c '"r 0 STATE OF LLNOS ) ) ss: COUNTY OF C 0 O.K ) N THE CRCUT COURT OF COOK COUNTY LLNOS COUNTY OEPARTMENT. LAW OVSON JOHN DOE # ) Pantff ) VS. THE CHCAGO PROVNCE OF THE SOCETY OF JESUS. Defendant. ) No. 0 L ) ) ) The dscovery deposton of REVEREND DANEL L. FLAHERTY. taken n the abovewentted cause before Dna C. Corvno a Certfed Shorthand Reporter of Cook County. nos On the th day of May 0. at 0 West Madson Street Chcago nos pursuant to Notce at the hour of 0: am. Reported by: Lcense No Dna C CorVno CSR RPR OB00 APPEARANCES: KERNS FROST & PEARLMAN LLC by MR. MCHAEL BROOKS and MR DAVD ARGAY 0 West Madson Street Sute 0 Chcago nos 00 () -0 Representng the Pantff OUERREY & HARROW LTD. by MR. ROBERT HUEBSCH West Jackson Bvd. Sute 00 Chcago nos 00 () 0 000 And- LAWOFFCES OF McCARTHY & TOOMEY by MR. TMOTHY C TOOMEY West Touhy Avenue Sute LnCOnwood nos 0 () -000 Representng the Defendant MR ROBERT MALONEY Attorney At Law P.O. Box Oak Park nos 00 () Representng Donad McGure. NDEX WTNESS EXAMNATON REVEREND DANEL L FLAHERTY By Mr. Brooks... By Mr. Maoney... By MrBrooks (further)... By Mr. Huebsch...... By Mr. Maoney (further)... 0 EXHBTS NUMBER MARKED FOR D FLAHERTY Deposton Exhbt. No......"... No... No...."... No..."...""... No.... 0 No......"... Nos. &... (Wtness sworn) MR BROOKS: Good mornng Father. My name s Mchae Brooks. As you know represent the pantffs n ths tgaton whch arses out of actons of Donad McGure a former Jesut prest. Durng the course of ths deposton today 'm gong to ask you a seres of questons some about Father McGUre and some about other subects woud ask that you gve an answer to 0 the best of your abty Pease do not specuate or guess at an answer. f you do not understand a queston pease et me know. w be happy to have the court reporter read t back to you or can rephrase t f you'd ke whatever s easer for you. f at any tme today you need a break to go to the bathroom to get some water whatever ust et me know and w be happy to et you take a short break so that whatever needs you have are met before we contnue. As you can see there's a court reporter here takng down everythng that you and say So the one request woud make to you n advance of my questonng s that you wat unt 'm actuay : :.. " J '. ' }.\ t.' : '} " :. McCork e Court Reporters' nc. Chcago nos () -00 (Pageg to ) EXHBT
They were ndvdua rboms at West across the rver from S. Lous. Beeve. Baden. guess yes. A of nos a of ndana the Q. On 'campus? bottom haf of Oho ncudng centered reay n o Cncnnat and what we ca our Appaachan msson whch s headquartered out of Lexngton Kentucky..J 0 0 A. Yes t was - we t was one of the eght wonders of the word. No mean t teray was. t was a crce that had been but by Baard who ran a orcus. So we had an atrum n the mdde where he coud run a crcus. Q. To your knowedge dd Dorad McGure ve n one of these ndvdua rooms whe he was at 0 West Baden? A. Sure yes. Q. Whe you were at West Baden dd you hear any rumors or gossp nvovng Donad McGure? Q. Let me foow up wth a specfc queston. Whe you' were at West Baden dd you hear any rumors or gossp about Donad McGure's sexuaty? Q. 'd ke to ask you a few questons about how the Jesuts are organzed. Correct me f 'm wrong but there's a Chcago order of the Jesuts s that rght? MR. HUEBSCH: Just so we have a tme frame are Q. And has that been the terrtory for the Chcago provnce snce the tme that you frst started workng there n? A. A but the Lexngton porton. So when oned we were n Chcago ndana and Oho. No. That's not rght ether. And the reason say that -- Q. When you say you oned you're takng about onng back n Chcago after your stnt n New York Cty? A. n -- no no no. Q. Oh you're takng about orgnay now? MR. HUEBSCH: thought we're takng about currenty. MR. BROOKS: We dd. But now -- but) asked -- MR. HUEBSCH: What was the ast queston? MR. BROOKS: asked f there had been a change.. you takng about currenty? n terms of the -- MR. BROOKS: Currenty and then 'm gong to THE WTNESS: And there had. tak about hstorcay. MR. BROOKS: -- ocae. MR. HUEBSCH: Just so we understand ust THE WTNESS: n -- so reay shoud go currenty. Go ahead. back and restate because when entered the -- what BY MR. BROOKS: s now the Chcago and Detrot provnce were a Q. As we st here today have a few one provnce and that ncuded -- over and above questons about the structure of the Jesuts. what sad for Chcago that ncuded Detrot and There's an offce n Chcago s that Ceveand and the upper pennsua of Mchgan. rght? 0 BY MR. BROOKS: A. That's