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 11th day of July, 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:
0002
01
01
02 W-I-T-N-E-S-S-E-S:
02
03 PAGE
03
04 MOST REVEREND DAVID FELLHAUER
04 (continued)
05
05 Cross Examination
06 By Mr. Turley........8717
06 Redirect Examination
07 By Mr. Mathis........8727
07 Recross Examination
08 By Ms. Demarest......8748
08 Recross Examination
09 By Mr. Turley........8755
09 Redirect Examination
10 By Mr. Mathis........8758
10
11 Deposition of Lewis
11 Adelman......................8762
12
12 Deposition of Delores Joann
13 Frost........................8770
13
14 Deposition of James Bernard
14 Frost, M.D...................8776
15
15 MOST REVEREND ARCHBISHOP MICHAEL J. SHEEMAN
16
16 Direct Examination
17 By Mr. Mathis........8781
17 Cross Examination
18 By Mr. Turley........8800
18 Cross Examination
19 By Ms. Demarest......8841
19 Redirect Examination
20 By Mr. Mathis........8846
20 Recross Examination
21 By Mr. Turley........8854
21 Recross Examination
22 By Ms. Demarest......8857
22 Redirect Examination
23 By Mr. Mathis........8857
23
24
24
25
25
0003
01
01 W-I-T-N-E-S-S-E-S:
02
02 PAGE
03
03 Deposition of Mr. (father to John Doe #4)....8859
04
04 Deposition of
05 (mother to John Doe #4)......................8876
05
06 Video deposition of
06 Sister Maureen O'Keefe.......8883
07
07 Deposition of Edith Kozadar..8910
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0004
01
01 E-X-H-I-B-I-T-S:
02
02 Marked Offered Admitted
03
03 Defendant's Exhibit No. 144
04 Ms. Frost letter to
04 Bishop.....................8773 8774
05
05 Defendant's Exhibit No. 145
06 Videotape deposition
06 of Sister Maureen O'Keefe..8906
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01
02 P-R-O-C-E-E-D-I-N-G-S:
03
04 July 11, 1997
05
06
07 (Whereupon the jury was brought into the
07 courtroom and thereafter the following was had:)
08
09 MS. DEMAREST: Your Honor, I had passed the
10 witness.
11 THE COURT: Okay.
12
13 MOST REVEREND DAVID FELLHAUER
14 CROSS EXAMINATION
15 BY MR. TURLEY:
16 Q. Bishop Fellhauer, --
17 Oh, I'm sorry. I'm so quiet they forgot
18 about me, Judge.
19 THE COURT: Quiet?
20 Q. Good morning, Bishop.
21 A. Good morning.
22 Q. Bishop, I just have a very few questions.
23 I'll be as brief as I can.
24 You told us yesterday that in this day and
25 time, because of heightened sensitivity to possible sexual
8718
01 misconduct, there are some things that are just
02 inappropriate. Because of the heightened sensitivity, they
03 may have -- I think you said, some things have an
04 appearance of impropriety.
05 A. Yes, I think -- yes.
06 Q. In that regard, you know, Bishop, in the
07 law, and I think this is probably true in your profession
08 as well, but in the law practice, we have canon of ethics
09 that says we should avoid even the appearance of
10 impropriety.
11 And I know you folks follow the same rules,
12 or you try to. And isn't that because, in fact, we have
13 learned from long, long experience that some things that
14 have the appearance of impropriety, in fact, are improper?
15 A. Yes. That's certainly sometimes true.
16 Q. So that one of the reasons that people
17 now -- you become uncomfortable if people might think it
18 has the appearance of impropriety, these overnight stays,
19 that sort of thing, others might become suspicious and so
20 on.
21 The fact of the matter is, sometimes those
22 suspicions are accurate, aren't they, --
23 A. That's correct.
24 Q. -- as isn't it turned out in this particular
25 case.
8719
01 And along that same line, you told us
02 yesterday that you viewed Kos filling up his life too much
03 with young people, while in one respect it might appear to
04 be an appropriate ministry, that you thought it wasn't
05 good, that too much of that sort of thing really was not
06 proper. And that's again because it can be a signal, can't
07 it, that there's something improper taking place?
