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
21
22
23 On the 11th day of June, 1997, the
24 above-entitled and numbered cause came on for a hearing
25 before the Honorable Anne Ashby, Judge presiding of the
0002
01 134th Judicial District Court of Dallas County, Texas, and
02 a jury, at which time the following proceedings were had:
03
04
05
06
07
08
09
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
0003
01
01 W-I-T-N-E-S-S-E-S:
02
02 PAGE
03
03 CLAUDETTE ALLEN
04
04 Direct Examination
05 By Mr. Turley..........4873
05 Cross Examination.
06 By Mr. Mathis..........4887
06 Cross Examination
07 By Ms. Demarest........4909
07 Redirect Examination
08 By Mr. Turley..........4911
08 Recross Examination
09 By Mr. Mathis..........4913
09
10 RICHARD GILBERT JAECKLE, M.D.
10
11 Direct Examination
11 By Mr. Turley..........4919
12 Cross Examination
12 By Ms. Demarest........4967
13 Cross Examination
13 By Mr. Mathis..........4982
14 Redirect Examination
14 By Mr. Turley..........5021
15 Recross Examination
15 By Ms. Demarest........5040
16 Recross Examination
16 By Mr. Mathis..........5044
17 Redirect Examination
17 By Mr. Turley..........5064
18 Recross Examination
18 By Ms. Demarest........5066
19 Recross Examination
19 By Ms. Mathis..........5067
20 Redirect Examination
20 By Mr. Turley..........5068
21
21
22 (John Doe #III)
22
23 Direct Examination
23 By Mr. Turley..........5069
24
24
25
25
0004
01 E-X-H-I-B-I-T-S:
01
02 Marked Offered Admitted
02
03 Plaintiff's Exhibit No. 201
03 Letter of 6-11-89
04 From Allens to
04 Bishop Tschoepe...........4887 4887
05
05 Plaintiff's Exhibit No. 202
06 Letter of 9-92 from
06 Allens to Bishop
07 Grahmann..................4887 4887
07
08 Plaintiff's Exhibit No. 203
08 Letter from Allens
09 to Father Duffy Gardner...4887 4887
09
10 Plaintiff's Exhibits 204-210
10 Excerpts from sessions
11 with Rudy Kos of
11 Dr. Jaeckle...............4966 4967
12
12 Defendant's Exhibit No. 61
13 Copy of Dr. Jaeckle's
13 CV........................5020 5020
14
14 Defendant's Exhibit No. 62
15 Dr. Jaeckle's file
15 on Rudy Kos...............5020 5021
16
16
17
17
18
18
19
19
20
20
21
21
22
22
23
23
24
24
25
25
4870
01
02 P-R-O-C-E-E-D-I-N-G-S:
03
04 June 11, 1997
05
06
07 (Whereupon the jury was brought into the
08 courtroom and thereafter the following was had:)
09
10 MR. MATHIS: Is there any document associated
11 with Mrs. Allen that I haven't seen before?
12 MR. TURLEY: There is one document we requested
13 from the Diocese that was not provided to us. I don't
14 know if you've seen it or not, Mr. Mathis.
15 MR. MATHIS: Well, if there is a document from
16 Mrs. Allen, I have not. So let's take that up before we
17 bring the jury in.
18 Is there a copy of this I can have?
19 MR. TURLEY: That is your copy. Actually,
20 there are two others but they don't pertain to what we're
21 talking about.
22 MR. MATHIS: Can I have the two others, too,
23 even if they don't pertain to this?
24 MR. TURLEY: We don't intend to use them.
25 MR. MATHIS: Well, I think they've been
4871
01 requested, Windle. And I don't know why I didn't get this
02 one.
03 MR. TURLEY: Well, because we didn't get it from
04 you, Mr. Mathis. I'm about to prove why we didn't get it
05 from you, in just a minute.
06 MR. MATHIS: I haven't had it. It's going to
07 take us a minute to -- it's going to take me a minute to
08 read it. If they've written other letters, though, I do
09 want to see them. And they were requested like four years
10 ago.
