0001
01 NO. 93-05258-G
01
02 JOHN DOE I, et al. ) IN THE DISTRICT COURT
02 )
03 VERSUS ) OF DALLAS COUNTY
03 )
04 REVEREND RUDOLPH KOS, et al. ) 134TH JUDICIAL DISTRICT
04
05
05 REPORTER'S RECORD
06 VOLUME____OF___
06
07 APPEARANCES:
07
08 MR. WINDLE TURLEY
08 Attorneys at Law
09 1000 University Tower
09 6440 N. Central Expressway
10 Dallas, Texas 75205
10
11 MS. SYLVIA M. DEMAREST
11 Attorney at Law
12 DEMAREST, SMITH, PRESLAR, JONES & GIUNTA
12 Cedar Maple Plaza
13 2305 Cedar Springs Road, Suite 350
13 Dallas, Texas 75201
14
14 FOR THE PLAINTIFFS
15 MR. RANDAL MATHIS
15 MR. DENNIS ROOSSIEN
16 Attorneys at Law
16 MUNSCH, HARDT, KOPF, HARR & DINAN, P. C.
17 4000 Fountain Place
17 1455 Ross Avenue
18 Dallas, Texas 75202-2711
18 FOR THE ROMAN
19 CATHOLIC DIOCESE OF
19 DALLAS
20
21 On the 6th day of June, 1997 the above-entitled
22 and numbered cause came on for a hearing before the
23 Honorable Anne Ashby, Judge presiding of the 134th Judicial
24 District Court of Dallas County, Texas, and a jury, at
25 which time the following proceedings were had:
0002
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01 W-I-T-N-E-S-S-E-S:
02
02 PAGE
03
03 MOST REVEREND ROBERT REHKEMPER
04
04 Cross Examination (resumed)
05 By Mr. Turley..........4517
05
06 Cross Examination
06 By Mr. Mathis..........4574
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0003
01
01 E-X-H-I-B-I-T-S:
02
02 Marked Offered Admitted
03
03 Plaintiff's Exhibit No. 176
04 9-66 Redacted Lynch
04 letter, Bill only..........4505
05
05 Plaintiff's Exhibit No. 177
06 redacted copy of
06 Exhibit No. 176
07 Bill only..................4505
07
08 Plaintiff's Exhibit No. 178
08 1989 Statement on
09 child abuse................4523 4524
09
10 Plaintiff's Exhibit No. 179
10 February '92 policy of
11 priests and sex abuse......4524 4524
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4505
01 June 6, 1997
02 (Out of the presence and
03 hearing of the jury)
04 THE COURT: Mr. Turley.
05 MR. TURLEY: Your Honor, at the end of
06 trial yesterday I had asked the witness about the pattern
07 of secrecy with respect to sexual abuse, reports of sexual
08 abuse of students and minors, and he had denied that. I
09 want to reurge 176, and in the alternative, Your Honor,
10 177. 176 is the document from the Diocese's file which
11 reflects that 1966 they concealed the matter of sexual
12 abuse by Father Lynch. If that troubles Mr. Mathis and the
13 Court, that Father Lynch's name be mentioned at this time,
14 177 is a redacted copy where Father Lynch's name is taken
15 out. I think I am -- certainly should be entitled to cross
16 examine this witness and impeach this witness' tesitmony
17 for the last statement he made before we left yesterday.
18 MR. MATHIS: We argued Exhibit 176 at some
19 length, yesterday. The objections that I made yesterday
20 are as valid today as they were yesterday when you ruled on
21 them. And taking the name out is not the problem. The
22 name of the individual in there is not what the principal
23 concern about that document is, it's the document. So the
24 alternative submission doesn't cure the problem at all.
25 We objected to this yesterday on the basis
4506
01 of relevancy, materiality, First Amendment, everything
02 that's included within our Objection A, and that hasn't
03 changed overnight.
04 MR. TURLEY: Maybe I'm missing something
05 here, Your Honor, but I don't see anyplace where this
06 document is not relevant. It's directly relevant to the
07 issue in this case, and now it's relevant for impeachment
08 of this particular witness.
09 MR. MATHIS: There is no inconsistency with
10 anything that he has said. Our --
11 THE COURT: Well, refresh my memory, if you
12 don't mind, on the impeachment issues?