08 A. Sometimes, yes, it can be a signal at times.
09 Q. One of the things that we know, in looking
10 for a possible pedophile situation, is to try to determine
11 if the actor or the suspected predator is a type of pied
12 piper with children or young people. That's one of the
13 signs we look for, isn't it?
14 A. Well, I -- yes, I would say, yes, sometimes,
15 sure.
16 Q. And you said yesterday, to Mr. Mathis, not
17 to Ms. Demarest, but when Mr. Mathis was taking your
18 testimony, that you -- at that time, anyway, what you on
19 the Board knew -- you did not think that there was in that
20 information that was supplied to you, a hint or a suspicion
21 that there was any sexual abuse taking place.
22 A. No, we -- we knew of the concerns, we shared
23 the concerns about the boys being over. Nobody had said
24 that there is -- "I believe bad things are going on".
25 Nobody ever said that.
8720
01 Q. Had there been a hint or a suspicion that
02 there was possible sexual impropriety or sexual misconduct
03 taking place, then you would agree, wouldn't you, Bishop,
04 that immediate and aggressive action would have then been
05 called for?
06 A. Yes, had there been an allegation of any
07 type.
08 Q. Are you one of those who adhere to the
09 policy that Monsignor Rehkemper has said is his policy and
10 Monsignor Duffy Gardner has said is his policy and I think
11 perhaps has been articulated by others, until somebody
12 actually comes forward --
13 MR. MATHIS: I object to that characterization
14 of the evidence. That's not consistent what what they
15 said. That is a semantics game.
16 MR. TURLEY: I thought we were not going to
17 object to mischaracterization and not play games.
18 THE COURT: Yes.
19 Ladies and gentlemen of the jury, please recall the
20 evidence and the testimony to the best of your ability.
21 Q. (BY MR. TURLEY) Bishop, the reason I asked
22 the question, Monsignor Rehkemper certainly made crystal
23 clear to the jury, I represent to you that he did, that
24 until somebody came forward with an actual allegation of
25 sexual misconduct, that he wasn't going to do anything
8721
01 about it.
02 Is that your position? Was that the
03 position of the Board up until 1990 when you were on it?
04 A. Mr. Turley, I cannot respond to what you say
05 about Monsignor Rehkemper just --
06 Q. Well, assume. I know you didn't. You
07 weren't here.
08 A. -- apart from what he said.
09 Q. Assume that that's true.
10 A. No. I, myself, would not consider it
11 necessary to have -- to have an accusation before doing so.
12 Q. Father Duca, when he was here, day before
13 yesterday, in his testimony -- you know Father Duca. You
14 served with him for many years in this Diocese.
15 A. I do.
16 Q. In his testimony he explained to the jury
17 that the Personal Board normally would only have the
18 information that the Bishop or the Vicar General chose to
19 share with him about various priests. You agree with that,
20 don't you?
21 A. That's correct, I do.
22 Q. And -- and you are -- you are unaware, I
23 guess, of just what it might have been that Bishop Tschoepe
24 and later Bishop Grahmann did not share with the Personnel
25 Board regarding Rudy Kos.
8722
01 Of course, I guess Bishop Grahmann came
02 after you had left, didn't he, because you took his place?
03 A. We were -- we overlapped for awhile.
04 Q. You would not be aware of what information
05 Monsignor Rehkemper or Bishop Tschoepe chose to withhold
06 from the Personnel Board?
07 A. Unless I knew that from another source.
08 Q. That's right.
09 And so that the impressions that you
10 explained the jury yesterday that you thought the Board had
11 about Rudy Kos and what that issue was, those impressions
12 were simply based upon the information that the hierarchy
13 had chosen to share with the Personnel Board; isn't that
14 right?
15 A. As I believe I mentioned, we discussed that
16 in the Personnel Board, including with Monsignor Kamel,
17 among other -- or he was one on the Personnel Board who had
18 had his own experience with -- with Rudy Kos.