11 MR. TURLEY: I'm ready, Your Honor, anytime.
12 MR. MATHIS: I'm still reading. I'm going to
13 need to see the other two letters. All of this is in the
14 Request for Documents.
15 MR. TURLEY: It is not. I dispute that.
16 THE COURT: Well --
17 MR. TURLEY: Those people are not parties to
18 this case.
19 THE COURT: You all stop.
20 Are there other letters?
21 MR. TURLEY: I have two other letters, Your
22 Honor.
23 THE COURT: Okay. Do you mind if he looks at
24 them?
25 MR. TURLEY: For what reason?
01 THE COURT: Well, because he has requested them
02 in discovery. And if not --
03 MR. TURLEY: Well, we requested them all in
04 discovery, too, and never got them.
05 There you go (indicating), Mr. Mathis.
06 THE COURT: May I see the attorneys up here just
07 a second?
08
09 (Whereupon there was a sidebar conference, out of
09 the hearing of the jury, and thereafter the following was
10 had, in the hearing of the jury, as follows:)
10
11
12 THE COURT: Please call your next witness.
13 MR. TURLEY: The plaintiffs, at this time, call
14 Mrs. Claudette Allen.
15 THE COURT: Please state your full, legal name
16 for the record.
17 MS. ALLEN: Claudette Allen.
18 THE COURT: You may proceed, Counsel.
19 MR. TURLEY: Your Honor, I don't believe this
20 witness has been sworn.
21 THE COURT: You're not sworn.
22 (Whereupon the witness was sworn by the
23 Court, and thereafter the following was had:)
24 CLAUDETTE ALLEN,
25 the witness, having been duly sworn and cautioned to tell
4873
01 the truth, the whole truth and nothing but the truth,
02 testified on her oath as follows:
03 DIRECT EXAMINATION
04 BY MR. TURLEY:
05 Q. Good morning, Mrs. Allen.
06 A. Good morning.
07 Q. Your name is Claudette Allen?
08 A. Yes, sir.
09 Q. Mrs. Allen, where do you live?
10 A. Ennis, Texas.
11 Q. And your husband's name?
12 A. Cliff.
13 Q. Cliff?
14 A. Cliff Allen.
15 Q. What do you folks do over there in Ennis?
16 A. I teach first grade and my husband works at
17 Elk Roofing there in Ennis.
18 Q. Mrs. Allen, I understand that you and your
19 husband have lived in Ennis for some years and you've also
20 been actively involved in St. John's Catholic Church there
21 in Ennis.
22 A. Since I was twelve years old I have been at
23 St. John's, except a short time when we left to go to
24 school.
25 Q. Okay.
4874
01 Tell us about your involvement with the
02 Church during the late 80's and the early 90's, if you
03 would, with St. John's in Ennis.
04 A. We were involved with the -- in sponsorship
05 in the youth group. And my husband was Youth Choir
06 Director during that time.
07 Q. I may have to have you lean forward and
08 speak up just a little bit more.
09 A. Sorry. I'm so nervous. I'm sorry.
10 THE COURT: Do you need some water?
11 MR. TURLEY: Let's get you a sip of water. You
12 probably don't do this every day, do you?
13 THE WITNESS: No.
14 Q. (BY MR. TURLEY) Let me ask you an easy
15 question. Tell us about your children. Don't you have
16 some children?
17 A. Yes. I have a daughter, Anna Marie, 25, a
18 second grade teacher. My son is 21.
19 Q. And your children went to St. John's there
20 in Ennis with you and your husband?
21 A. Right, uh-huh, sure did.
22 Q. They were active in the youth group?
23 A. Yes.
24 Q. Was your son an altar boy in Ennis?
25 A. Yes, uh-huh.
4875
01 Q. So you -- you said that you were -- you were
02 one of the youth leaders?
03 A. Yes.
04 Q. What years did you work with the youth
05 group?