13 MR. TURLEY: I had asked the witness
14 yesterday a couple of times at the end of his testismony if
15 the church didn't engage in a practice of secrecy of
16 concealing and keeping confidential, acts of sexual abuse,
17 or discovery of sexual abuse with minors. He denied that.
18 He said no. This document contradicts that position
19 directly and straightforward. It couldn't be plainer.
20 THE COURT: Response.
21 MR. MATHIS: That doesn't contradict this at
22 all. For one thing, nobody knows particularly what that
23 documents means in any detailed sort of way, or who was
24 involved, or what the circumstances were. But that
25 doesn't have anything to do with the continuing effort to
4507
01 try to inject collateral matters into this case.
02 This is what we talked about yesterday with
03 the Rules 403, 404, the First Amendment questions, the
04 relevancy, materiality, everything that's included within
05 my Objection A that we -- that we have had to make over and
06 over throughout the course of the trial thus far.
07 That document should not be admitted into
08 evidence. And nothing has changed since yesterday when all
09 of this was discussed and considered at length. I think
10 part of this discussion was in Chambers yesterday. And
11 nothing has changed since then. The ruling was appropriate
12 yesterday.
13 MR. TURLEY: Your Honor, what has not
14 changed is that the Court ruled before this case started,
15 that we could talk about sexual abuse by priests within the
16 Dallas Diocese.
17 MS. DEMAREST: That they had notice of.
18 MR. MATHIS: No, the Court denied my Motion
19 in Limine on the subject, the Court did not rule what could
20 be talked about, other than denying the Motion in Limine on
21 that subject. And so the Court did not rule. The Court
22 did rule yesterday --
23 THE COURT: Refresh my memory as to what
24 the --
25 MR. MATHIS: Sure, I can do that.
4508
01 THE COURT: Can you do that?
02 MS. DEMAREST: About what?
03 THE COURT: As to what your motion in limine
04 said.
05 MR. MATHIS: Right.
06 MR. TURLEY: The Court ruled, Your Honor --
07 the Court ruled that we were entitled --
08 MR. MATHIS: Well, let me finish. She asked
09 for the --
10 MR. TURLEY: -- that you were going to cut
11 us off with the Dallas Diocese.
12 THE COURT: Right.
13 MR. TURLEY: The Court said we can discuss
14 sexual abuse by priests of the Dallas Diocese, and that's
15 what we have been doing, and that's what this is.
16 MS. DEMAREST: And the -- and the other
17 items that have come in through witnesses have been
18 relevant to thir particular qualifications, or to other
19 factual issues in this case.
20 The other thing that the Court should
21 consider with regard to Father Lynch is that -- that there
22 is no question that this gentlemen went on to abuse other
23 individuals in the Diocese. And, in fact, at the beginning
24 of these cases at least two other claimants came forward.
25 And we have evidence of that, and the Vicar General, Duffy
4509
01 Gardner, has evidence of that.
02 Also, this priest was removed from his
03 position as pastor, following the complaints of abuse. It
04 was not cited as the basis for his removal, health was
05 cited for the basis of his removal, but it was after the
06 Diocese had received and paid an additional complaint.
07 MR. MATHIS: May I respond now?
08 THE COURT: Sure.
09 MR. MATHIS: Your Honor, when the motion --
10 when the motions in limine were heard a number of weeks
11 ago, you will remember the chart that I had on the
12 blackboard at that time was a circular chart.
13 THE COURT: Sure.
14 MR. MATHIS: And we were talking about
15 whether or not -- beyond Rudy Kos, the Peebles and Hughes
16 lawsuits and circumstances would be admissible in this
17 case, and then the next ring out were any other priests
18 within the Dallas Diocese, and then out from that, anything
19 in the United States.
20 The ruling in the motion in limine at that
21 time left out things outside of the Dallas Diocese, but
22 left in things inside of the Dallas Diocese. That's on the
23 motion in limine, that's not ruling on the evidentiary
24 points.
25 Now the Court has over the last four weeks
4510
01 allowed in everything with regard to the Peebles and Hughes
02 lawsuits, and has also let in the Brown matter under the
03 guise of --
04 THE COURT: Not everything in the Peebles
05 and Hughes lawsuits.
06 MR. MATHIS: Well, Your Honor, ultimately I
07 am going to have to respond to what has been said --
08 THE COURT: Whatever.
09 MR. MATHIS: -- so everything has been
10 admitted. We are trying three cases in one, in effect.