19 Q. Exactly.
20 And if Monsignor Kamel or Bishop Tschoepe or
21 Monsignor Rehkemper did not share information with the
22 Board, then you didn't have that information to build your
23 impressions on about what the issue really was.
24 A. That would be correct.
25 Q. And you might have had -- as you testified
8723
01 here yesterday, you might have had more or different
02 opinions if you had had more or different information;
03 isn't that true?
04 A. Well, I think -- yes I think that is taken
05 for granted, uh-huh.
06 Q. And you're certainly not here to tell us
07 anything about the opinions that you had or the Personnel
08 Board had regarding Rudy Kos as to anything that happened
09 after you left in 1990.
10 A. No, I don't have -- I don't have anything to
11 say about that.
12 Q. Bishop, I'm not going to go all the way
13 through these again. Ms. Demarest did it with you
14 yesterday, but -- I think -- and I think she covered almost
15 all of the things I wanted to talk to you about. I'm not
16 going to go through these -- I'm going to show them to
17 you, if I have the light on.
18 Bishop, there are about ten items that I
19 think Ms. Demarest talked to you about yesterday, nine or
20 ten items --
21 Just one second. I'm waiting for this
22 screen to come up.
23 We had nine or ten items. I'm not going to
24 go through and read these to you, Bishop. Ms. Demarest
25 went over them with you. But they have to do with the
8724
01 letters that Father Clayton had shared with the Diocese.
02 They have to do with the information that Mrs. Allen --
03 Mr. and Mrs. Allen shared with the Diocese in 1989, they
04 have to do with the -- the information that Monsignor
05 Rehkemper took up with Father Kos about the warnings that
06 he was giving him, all of that type of information.
07 And finally, also in 1989 there was --
08 assume that there has been testimony in this case that the
09 Diocese's school superintendent had been informed that Rudy
10 Kos was, from time to time, taking boys away from the
11 church, away from the school for overnight trips.
12 Bishop, all of that information combined,
13 which I realize you said yesterday you didn't have all of
14 that information, you would agree, would you not, that all
15 of this together certainly, certainly rises to the
16 threshold level of at least a hint of possible sexual
17 impropriety. You would agree to that; wouldn't you,
18 Bishop?
19 A. I don't know how to phrase it. Obviously
20 it's a cause for concerns. We -- we -- we thought it was
21 cause for concern.
22 Q. My question, Bishop, is real simple: Don't
23 you agree with me that this information is a hint that
24 something improper may be taking place?
25 A. I don't think I would characterize it as a
8725
01 hint.
02 Q. That's still your mindset?
03 A. Yes.
04 Q. Bishop, am I correct that the -- the
05 Diocese's office -- the Bishop, under his direction, sets
06 the salary for all of the priests within the Diocese?
07 That comes from the Diocese's Office, doesn't it, not from
08 the parish?
09 A. It doesn't come from the parish.
10 Obviously there would be priests in other
11 ministries who would be paid different salaries,
12 particularly if they work for other institutions such as
13 hospitals.
14 But basically, yes, it is the Bishop who
15 sets the diocesan priests' salaries in a parish.
16 Q. Now, Bishop, you knew -- the Personnel Board
17 knew and you knew and -- and the Bishop and Monsignor
18 Rehkemper all apparently had strong opposition to overnight
19 stays in the rectory by children; isn't that right?
20 A. Yes.
21 Q. But did you know that that policy was never
22 communicated to the lay staffs of the various parishes?
23 For example, Mrs. Strunc, the secretary over
24 at John's in Ennis, that policy was never communicated to
25 her. Did you know that lay staff did not know that, about
8726
01 that policy?
02 A. I don't recall whether there was a written
03 policy or not.
04 Q. Well, but my question is: when you were
05 here, were you aware of the fact that the lay staff, the
06 secretaries, the housekeepers, the people at the various
07 parishes were uninformed about the diocesan policy against
08 overnight stays of young people in the rectory?
09 A. I don't -- I don't know of any -- any policy
10 such as that that were communicated specifically to lay
11 employees.
12 Q. And are you aware, Bishop, that to this day,
13 except for what has been communicated in this courtroom,
14 the laity, the members of the various parishes have never
15 been officially told about that policy against overnight
16 stays and the policy of taking children out of town on
17 trips overnight?