correct. Q. At some pont that was carved out nto a Q. What s that socety caed? dfferent offce? A. Let me gve you a tte wder pcture. A. n the provnces were separated '.' Q. Okay. That was my next queston. f you because We had too many men for one provnca to " want to start that way that's fne. apprecate hande. So the provnces were spt n. your hep. Q. Who chooses who the provnca of the A. n North Amerca we have what s caed Chcago Jesuts s gong to be? the Jesut Assstancy North Amercan Assstancy. A. Utmatey the genera n Rome. But the There are ten provnces. The Chcago provnce s ' process nvoves gatherng nformaton from men of one of those ten provnces. the provnce and then the provnca and hs " Q. And what are the -- what does the Chcago consutors prepare what s caed the tema three \ regon encompass? toe-ron-a of three names to send to the genera' A. Okay. The Chcago regon s Chcago a. wth a the supportng documentaton for hm to of nos wth the excepton of the docese make a choce.:. McCorke Court Reporters nc. Chcgo nos () -00 (Pages to ) g
Q. And has that been true snce the tme that Q. Oan you te me what s ben done to the ' you were provnca n? extent of your knowedge obvousy? A. Yes. g A. We what has been announced s that- agan because of manpower -- and n ths case dmnshng manpower -- the provnces w be reagned from ten to fve and the three provnces nvoved n the Mdwest are Chcago Detrot and Wsconsn. 0 Q. You ndcated n your testmony that there are ten provncas n the Unted States and obvousy you ust referred to someone n Rome who you caed beeve the genera n Rome. s there any umbrea group wthn the Unted Staes that a ten provncas report to? Q. So ust so that have t cear n my head the provncas n Chcago report to the genera n Rome s that rght? A. That s correot. Q. And how s the genera n Rome chosen? A. We we have what s caed a genera oongregaton and members from a of the provnces around the word meet receve reports from around the word and then ook for someone to become the genera and eect hm. Q. Can the genera n Rome gve specfc drectons to the Chcago Jesuts n terms of what actons they shoud be takng or not takng on a partcuar ssue? 0 Q. s Wsconsn a separate provnce rght now? A. Oh yes. Q. How ong has Wsconsn been a separate provnce? A. thnk snce. The same tme we spt from Detrot Wsconsn spt from Mssour for the same reasons. Q. As far as you know there's an effort that those three provnces w be combned nto a snge provnce s that rght? You nodded your head need an ora'answer. A. Oh 'm sorry. Yes yes.) : Q. That's okay. Do you know when that s expected to take pace? ''. --"""'===-=--"""""F""'-==---""""=-"""" MR. HUEBSCH: Do you understand that queston? A. thnk they hope to accompsh t by THE WTNESS: Yes but guess what 'm tryng. ' " to sort out n my mnd s both the theory and the Q. Do you know where the centra offce of g practce. Theoretcay he coud do that. n those -- of that new regon w be ocated? practce he amost often does not. Let me put t A. do not nor does anybody. ths way he mght wrte a etter to the Socety Q. s the Chcago order a separate ega 'f around the word of whch the Chcago provnce s entty to the best of your knowedge? part of t-- A. Lega yeah. But we'd have to dstngush BY MR. BROOKS: canon aw and cv aw. 0 Q. Sure 0 Q Let's speak as to cv aw frst. A. -- wth the drectve or whatever. But he A. Cv aw.-. rarey tes the Chcago provnce as the Chcago Q. Under the cv aw s t ncorporated n provnce to do or not do anythng. nos? Q. s t far to say that the Chcago Jesuts are a sef-governng nsttuton? A. The Chcago provnce? Q. Yes A. Yes t s. Yes t s. A. Headed by the provnca? Q. Yes. A. Yeah wth the reatonshp but yes. Q. s there some sort of reorganzaton that's beng done wthn the Jesut socety n Amerca currenty? A. Yes. Q Do you know what type of organzaton t's ncorporated as? A. 0()(c) notfor proft don't know whether the term regous s used. don't remember the documents. Q Under canon aw what s ts ega status? : A. don't know. You know t's a separate] entty. What you woud ca t don't know. : Q. Whatever t woud be caed probaby coudn't pronounce anyway. J "'""''''''''''''''' "M"'A"""'''''' ''''''''''"'' -"'""m. '''""..'.'''L''_'"""'-.:'"..""..' """":"_". '.." v"...=<>. """"J (Pages to ) McCorke Court Reporters nc. Chcago nos () -00