06 A. From about '87 -- I believe it was the end
07 of '87 through '89, the end of '89.
08 Q. And your husband worked with the youth --
09 with the youth choir?
10 A. Uh-huh.
11 Q. What years did he do that?
12 A. Same time. We worked together.
13 Q. Do you folks still participate actively
14 within your Church aside from just attending mass?
15 A. No, not right now we're not.
16 Q. Okay.
17 Mrs. Allen, do you remember when Rudy Kos
18 was -- became your pastor there at St. John's --
19 A. Yes, sir.
20 Q. -- in Ennis?
21 When was that?
22 A. The summer, I believe, of '88.
23 Q. And in the summer of '88, as you've just
24 said, you and your husband were involved in the youth
25 program, right?
4876
01 A. Yes, sir.
02 Q. Very active in your church at that time?
03 A. Yes, sir.
04 Q. That predated Mr. Kos?
05 A. Yes.
06 Q. After Rudy Kos came there to be your pastor,
07 did you start to make some observations about boys staying
08 overnight in the rectory?
09 A. Yes.
10 Q. When did -- when did you first start making
11 those observations or learning that that apparently was
12 taking place?
13 A. Probably a month or so after he came we
14 started hearing people talking, and wondering what in the
15 world is -- you know, are they talking about, why do we
16 keep hearing them say things that we were hearing them say
17 at youth meetings or after young functions and all.
18 Q. This would be like a month -- he came there
19 in the summer of '88?
20 A. Right.
21 Q. Did you hear any comments from the boys,
22 themselves about that sort of thing?
23 A. Comments? That's what we were hearing, is
24 comments about -- you know, hearing so-and-so spent the
25 night or so-and-so was over there. And we didn't
4877
01 understand what in the world was going on.
02 Q. Now, I want to be sure here -- these are
03 comments being made by your young people at St. John's --
04 A. Yes, sir, uh-huh.
05 Q. -- about other young people at St. John's
06 staying overnight and themselves staying overnight?
07 A. No. Now I never heard anybody say, "I spent
08 the night."
09 Q. But everything -- was this fairly general
10 knowledge among the youth group?
11 A. Yes.
12 Q. And you started -- you and your husband
13 started hearing this and making these observations in the
14 summer of '88?
15 A. Right.
16 Q. Did you ever write to the Bishop and
17 complain about that?
18 A. Yes. When --
19 Q. Let me ask you, before -- before -- just a
20 few other questions before you get ahead there.
21 A. Uh-huh.
22 Q. You say you did write to the Bishop. And in
23 that letter that you say you wrote to the Bishop, did you
24 specifically mention the fact, or not, that Rudy Kos was
25 having boys spend the night in the rectory?
4878
01 A. Yes, I believe I did, yes.
02 Q. Now, yesterday Monsignor Rehkemper, seated
03 right where you're seated, swore under oath that the
04 Diocese never received any complaints from parishioners
05 about Rudy Kos having boys overnight. In fact, I think you
06 were in this courtroom yesterday afternoon. Do you
07 remember Monsignor saying that?
08 A. Yes.
09 Q. Do you remember?
10 A. Yes, uh-huh.
11 Q. Are you sure you sent such a letter to the
12 Bishop?
13 A. Yes.
14 Q. To whom was it addressed?
15 A. To Bishop Tschoepe. And -- it was addressed
16 to him.
17 Q. To Bishop Tschoepe?
18 A. Uh-huh.
19 Q. Well, did you hear Monsignor Rehkemper
20 testify yesterday that no such letter was ever received and
21 no such letter was in the Diocese's file?
22 A. Yes.
23 Q. And so how are we ever going to know what
24 you said to Bishop Tschoepe and when you sent the letter?
25 A. I have copies -- I have a copy.
4879
01 Q. You kept a copy?
02 A. Yes, sir.
03 Q. Do you have it with you?
04 A. Yes.
05 Q. Could I see it?
06 Let me ask you to hold on to that just a
07 minute, because you've been kind enough to supply me a copy
08 of it already.
