have represented to
08 us there isn't anything else by not providing the
09 complaints which we previously asked for.
10 MR. MATHIS: I have given you --
11 MR. TURLEY: By court order.
12 MR. MATHIS: I have given you --
13 MR. TURLEY: I'm assuming you don't have any.
14 MR. MATHIS: I have given you everything that
15 Judge Ashby ordered to be produced with respect to these
16 priests, other than what was given to Judge Andrews for in
17 camera inspection.
18 MS. DEMAREST: Which concerned the Diocese -- which
19 concerned the medical evaluation of Father Saldana by
20 Dr. McNamara and some correspondence between bishops. We
21 -- the -- that was not --
22 MR. MATHIS: I'm not in a position