11 THE COURT: That in essence is not entirely
12 correct.
13 MR. MATHIS: That is certainly my feeling of
14 what has happened. Certainly, aspects of those cases won't
15 be tried here, damages and that sort of thing won't, but
16 the circumstances, we will have to respond to, and so we
17 are.
18 The -- outside of the Dallas Diocese, that
19 was to be kept out and has now come in under the guise of
20 it relates to witnesses' qualifications. The jury is not
21 entitled to hear about all of these other circumstances
22 outside of the Dallas Diocese, but if Father Doyle or Dr.
23 Fierman is allowed to testify about their historical
24 experience in treating priests or dealing with priests from
25 other parts of the country, that effectively does the same
4511
01 thing. The jury knows all about it. I mean, we are
02 trying the Catholic Church in America on this subject in
03 this courtroom right now.
04 THE COURT: No, we're not.
05 MS. DEMAREST: No, we're not.
06 MR. MATHIS: May I finish? I think we are.
07 I think we are, and I have said that for quite a while now,
08 and I --
09 MR. TURLEY: We got it.
10 MS. DEMAREST: We got it.
11 MR. TURLEY: We got it, Mr. Mathis. You've
12 said it eighteen times. We understand it.
13 MR. MATHIS: Good. With respect to -- to
14 Father Lynch in this memo, this is just one more problem to
15 be added, on top of what already has been admitted into
16 evidence. We are talking about something many, many years
17 ago that no one has any way now to investigate or respond
18 to.
19 Now, you know, everybody knows, because
20 Sylvia certainly I think spoke with at least one, that
21 there were claimants that came forward recently after these
22 lawsuits were pending, and there was publicity with regard
23 to Father Lynch. There is no way to investigate claims of
24 this nature thirty years after the fact, so --
25 MR. TURLEY: Your Honor --
4512
01 THE COURT: Wait a minute --
02 MR. MATHIS: Wait till I make my point.
03 MR. TURLEY: Your Honor, let me cut him off.
04 He --
05 MR. MATHIS: Let me make my point.
06 MR. TURLEY: Well, he just goes on and on,
07 Your Honor.
08 MS. DEMAREST: Please get to the point.
09 THE COURT: Sylvia -- y'all stop.
10 MR. TURLEY: We are not going to get this
11 case tried --
12 THE COURT: Stop, stop.
13 MR. TURLEY: He just goes on and on, Your
14 Honor.
15 THE COURT: Stop.
16 MR. TURLEY: We ought to have some way --
17 THE COURT: Stop. You may finish.
18 MR. MATHIS: If you allow evidence in the
19 form of that memo, or a question about that memo, I have no
20 way to respond to it, it's too many years after the fact.
21 It is not fair to admit evidence where we
22 don't have a fair opportunity to respond. It unduly
23 prejudices our position in the case and gives the jury the
24 confusing and misleading impression. That's what Rule 403
25 is all about, and that's what we talked about yesterday. We
4513
01 settled this and talked about it yesterday.
02 MS. DEMAREST: Well, I want to just say the
03 basis for all of this -- the Court has to remember, we've
04 gone through this in detail. This evidence is relevant on
05 pattern and practice of an organization, habit and
06 customary practice. Those are all provided for by the
07 rules.
08 It's relevant on the issue of notice. It's
09 relevant to the Plaintiffs' claims of fraud -- of
10 fraudulent concealment, conspiracy. Those are the bases
11 for all of this evidence coming in.
12 We didn't create the situation within this
13 Diocese that led to the present litigation, they did.
14 Now, because of their habit and practice this -- this
15 information is relevant.
16 This particular document establishes that
17 the pattern and practice of concealment predated the
18 incidents that are involved in this case. And I believe
19 it's relevant on that basis. And see how quick you can be?
20 MR. TURLEY: And, Your Honor --
21 MR. MATHIS: I object to the sidebar
22 remarks. I am entitled to make my responses to objections,
23 and I should not have to have scarcastic remarks directed
24 to me. I am not doing that to Sylvia, and it should not be
25 done back.
4514
01 THE COURT: All right. Sustained as to
02 sidebar. Y'all don't do that.