0 and ower case. Q. Do you know Why t woud be - strke that. Do you know why you woud be wrtng a etter of ths type gven your poston wth the Jesut order n? A. Yes because of my background n oumasm often drafted etters for Father Brad Schaeffer. He's one of the few provncas dd t for. Q. Were there other provncas you drafted. etters for? A. Not that can remember. Let's see. Who woud the other be? Wd don't thnk so. Baumann don't thnk so. MR. TOOMEY Wat for a queston. BY MR. BROOKS Q. Schmdt have you drafted eters for Father Schmdt? A. Ony offca etters to go to Rome concernng the budget that's a for hm to sgn. Q. Woud Father Schaeffer have dctated ths etter to you and you were ust merey wrtng down hs words or woud you have drafted ths yoursef 0 0 Does seeng ths refresh your memory as to whether or not Father McGure receved any sort of psychatrc treatment n or about? A. We yes but as you can f you compare the etters you' see that even got t wrong and he corrected t to Phadepha. Q. Far enough. But as you st here today do you reca anythng regardng such treatment? Q. Were you nvoved n strke that. Do you know whether the Jesuts requred Father McGure to undergo treatment? Q. So you were not nvoved n that decson? Q.. Dd you ever dscuss Father McGure's treatment wth Father McGure? Q. Dd you ever dscuss Father McGure's treatment wth any of hs menta heath provders? A. remember remember that when he came baok from one of the nsttutons - coudn't 0 and then gven t to hm for sgnature? A. 'm not sure understand the queston. Q. Far enough. As you ook at ths etter here.- strke that. Typcay woud you ust take down dctaton of Father Schaeffer? A. Oh no no no no. Q. So you woud draft the substance of the etter and gve t to hm for revew and sgnature? A. We or to correct or modfy or whatever yes. Q. Do you recognze the name on ths etter? A. Yes t's hs Q. t's Donad McGure's? A. Correct. Q. was a awyer here n Chcago s that rght? A. That's correct yes he was. Q. And athough t's been redacted n both of these etters there's a reference here presumaby to at east one f not two nsttutons n whch Father McGure apparenty receved treatment. 0 0 organzed and was asked to be a member of the support group. And one of the peope from the nsttuton _. can't remember the name of the nsttuton -. expaned our roe but don' remember that he gave us any specfcs of the -. the ness or the treatment or anythng such as that. Q. And you don't remember hs name? Lord no. Q. Who asked you to be part of ths support group? A. don't remember. Q. Were you tod why Father McGure was havng a support group put together for hm? A. thnk t was ust n conuncton wth the recommendaton of the nsttuton. Q. And at that tme dd you earn why he had been treated at the nsttuton? A. Not that can reca. Q. So to the best of your memory you were asked to be part of the support group but you. ddn know the type of treatment that Father McGUre had receved? A. Correct that's my best recoecton. McCorke Court Reporters nc. Chcago nos () -00 '' 0... ''''"'' (Pages 0 to t0t
Q. Have you ever heard the name A. Yes. before Q. -- at Oansus House? A.. thnk so yes. Q. What about the name' (Whereupon FLAHERTY DeposUon Exhbt No. was marked for Q. Do you remember recevng any nformaton. dentfcaton.) n or thereabouts as to whether or not Father BY MR. BROOKS: McGure had been nvoved n a reatonshp wth Q. Ths s a very short one. A rght a. Father. Father Faherty you've been handed what's 0 0 been marked as Exhbt No.. t's a very short Q. Do you remember whether any restrctons memorandum dated March wth a Bates stamp f were put on Donad McGure's.- strke that. number of. t's a memorandum to you among Do you remember f the Jesuts mposed any other peope from Father Gschwend restrctons on Donad McGure ether at the end of G-s-c-h-w-e-n-d and ndcates the meetng wth. J or begnnng of nvovng Father Father Gschwend and the aftercare team s confrmed McGure's behavor wth persons under the age of for :00 o'cock on Wednesday Apr th at 0? North Oark Street. ' You see that don you? : J Q. Were you - do you remember recevng any A. do. nformaton from any Jesut offca that there Q. t refers to the aftercare team. :) were certan restrctons paced on Father McGure? s that the same thng as the support A. don't remember. group you mentoned earer n your testmony? Q. Do you remember any conversatons wth A. 'm sure t s. Donad McGure n or about regardng any Q. And do you see the names on ths 0 0 restrctons paced on hs behavor? memorandum A. do. Q. Who - to the best of your memory who Q... other than yourse ese was vng n Cansus House at that tme? and Father Hardon H-a-r-d-o-n? A. '0? aso members To your knowedge were these Q. Eary? of the aftercare team? A. Mysef Father Joe Downey. Was Perko A. We accept that. was tryng to there by then? suspect Perko. don't thnk remember who they were and coudn't. K nnety (phonetc) was there yet. woud say Q. Does ths refresh your memory that they 0 those three and mysef. 