09 Let me ask you, please, ma'am, if Exhibit
10 202, what we've marked as 202, is a copy of the letter --
11 I'm sorry. Wrong one. Just a minute.
12 Here we go.
13 MR. MATHIS: It's 201.
14 MR. TURLEY: 201.
15 MR. MATHIS: June '89.
16 MR. TURLEY: I've got it. June 11th.
17 Q. (BY MR. TURLEY) June 11th, 1989. You can
18 see it on the screen.
19 Is this a copy of the start of the letter
20 that you sent to Bishop Tschoepe at the time?
21 A. Yes, it is.
22 Q. And we've marked it Exhibit 201.
23 Now, in the letter -- we won't take the
24 jury's time to go through all of it right now, but some
25 portions of this letter -- a good portion of this letter
4880
01 describes which conflicts that apparently you're having
02 with Rudy Kos, you and your husband, about the youth group?
03 A. Yes.
04 Q. Can you tell us, in a nutshell what you were
05 explaining to the Bishop at that time?
06 A. We were trying to figure out what was going
07 on with the youth group. We had been meeting every week
08 with Rudy Kos, and all of -- he didn't want to meet
09 anymore. And there was just a lot of different things
10 going on in the parish that we didn't understand.
11 Q. All right.
12 Now, Mrs. Allen, Monsignor Rehkemper, when
13 he testified yesterday said that the Diocese -- you heard
14 him say the Diocese never received a complaint from a
15 parishioner about Rudy Kos, said there wasn't anything in
16 the file about Rudy Kos in the way of a complaint and said
17 that he never received any complaint.
18 Do you know if, in fact, Monsignor Rehkemper
19 also received a copy of this letter?
20 A. I sent a copy to him, also.
21 Q. So we turn over to last page, --
22 A. Uh-huh.
23 Q. -- and there is his name.
24 And it is your testimony that you sent a
25 copy of this letter to Monsignor Rehkemper, --
4881
01 A. Yes.
02 Q. -- as well as Father Hughes, Mr. Simmon and
03 Father Rudy Kos?
04 A. Yes.
05 Q. Now, in this letter, do I understand that
06 you specifically point out to the Bishop and to Monsignor
07 Rehkemper in June of 1989 that for several months Father
08 Rudy Kos has continued to have boys stay overnight in the
09 rectory, that is it --
10 We'll find that in this letter.
11 A. Yes.
12 Q. Let's look at it. Let's look at page 2, I
13 think. We have that identified down here (indicating)
14 I have got it on the correct place, where you
15 say -- read along with me and see if I read it correctly.
16 Let me highlight it to see what we're going to read here.
17 "Another thing that is concerning us is that on several
18 occasions Father Kos has had boys over to spend the entire
19 night, not just a few hours of computer games. For
20 several months we thought very little about it, but we
21 wondered how this looks to others that are not involved
22 with the youth of our parish."
23 Is that what you wrote --
24 A. Yes, it is.
25 Q. -- to Bishop Tschoepe and Monsignor
4882
01 Rehkemper June 11th, 1989?
02 A. Yes.
03 Q. So that if they had read this, they would
04 have known that Rudy Kos was continuing to have boys in the
05 rectory from almost the time he came to St. John's?
06 A. Yes.
07 Q. Now, Mrs. Allen, you've used some language
08 in here where you say, "We wondered how this looks to
09 others that are not involved with the youth of our parish."
10 Tell the jury, please, whether or not your concerns were
11 greater than just appearances -- than just appearance.
12 A. Yes, because it was -- seemed to be
13 happening so often, we kept hearing these things so often.
14 And we wondered what was going on. Why would they be
15 spending the night all night? And we wondered if even more
16 was going on.
17 Q. Something in the way of a sexual
18 impropriety?
19 A. Yes, yes.
20 Q. Now, Mrs. Allen -- so you sent this letter
21 in 1989, sent it to the Bishop and to Monsignor Rehkemper.