18 A. I'm not aware of that.
19 Q. Do you agree with me that that is an
20 important policy? That's an important policy.
21 A. I think it is, yes.
22 Q. And it is an important policy that should be
23 shared with the laity and the lay staffs at the various
24 parishes so that they can be involved in seeing that it is
25 enforced. That would make sense, wouldn't it?
8727
01 A. It would make sense.
02 Q. Bishop, that's all I have. Thank you very
03 much, sir.
04 REDIRECT EXAMINATION
05 BY MR. MATHIS:
06 Q. Bishop Fellhauer, I have just a few more.
07 First of all, as we talked about yesterday,
08 during all of this period of years that we're talking about
09 when Rudy was at All Saints, Monsignor Kamel, during this
10 four years right here (indicating), '81 to '85, Monsignor
11 Kamel lived there at All Saints with Rudy Kos, didn't he?
12 A. That's correct.
13 Q. And you knew Monsignor Kamel and had known
14 him for many, many years before Rudy ever graduated
15 seminary and went to work there at All Saints.
16 A. Yes, I knew Monsignor Kamel well.
17 Q. Was Monsignor Kamel an experienced,
18 respected member of the clergy here in Dallas?
19 A. Very much so.
20 Q. All right.
21 So during all of these same years that you
22 served on the Personnel Board with him from -- from before
23 Rudy Kos graduated until you moved in 1990, part of your
24 evaluation of what this situation was or was not was based
25 on the guidance you received and the information you
8728
01 received from Monsignor Kamel.
02 MS. DEMAREST: I'm going to object as leading.
03 THE COURT: Sustained.
04 Rephrase.
05 Q. (BY MR. MATHIS) Did you, in the course of
06 serving on the Personnel Board in considering Rudy Kos,
07 rely on information from Monsignor Kamel?
08 A. I did, considering it very reliable.
09 Q. Did you also rely on information from Father
10 Rehkemper?
11 A. I did.
12 Q. All right.
13 Now, so there were not just one source of
14 information as you considered what was or was not going on
15 with Rudy Kos.
16 A. That's correct.
17 Q. Now Kamel, he was in residence at All Saints
18 Church, wasn't he?
19 A. Excuse me, Kamel?
20 Q. Yes. Father Kamel lived at All Saints, in
21 the rectory?
22 A. Oh, yes. He was the pastor. He was in
23 residence in that sense.
24 Q. All right.
25 So he would have been, in addition to Father
8729
01 Kelly, the man on the scene to know exactly who was coming
02 over to the rectory at any given time.
03 A. He would have -- yes, he would definitely be
04 in a position to observe.
05 Q. He would have been the person, in addition
06 to Father Kelly, in the best position to see what was going
07 on or not going on on a day-to-day basis?
08 A. I would think so, yes.
09 Q. Now, he would, likewise, be the one to know
10 whether or not, say, a (John Doe #17), who testified
11 yesterday, who was an adult friend of Rudy Kos, was one of
12 the people that was over there, correct?
13 A. Excuse me?
14 Would you repeat that?
15 Q. Yes.
16 Father Kamel, in being in residence at All
17 Saints Church, would have been on the scene to see who was
18 going over there and staying, such as (John Doe #17) who
19 testified here yesterday morning.
20 A. That's right.
21 Q. All right.
22 And you know from his testimony, (John Doe #17)
23 was an adult during all of these years. He was a grown
24 man.
25 A. That's right.
8730
01 Q. All right.
02 So in Father Kamel's consideration and
03 reporting and advising you and the rest of the Personnel
04 Board, he would have had various information from right
05 there on the scene that the Board, not being there,
06 wouldn't necessarily know.
07 MS. DEMAREST: Your Honor, I'm going to object to
08 this leading, leading, leading.
09 MR. MATHIS: Well --
10 THE COURT: That's sustained.
11 Q. (BY MR. MATHIS) Well, Father Rehkemper -- I
12 mean, Father Fellhauer, was there anybody in a better
13 position to evaluate Rudy Kos between 1981 and 1985 than
14 Monsignor Kamel and Greg Kelly who were living in the same
15 house with him?