0 were aso on the aftercare team? Q. And at that pont Father Downey was the A. To be perfecty honest wth you st superor s that rght? have no cear recoecton but accept that A. Correct. they were. Q. And Father Downey never had any Q. 'm not mpyng that they were. conversatons wth you regardng restrctons on A. We- Father McGure's behavor?. Q. 'm askng f t refreshes your memory as. to whether or not -- Q. At ths pont n tme whch room wthn. A. 'm ust fgurng that they woudn't have Cansus House dd Father McGure resde n? gotten a copy of ths f they were not. A. The one at the back stars.. Q. Far enough. 'm not gong to argue wth Q. s that the one rght off of the ktchen? that concuson at ths pont. \ A. Yeah.. Do you know whether or not Father Gschwend Q. To your knowedge s that the room he was a member of the aftercare team? aways occuped.- A. thnk not. 0 0B """" '. _."="".\M'''' ""':""" """".-"<.n'"'-""'""""'g<''''''''.. '_w''''<...:"... ''''''"""'...''''.-..'"''''M'"''''''....\.<''''' '''.'''''''''""'-""".""''''''""''''J'-. """""""_"'''''''''''W''''' )' (Pages 0 to 0) McCorke Court Reporters nc. Chcago nos () -00 {
( ( 0 O. Do you know what Father Gschwend's poston wthn the Jesut order was at that pont n tme? A No. thnk thnk he was the assstant for peope that we mentoned earer peope vng outsde the provnce. But he aso thnk asssted the provnca wth -- because of hs background n -- and degree n psychoogy wth certan cases ke ths. But hs exact tte don't remember. Q. And does ths refresh your memory as to what type of treatment Father McGure had receved -- A No. Q. -- n? A No Q. Was t the fact that -- strke that. Dd the fact that ths memo came from Father Gschwend ndcate anythng to you at that tme n terms of what type of probems Father McGure mght have been experencng? A No. Q. Do you reca how many meetngs the aftercare team had? 0 0 whether t was. acoho or God knows what. O. And at ths pont. you and Father McGure had ved together for severa years n Cansus House s that rght? A. Correct. O. Dd you dne together for your evenng mea? A. Rarey. O. What about breakfast or unch. dd you eat together? A. Rarey. O. Why s t that you woudn't have a ot of meas wth hm n the same house? A. We frst of a because he was very often on the road. Secondy because my schedue was totay dfferent. get up at :0 n the mornng and 'm out of the house at :0. go to bed at :0 at nght. When came home after a day at the offce and Father McGure and the Msson Fdes peope or whatever woud be n the ktchen t woud annoy the he out of me. Don't put that n there. t woud annoy me. and woud avod them. That's ust an honest statement. O. That's a 'm askng for. A. One. O. And was t on Apr th by chance? And that's true n the eary 0s as we as ater on n the 0s and eary 00s? A. have to assume that. A. Correct. O. And do you remember anythng about that meetng or what was dscussed? A. My understandng of the meetng was -- and O. At ths pont n was Father McGure nvoved wth the Msson Fdes F--d-e-s organzaton? that's why used the term support group -- A. beeve yes because -- don't O. Rght. remember the date but do remembe _ hs 0 A. -- was that f Don needed to tak to somebody he woud tak to the support group. had no understandng that t was an oversght group n any way. 0 brother heped hm set up that organzaton. O. And do you reca any partcuar person other than Father McGure who was nvoved wth that organzaton? O. And do you remember attendng that A. Oh yes. meetng? O. What were the names? A. remember attendng the meetng.. (sc) O. What happened at that meetng? thnk. and her husband - - A. Ths person from wherever the nsttuton -- don't know f they actuay had you know -- wonder f he was even there. thnk he was or she was. don't remember man or woman. don't remember the specfcs to be honest wth offcers to be honest wth you. That's -- thnk that's t. Anyway they're the ony ones deat wth. you. But my sense was that we were to be hs support group f he had to tak to somebody. But O. At some pont : s that rght? became don't remember that the -- don't remember at a A. beeve so -- we don't beeve so. that we were tod what n fact the probem was Yes. 0 (Pages 0 to ) McCorke Court Reporters nc. Chcago nos () -00 <:.