03 MR. TURLEY: Your Honor --
04 THE COURT: Mr. Turley.
05 MR. TURLEY: -- that letter is just simple
06 and plain. All it says there is "We elect to keep
07 confidential this incident of sexual abuse." We are not
08 going into that sexual abuse. We are not showing when it
09 happened, who it was, anything about it; just that is their
10 pattern and practice to keep these things confidential,
11 which is contrary to what the witness testified to
12 yesterday. That has to come in.
13 And Mr. Mathis saying he is surprised with
14 this, he has known about this since the get-go. This
15 letter has been in their file. That's where we got it. He
16 has known this has been in this case. This isn't any
17 surprise to him.
18 MR. MATHIS: Pattern and practice doesn't
19 open the door to everything. I mean, any time --
20 MR. TURLEY: It just about does, in fraud
21 and --
22 MR. MATHIS: Any time --
23 THE COURT: Don't interrupt.
24 MR. TURLEY: It just about does, Your Honor,
25 in fraud and --
4515
01 THE COURT: Wait. Mr. Turley --
02 MR. TURLEY: -- and conspiracy --
03 THE COURT: Mr. Turley, please don't
04 interrupt.
05 MR. MATHIS: Pattern and practice, notice
06 and fraud have become the buzz words here. That does not
07 justify the admission of evidence that is violative of 404.
08 It's improper collateral matters.
09 It -- it is -- this is exactly what Rule 403
10 was designed to talk about; not to mention the other things
11 that are within our Objection A that relate to the First
12 Amendment.
13 How, the Diocese is administered -- is
14 governed by Canon Law. That is not an appropriate area of
15 inquiry by a civil state court.
16 THE COURT: Okay. May I see the attorneys
17 in my office for just a second, please?
18 (After an in-chambers conference
19 the proceedings resumed within
20 the presence and hearing of the
21 jury as follows:)
22 THE COURT: Ladies and gentlemen of the
23 jury, I'm sorry to keep you waiting, we've just had some
24 real intricate matters that needed to taken up outside your
25 presence, and, yes, we should have worked on it yesterday
4516
01 afternoon. But I'll be honest with you, we were all
02 exhausted and we couldn't do, it. So we are going as fast
03 as we can.
04 And I also want you -- to say, we have not
05 given up our hope of getting through by the end of June.
06 I mean, everybody who has given me letters, and stuff like
07 that, we'll talk about them. You who have -- Juror Number
08 11, tell me your name. No -- is it you who's got a job
09 problem? Okay. Let's talk about it. When are you going
10 to talk with your boss?
11 JUROR: At the end of the month.
12 THE COURT: I'm sorry, at the end of the
13 month?
14 JUROR: Yes.
15 THE COURT: Okay. As soon as you talk to
16 them, would you let me know?
17 JUROR: Yes.
18 THE COURT: Okay. And then we'll know what
19 the situation is.
20 JUROR: Okay.
21 THE COURT: And the other people, we're not
22 -- I mean, I'm not saying that -- that we're not going to
23 get through, we're doing everything we can to get through.
24 The July -- June the 30th, that's a Friday, we'll -- I
25 mean, a Monday, will be a working day, for those who are,
01 you know, who are here, if we're not through earlier. Yeah.
02 That's the last day of June.
03 I want to read this letter before we get
04 started, because it's a real positive way to start the day.
05 "Judge Ashby, thank you, thank you, thank
06 you. We really appreciate the new microwave and
07 refrigerator you obtained for us, especially so soon after
08 our request. You have been very kind to us. Thanks again.
09 It's a unanimous decision."
10 (Laughter in the courtroom)
11 THE COURT: Okay. You may proceed, Counsel.
12 MR. TURLEY: Thank you.
13 MOST REVEREND MONSIGNOR ROBERT REHKEMPER,
14 having been duly cautioned and sworn to tell the truth, the
15 whole truth and nothing but the truth was examined and
16 testified as follows:
17 CROSS EXAMINATION - RESUMED
18 BY MR. TURLEY:
19 Q. Good morning, Monsignor.
20 A. Good morning.
21 Q. Monsignor, I want to catch up here just a
22 little bit, if we could. We have a little kind of a chart
23 that we have been trying to keep -- help our memories with
24 things that have been said.
25 Yesterday we talked about Father Williams
4518
01 coming to you, and you and he, and I guess Father Kos, had
02 this conversation in December or January?