22 And what did the Bishop say to you when he responded about
23 your concern?
24 A. He never responded.
25 Q. You never heard back from him?
4883
01 A. No, sir, not a thing.
02 Q. What did Monsignor Rehkemper say when he
03 responded about your concern?
04 A. Nothing. I never heard anything from them.
05 Q. How do you know they ever got the letter?
06 A. I guess I don't. I mailed it myself, but I
07 never got a response.
08 Q. Did you subsequently have a conversation
09 with Father Rudy Kos?
10 A. Yes.
11 Q. Did he indicate whether or not the Diocese
12 had received your letter?
13 A. Yes. He said the Bishop sent him a copy and
14 told him to handle it.
15 Q. So you know that -- according to Father Kos,
16 that the Bishop received a copy of this letter?
17 A. Yes.
18 Q. And you know it's not in the file, you heard
19 from the testimony when you were here yesterday?
20 A. (Witness nods) Uh-huh.
21 Q. Now, Mrs. Allen, was there ever -- you know,
22 we don't have any other letters from you to the Diocese
23 about Rudy Kos, that is in the file. You heard that
24 testimony yesterday, also?
25 A. Right.
4884
01 Q. Let me just ask you, Mrs. Allen, is this the
02 only letter you sent to the Dioceses about Rudy Kos?
03 A. No.
04 Q. Do you remember if in September of 1992 you
05 sent a letter, this time to Bishop Grahmann; do you
06 remember this (indicating) letter?
07 A. Yes, sir.
08 Q. And we've marked this as Exhibit 202.
09 Now, on this letter, ma'am, again without
10 going through everything that you've said in here and your
11 concerns that you have expressed, do you see the part that
12 I've highlighted there where you say, "We are enclosing for
13 your information copies of letters written to Rudy Kos on
14 May 30th, 1989 and Bishop Tschoepe on June 11th, 1989."
15 So is that what you did, in fact?
16 A. Yes.
17 Q. You sent those copies?
18 A. Yes.
19 Q. So let me understand now: June -- September
20 29th, 1992 you don't know what is happening on that
21 particular day about Rudy Kos, do you?
22 A. No.
23 Q. Well, the jury -- the jury has heard
24 something about that. We'll come back to it.
25 But on September 29th, 1992 you send a
4885
01 letter to Bishop Grahmann continuing your concerns about
02 Rudy Kos, and then this time enclosing the letter that you
03 sent in 1989.
04 A. Yes.
05 Q. Do you know, Mrs. Allen, that that letter --
06 this letter right here (indicating) that we're looking at,
07 that day Rudy Kos confessed, I think, and admitted that he
08 had been sexually abusing people, or at least (John Doe #1),
09 that your letter that you dated that day and was obviously
10 received a day or two after that is not in the file?
11 A. No, I know it is not.
12 Q. Did they send it back to you?
13 A. No.
14 Q. Now, that same day you sent another letter,
15 did you not, the same day, to the new Vicar General, this
16 time, Father Duffy Gardner?
17 A. Yes.
18 Q. And without going all through it, this was
19 September 29th, 1992. And we've marked this one as Exhibit
20 No. 203.
21 I note on Exhibit No. 203 it is essentially
22 the same letter that you sent to Bishop Grahmann, isn't it?
23 A. Yes.
24 Q. I didn't compare it word to word, but it
25 looks like you said about the same thing.
4886
01 In this letter you're also telling the new
02 Vicar General about what was happening in 1989, by
03 enclosing a copy of your 1989 letter. And this letter to
04 Duffy Gardner, you heard Monsignor Rehkemper say, is not in
05 the file.
06 A. Yes.
07 Q. But you sent it?
08 A. Yes.
09 Q. All right.
10 Now, Mrs. Allen, how is it that you still
11 have copies of these letters? Why do you still have copies
12 of them?
13 A. So that I would have -- acknowledged what I
14 had said and had a record it, because I never got any
15 response.