16 A. I wouldn't think so.
17 Q. Okay.
18 Is there anybody else during those years who
19 would have been in a better position to observe, say, Rudy
20 Kos and (John Doe #17) going with the groups of boys to the
21 movie or to the mall or wherever they went?
22 A. Nobody would be in a better position than
23 those with whom you lived and worked in the same house.
24 Q. All right.
25 So in your view was it perfectly reasonable
8731
01 and appropriate for you to rely heavily on the evaluation
02 of Monsignor Kamel?
03 MR. TURLEY: Leading, leading, leading.
04 THE COURT: Sustained.
05 Q. (BY MR. MATHIS) Well, Father Fellhauer, tell
06 us who you would have relied on most heavily for guidance
07 in evaluating Rudy Kos during all of this period of time.
08 A. I would have and did rely very heavily,
09 probably most heavily, on Monsignor Kamel's remarks,
10 observations.
11 Q. What were Monsignor Kamel's -- what was his
12 feel for this, his evaluation for what Rudy Kos was or was
13 not doing?
14 MS. DEMAREST: I'm going to object, Your Honor.
15 This is pure speculation. He can't possibly know what
16 Monsignor Kamel's feeling was.
17 THE COURT: Sustained. I think he can talk about
18 his impression.
19 MR. MATHIS: Yes.
20 THE COURT: His personal impression, but not --
21 MR. MATHIS: Yes.
22 Q. (BY MR. MATHIS) Bishop Fellhauer, what, from
23 your --
24 MR. TURLEY: Well, Your Honor, I'm going to
25 object. This has been asked and answered at least two
8732
01 times, maybe three.
02 MR. MATHIS: I don't think it's been asked in
03 this way.
04 THE COURT: Okay.
05 MR. MATHIS: And I want to know this --
06 THE COURT: Go ahead.
07 Q. (BY MR. MATHIS) What was your impression?
08 What was your analysis of Monsignor Kamel's explanation of
09 Rudy Kos and his spending time with (John Doe #17) and these
10 other people?
11 A. Monsignor Kamel expressed verbally --
12 MR. TURLEY: Objection, hearsay.
13 THE COURT: Sustained. And nonresponsive.
14 MR. MATHIS: It's not offered for the truth of the
15 matter, it's offered to show notice of what Bishop
16 Fellhauer heard and relied on.
17 THE COURT: Okay, then ask that question, because
18 it's nonresponsive as it is. His analysis.
19 Q. (BY MR. MATHIS) Okay, Bishop, what we need
20 to know is: What is your analysis of what Monsignor Kamel
21 told you?
22 A. My analysis is that Monsignor Kamel observed
23 some young people there. He had had concerns. As time
24 went on, his concerns abated. He did not believe that
25 there was anything improper happening. And he thought,
8733
01 even though, that he and the other priests were sometimes
02 inconvenienced by the presence of others, that is, their
03 privacy was to some extent taken away, that he thought it
04 was, on the whole, worth it because of the rapport that
05 Father Kos, Rudy Kos had with young people.
06 Q. All right.
07 Did Monsignor Kamel ever -- did Monsignor
08 Kamel ever indicate to you whether he, in fact, knew the
09 families of a number of these people involved and was
10 familiar with them there at the All Saints Church?
11 MR. TURLEY: Objection, hearsay.
12 THE COURT: Sustained.
13 MR. MATHIS: Again, Your Honor, that's not offered
14 -- I'm not asking for specific words and it's not offered
15 for the truth of the matter.
16 Let me rephrase it.
17 THE COURT: Okay,
18 Q. (BY MR. MATHIS) Based on anything you ever
19 heard from Monsignor Kamel, did he indicate one way or
20 another whether he himself knew a number of the parents of
21 the people who were spending time with Rudy Kos?
22 MR. TURLEY: Still hearsay.
23 MR. MATHIS: This is just notice, Your Honor.
24 THE COURT: Say that again, the -- say that
25 again.