03 A. December.
04 Q. And Williams says that "Kos can't stay away
05 from boys. Almost there -- there almost every night." And
06 he thought it was a serious matter. Do you remember that?
07 A. Surely.
08 Q. I want to put this up here. Now, I have
09 this -- this marked as January, 1992. That's when Father
10 Williams remembered it was, but whether it's December or
11 January, we realize there might be some difference there.
12 All right. And -- and then it was, I think,
13 in the -- the preceding month -- and we could have these
14 months switched around, that as we talked yesterday.
15 Father Kos comes to you along with Williams
16 and says that he needs to see a psychiatrist. Do you
17 remember that?
18 A. Yes.
19 Q. All right. And I've marked this one as
20 December, '91.
21 A. That's true. I thought that's the one you
22 were talking about.
23 Q. Okay, I'm sorry. Well, we -- something like
24 that.
25 A. Uh-huh.
4519
01 Q. All right. Thank you. Now, Monsignor,
02 before I go on with some questions where we left off
03 yesterday, you must have known for some period of time --
04 as close as you were to Bishop Tschoepe, you must have
05 known about his plans to retire, probably before they were
06 announced publicly, I would think.
07 A. Yes, uh-huh.
08 Q. And you have been running the Diocese,
09 yourself for the last several years?
10 A. No.
11 Q. Not exclusively, but you had been helping
12 the Bishop?
13 A. I had been helping the Bishop; he was
14 running the Diocese.
15 Q. For -- for something -- almost twenty years,
16 I guess.
17 A. I think it was eighteen.
18 Q. That you've been assisting him --
19 A. Uh-huh.
20 Q. And doing, I suspect, a very large portion
21 of the work, administrative work in getting it done?
22 A. Right.
23 Q. And you expected to be -- at least
24 considered yourself to be appointed Bishop?
25 A. Very unlikely.
4520
01 Q. You must have considered it, though?
02 A. No, I really didn't. I didn't think that
03 they would ever draw a man from the Diocese to be the
04 Bishop of the Diocese, because it doesn't work too well
05 that way.
06 Q. It is done sometimes, though?
07 A. Very seldom.
08 Q. And in any event, for certain, you wanted to
09 keep the record as clean as you could, because you knew
10 there was going to be a change in the Bishop's position
11 here in Dallas?
12 A. I never looked at it that way.
13 Q. Monsignor, when we discussed yesterday about
14 you needing to wait until you could get a replacement for
15 Father Kos over in Ennis at St. John's, this was not the
16 only time that you had to wait to remove a suspended child
17 abuser until you could get a replacement, was it?
18 A. No, I don't think so. I'm not positive. I
19 don't know what you have reference to.
20 Q. So this was not the only time that that had
21 happened?
22 A. As far as I know. The only one I can think
23 of would be the -- the St. Augustine Pastor.
24 Q. All right. You can't think of any others?
25 A. Not offhand.
4521
01 Q. Never -- it would be your testimony you
02 never told a parish or parishioners that you couldn't
03 replace this troubled priest until you could get somebody
04 else?
05 A. I don't recall that --
06 Q. Okay.
07 A. -- I ever told anybody that, because I don't
08 think that was the point.
09 Q. Father?
10 A. Sometimes it takes awhile to get a priest
11 from one parish to another, if that's what you are driving
12 at.
13 Q. Let me ask you to look at Exhibit No. 1 --
14 MR. TURLEY: Next number.
15 MS. DEMAREST: Oh, is that '89 --
16 MR. TURLEY: Yes, ma'am.
17 MS. DEMAREST: 178.
18 Q. (BY MR. TURLEY) 178. I want to show you
19 Exhibit 178, if we could please. This is -- you see it
20 there on your screen. This is the statement on child abuse
21 released by the Administrative Committee of the National
22 Conference of Catholic Bishops, November 1989; is that
23 correct?
24 A. That's what it says.
25 Q. Now, let me ask you if you agree with the
4522
01 statement that they -- and this went out to all of the
02 Bishops in all of the dioceses in the nation, didn't it?
03 A. I don't know.
04 Q. Let me ask you if you agree with their
05 statement down here near the end of that second paragraph
06 that I have where they say, "Even a single case is one too
07 many, which is why the Church views even a rumor of such an
08 occurrence with intense concern.