16 Q. I notice on -- on some of the materials here
17 -- did you keep this in your computer?
18 A. Uh-huh -- well, it was one of those computer
19 typewriters.
20 Q. Yes, ma'am.
21 Now, were any changes made in this letter
22 when you ran it off --
23 A. No.
24 Q. -- from the time you sent it?
25 A. No, none at all.
4887
01 MR. TURLEY: Your Honor, we offer Plaintiff's
02 Exhibit Nos. 201, 202 and 203.
03 THE COURT: Any objection?
04 MR. MATHIS: No objection.
05 MR. TURLEY: Thank you very much, Mrs. Allen.
06 THE COURT: They are admitted.
07 MR. TURLEY: Your Honor, I would like to put up a
08 note on our red flag chart.
09 THE COURT: Sure.
10 Q. (BY MR. TURLEY) We keep these little
11 records to kind of help us remember, Mrs. Allen. I only
12 have one here. I'll do another one for September, but I
13 don't have it here.
14 This was the one in June of '89. Have I
15 stated that correctly, "Mr. and Mrs. Allen inform the
16 Diocese that for several months boys spending nights at the
17 rectory."
18 Is that correct, ma'am?
19 A. Yes.
20 Q. Thank you.
21 CROSS EXAMINATION
22 BY MR. MATHIS:
23 Q. Mrs. Allen, my name is -- let's kind of get
24 situated here. My name is Randy Mathis. You and I have
25 never met, have we?
4888
01 A. No.
02 Q. I have a few questions. It probably won't
03 take too long, but since your deposition or anything --
04 since your deposition was never taken in the case, I need
05 to ask a few questions just so I'll understand exactly
06 where we are.
07 First of all, is -- your letter in 1989,
08 Exhibit 201, do you know if that is the same letter that
09 Father Williams talked about the other day that the Bishop
10 had gotten and written a reply to Rudy and then sent it to
11 Rudy?
12 A. I don't know. I'm sorry. I wasn't here. I
13 didn't hear his testimony.
14 Q. Okay.
15 So you don't know whether that is the same
16 letter, or not? I mean, I'm guessing it is, but I'm trying
17 to figure it out.
18 A. I don't know.
19 Q. Okay.
20 Let me ask you: On these letters, they
21 don't show a signature by you.
22 Do I understand right that where these came
23 from are out of your typewriter; they're not photocopies of
24 the letters that you say was actually mailed?
25 A. Right. They came out of our typewriter.
4889
01 Q. Okay.
02 So if this letter in '89 -- and let's assume
03 that this went and -- got to Bishop Tschoepe. If you wrote
04 a letter to -- or wrote a handwritten note on there back to
05 Father Rudy and returned it, that would mean Tschoepe
06 didn't keep a copy; Rudy had the only copy with your
07 signature on it?
08 A. I guess. I don't know.
09 Q. Did you and your husband both sign it?
10 A. I believe so, uh-huh.
11 Q. Okay.
12 Let's kind of take a look at this a second.
13 First of all, if you can -- first of all, if you can look
14 at your screen here, let me orient you to what it is. This
15 is a timeline chart of Rudy and the churches that he was at
16 and when he went there. You remember St. John's Church
17 back in 1988; is that right?
18 A. Yes.
19 Q. And you say you remember seeing the boys
20 around and staying at the rectory just almost from the
21 beginning?
22 A. Yes.
23 Q. Okay.
24 At the first, what did you think about it?
25 A. At first I thought that it was wonderful,
4890
01 because I thought he was really putting kids first.
02 Q. Did you know who the boys were?
03 A. Sometimes I did, usually. I mean, because
04 of teaching at St. John's and being in the youth group, I
05 usually knew them.
06 Q. You did teach at St. John's, if I remember
07 your name right. You did teach at St. John's?
08 A. Yes.
09 Q. And I think you were (John Doe #III)' first
10 grade teacher.