8734
01 MR. MATHIS: It's not offered for the truth --
02 THE COURT: No, but your question.
03 MR. MATHIS: -- it's purely notice.
04 Did Monsignor Kamel indicate to Bishop Fellhauer
05 through all of this period of time whether or not he knew
06 the parents of any of the people who were spending time
07 with Rudy at the rectory.
08 MR. TURLEY: That's plain hearsay and it's not
09 notice.
10 MR. MATHIS: It certainly is. It certainly is.
11 MR. TURLEY: The fact that "he", indicating --
12 who are you talking about when your referring to "he"?
13 MR. MATHIS: Father Kamel.
14 THE COURT: The he -- that Father Kamel knew any
15 of the parents. And it goes to notice?
16 The objection is sustained as to hearsay.
17 Q. (BY MR. MATHIS) Do you yourself know whether
18 Monsignor Kamel knew any parent of any of the boys who were
19 spending the night?
20 MR. MATHIS: Does he himself know.
21 MS. DEMAREST: Your Honor, that would have to be
22 information he obtained from Monsignor Kamel, which would
23 be hearsay and --
24 THE COURT: Wait a second. This question is not
25 objectionable. This is a, "Do you know?"
8735
01 THE WITNESS: Please repeat.
02 (laughter in the courtroom)
03 MR. MATHIS: I'm not going to give up on this
04 question.
05 Q. (BY MR. MATHIS) Father, do you know whether
06 or not Monsignor Kamel knew any of the moms and dads of the
07 boys who were staying up at the rectory?
08 A. I can tell you what my impression was since
09 I don't recall specific conversations.
10 Q. Okay.
11 THE COURT: Then it's nonresponsive.
12 MR. TURLEY: That's what it thought.
13 MR. MATHIS: Okay.
14 Q. (BY MR. MATHIS) Would you tell us your
15 impression of whether Monsignor Kamel knew any of the
16 parents of the boys who were staying at the church?
17 A. My impression --
18 MR. TURLEY: That calls for speculation.
19 THE COURT: Okay, that's overruled.
20 Go ahead and you can answer that.
21 (laughter in the courtroom)
22 THE WITNESS: My impression is -- strong
23 impression is that Father Kamel, having been pastor for
24 some time, the founding pastor of All Saints Church and
25 knowing a great number of the parishioners there, would
8736
01 certainly have known the families of -- of all or some or
02 many of the boys that were there.
03 Q. (BY MR. MATHIS) All right.
04 Bishop, after Rudy Kos moved to St. Luke's
05 Church do you know -- do you know whether or not -- there
06 has been this indication in one of these letters that
07 somebody thought Rudy was gay. Do you know whether or not
08 that has anything to do with him, just by happenstance,
09 spending so much time with (John Doe #17) who was his best
10 friend?
11 A. I don't recall having heard an allegation or
12 a suspicion that he was gay.
13 Q. Okay.
14 While Rudy was at St. Luke's when Father
15 Clayton expressed his concerns, how did Monsignor Kamel
16 equate Father Clayton's concerns with his own experience at
17 All Saints Church with Rudy?
18 MS. DEMAREST: Your Honor, I'm going to object.
19 There is no way that that can be anything but hearsay.
20 MR. MATHIS: No, it's his -- Your Honor, it's
21 his reaction. He served on the Personnel Board with this
22 man for many, many years.
23 THE COURT: Okay, then ask it that way.
24 Q. (BY MR. MATHIS) Okay. Well, if I -- if I
25 ask, then, Father, on the Personnel Board, when the Board
8737
01 was made aware of Father Clayton's concerns at St. Luke's
02 Church, what was -- based on your perception of Monsignor
03 Kamel, what was his analysis of Clayton's concerns in
04 relation to what he had seen himself at All Saints Church?
05 MS. DEMAREST: Your Honor, I object. It has to be
06 speculation on this witness's part.
07 MR. MATHIS: It's not speculation if he was with
08 him and meeting with him on the Personnel Board.
09 MS. DEMAREST: Your Honor, he can't possibly know
10 what Monsignor Kamel was thinking.
11 MR. MATHIS: He can if --