09 "Church leaders are advised to investigate
10 immediately, to remove a priest rapidly where the evidence
11 warrants it, to seek appropriate treatment for the
12 offender, and to extend pastorial help to the victim of
13 such a tragedy, and to the victim's family."
14 In 1989 did you agree with that statement of
15 the National Conference of Catholic Bishops?
16 A. Yes; particularly where it says, "where the
17 evidence warrants it".
18 Q. And do you also agree with the second page
19 of this statement where they say, "The hint of such a case
20 is viewed by a bishop with alarm."
21 A. Yes, I would imagine that is true.
22 Q. So we would be safe to say that there were a
23 lot of alarms going off over the years when Rudy Kos was
24 Pastor here in this Dallas Diocese?
25 A. There were a few that I knew of.
4523
01 MR. TURLEY: Your Honor, we offer Exhibit
02 178.
03 THE COURT: Any objections?
04 MR. MATHIS: No, Your Honor.
05 THE COURT: 178 is admitted.
06 Q. (BY MR. TURLEY) And then later on in
07 February of 1992, when this matter is really raging around
08 you with respect to Father Kos, the National Conference
09 speaks again, and they issue Exhibit Number 179. Do you
10 see that?
11 A. I do.
12 Q. And -- let's see what we've got here.
13 "Office of Media Relations United States Catholic
14 Conference policy on -- policy on priests and sexual abuse
15 of children". Let's see what they said then in 19 --
16 February of 1992. See if I read this correctly.
17 "When there is even a hint of such an
18 incident, investigate immediately. Remove the priest
19 whenever the evidence warrants it. Follow the reporting
20 obligations of the civil law. Extend pastorial care to the
21 victim and the victim's family. Seek appropriate treatment
22 for the offender."
23 Then they go on down and they say -- right
24 here (indicating) they mention that they have issued this
25 -- a similar policy in '88, and again in '89, and we just
4524
01 read the one in '89, didn't we?
02 And they say, "As well as those two prior
03 policies, as well as in the four sessions in recent years
04 where the bishops have discussed the matter in general
05 meetings." In other words, this -- they are saying, and
06 now, read -- read back up here with me -- I want to
07 underline this.
08 "This firm approach is evidenced by
09 statements issued by the Conference's Office of General
10 Counsel in '88, '89 -- and by the Administrative Board in
11 '89, as well as four sessions in recent years when the
12 bishops have discussed the matter in general meetings."
13 You were present at some of those meetings,
14 were you not?
15 A. No.
16 Q. Bishop Tschoepe --
17 A. Bishop Tschoepe probably was, but I wasn't.
18 MR. TURLEY: All right. Plaintiff offers
19 Exhibit 179.
20 MR. MATHIS: No objection.
21 THE COURT: Admitted.
22 Q. (BY MR. TURLEY) You agree with those
23 policies, don't you, Monsignor?
24 A. Sure. I think they are good policies. Not
25 that I knew them at the time. I don't remember seeing
4525
01 them.
02 Q. Monsignor, do I understand that this Diocese
03 had had for several years what you refer to, I think, as a
04 Blue Ribbon Committee? Do you know about the Blue Ribbon
05 Committee?
06 A. I knew there was a committee, but I didn't
07 know it was called a Blue Ribbon Committee.
08 Q. There has been testimony in this case --let
09 me ask you to --
10 A. Uh-huh.
11 Q. -- to assume that there was a Blue Ribbon
12 Committee, and priests have testified that they have served
13 on it, and it was set up to deal with sex abuse and what
14 actions should be taken with pastors -- with priests and
15 victims of sexual abuse here in this Dallas Diocese. Do
16 you understand that's what it is supposed to do?
17 A. Yes, uh-huh.
18 Q. But what I --
19 A. I don't know if that was exclusively what it
20 was supposed to do, but that was one of the things that it
21 was appointed for, uh-huh.
22 Q. When we took your deposition about two
23 and-a-half years ago, I understood you to say at that time
24 you didn't even know of the existence of that committee.
25 A. I didn't. I didn't know the --
4526
01 Q. And you never shared any information with
02 that committee about Kos, because you didn't even know
03 about it.
04 A. That's right. I did not know what the
05 committee consisted of, or who the members were.
06 Q. And you are the number two man in charge in
07 this Diocese?
08 A. Yes.
09 Q. For twenty years.
10 A. That's right, but some thin