11 A. Yes.
12 Q. You've known the (mother to John Doe #III), a
13 long time; is that right? Nine or ten years; is that
14 right?
15 A. Yes.
16 Q. Did you -- were some of the boys that came
17 there when Rudy first moved to St. John's, were they coming
18 in their own automobiles?
19 A. I have no idea.
20 Q. You didn't know how they got there?
21 A. No, I had no idea.
22 Q. So if that is the case, you wouldn't have
23 any knowledge, then, about whether their moms and dads knew
24 they were there or whether they were old enough they didn't
25 need their parent's permission?
4891
01 A. No, I had no idea.
02 Q. But your evaluation of it there, at first,
03 was that this was a good thing and Rudy was doing a good
04 work with the kids; is that right?
05 A. At first, uh-huh.
06 Q. How long was he at St. John's before Rudy
07 sat up that thing called Teen Challenge? Do you remember
08 about when that came into effect?
09 A. I'm sorry, I don't remember exactly. It
10 seems like around -- possibly a year after he was there, I
11 want to say, sometime like that.
12 Q. That sounds about right to me, too. I
13 didn't know. Somewhere in there.
14 A. Right.
15 Q. All right.
16 Would it -- would it have been -- do you
17 know -- do you think, before or after your June 11th letter
18 to Bishop Tschoepe?
19 A. I'm sorry, I don't remember for sure.
20 Q. I tend to think it's around that time
21 somewhere.
22 A. I don't know. I'm sorry, I don't remember.
23 Q. Incidentally --
24 A. Because that was something he was doing
25 and --
4892
01 Q. And you weren't involved?
02 A. And I wasn't involved in it.
03 Q. Did you -- do you know Bishop Tschoepe?
04 A. I have met him a couple of times. I don't
05 know him, know him.
06 Q. But you know he is an elderly man and
07 retired now?
08 A. Right.
09 Q. Your letter here -- this is a pretty lengthy
10 letter. It is two and-a-half pages. And there is this
11 two sentence part on the second page that Mr. Turley talked
12 about. Let's look at some of the other parts of this.
13 A. Uh-huh.
14 Q. What kind of gave rise to your difficulties
15 with Rudy? You say you had worked with the youth program
16 there for awhile?
17 A. Uh-huh.
18 Q. What was your and your husband's position
19 with the youth program?
20 A. We were adult sponsors, I guess you would
21 say, volunteer sponsors.
22 Q. All right.
23 And were you the two that were kind of in
24 charge of running it?
25 A. Yes.
4893
01 Q. Okay.
02 When Rudy got there, when he was first
03 assigned to the Church in '88 -- so that would have been
04 about a year before your letter, did some problems develop
05 between you and your husband and Rudy Kos?
06 A. Not for a long time. In fact, it was -- we
07 were having weekly meetings. And he suggested things we
08 did that -- you know, we did. And everything seemed to be
09 fine.
10 Q. Okay.
11 So on our timeline that I started yesterday,
12 between '89 -- I mean '88, I'm sorry, and at least the
13 middle -- the summer of '89, you and your husband got along
14 okay with Rudy?
15 A. Uh-huh.
16 Q. Is that right?
17 A. Yes.
18 Q. Marsha, the Court Reporter here, will have
19 trouble with a uh-huh.
20 A. I'm sorry. Yes.
21 Q. That takes a little getting used to, once
22 you get the hang of it.
23 During that first year was -- was this
24 activity continuing where Rudy had the boys around the
25 church?
4894
01 A. Yes.
02 Q. Okay.
03 And so that went on -- if I write up here
04 '89, at the top, that year there you saw the boys around
05 the church, were cognizant of it; is that right?
06 A. Yes, uh-huh.
07 Q. I assume your husband was, too?
08 A. Yes.
09 Q. Were other people around the church, as
10 well?
11 A. Sometimes, yes.
12 Q. I mean, this wasn't a secret sort of a
13 thing, was it? I mean Rudy -- you weren't catching Rudy
14 sneaking people in in the middle of the night; he was ju