Q. Was there typcay a group mea at Do you see that? J Cansus House at any pant? A. Yes. ' A. For the communty? Q. Bau s that short for Father Baumann? W Q. For the communty. A. That's correct. A. No no. Q. Father Baumann was the -- Q. Was there a weeky dnner that the -- A. The provnca. Q. -- provnca at that tme s that rght?. Q. Dd you for ack of a better term A. Correct. socaze wth Father McGure at a durng the Q. He's now n South Afrca s that rght? 0 0s? 0 A. -Correct. A. Oh when he woud come home from a trp Q. Do you know f he has any pans to come to you know woud ask hm how thngs went. He Chcago n the near future? ' woud te stores. He was a funny storyteer and A. Not that know of. Hs heath s not : funny. You know we mght spend ten or mnutes. _ very good. 'd ask hm how t went. and he'd say fne. That Q. 'm sorry to hear that. was t pretty much. That ast.. that paragraph we were ust Q. Durng the tme that you were together at referrng to ndcates that Father Baumann dd te Cansus House were you ever nformed of any hm that one step he wants taken mmedatey s restrctons on McGure's behavor mposed by the that the young men currenty workng for Don shoud Jesuts? no onger be present n your resdence at a. A. Not that can reca. Do you see that? (Whereupon FLAHERTY Deposton A. Yes do. : Exhbt NO. was marked for Q. Do you know what that s referrng to? dentfcaton.) A. assume what we've been takng about BY MR. BROOKS: that the young men workng for Don shoud no onger Q. Father Faherty the court reporter has be present n your resdence. handed you a two-page document the frst date of Q. By your resdence that's referrng to ' whch s December th 00. Ths s Bates Cansus House rght? stamped No. through wth the caveat that A. Cansus.House. unke the other documents ths document the Bates Q. And t says the young men currenty : number s on the top rght-hand corner rather than workng for Don do you know specfcay the names the bottom. of those young men t's referrng to? t 'd ask you to take a mnute to revew A. do not. do not. 0 ths e-ma chan pease. 0 Q. And durng ths tme perod.. and we've A. Woud you repeat that? was readng. moved on some years from my ast seres of Q. Sure. That's what 'm askng you to do questons. Now we're nto 00 -- dd you see rght now. Let me know when you're done readng young men come n and out of Cansus House n t the document. connecton wth work they were dong for Donad. You receved ths document? McGure? A. have. MR. HUEBSCH: Do you understand that queston? Q. t's an e-ma chan between Father Perko THE WTNESS: understand that queston but P-e-r-k-o and Father McGurn M-e-G-u-r-n. 'm tryng to put t n a tme frame. coudn't My frst queston s whether or not you've say. seen ths document before? BY MR. BROOKS:. A. have not. Q. At any pont n tme dd you see young ( Q. The ast paragraph of the frs.. or the men go n and au of Cansus House? 'f. ' top e-ma n ths chan starts wth Bob B-a-u dd A. Pror to 00? te hm. MR. HUEBSCH: Let me pose an obecton. When.."""-".-'. """'''''' ''''''''''"''''''''''''''''''''r'''"'''''' ".''''''''"''''''>' """" "". "'''""''k»...o>.""""<".''''a''''''''''.. '''''_."-""" "..._.." ""'""''''':_'''' '"'""''''''''''' =.'.. '.w>"""_' (Pages to ) McCorke Court Reporters nc Chcago nos () -00
you're takng about come n and out of Cansus A. No don't. can't put a date on t. House do you actuay mean enter and ext or do Q.. A rght. But based on ths e-ma dated 'J you mean present n the house? December of 00 do you thnk that you saw young. MR. BROOKS: We you're rght. can be more men workng for Don n the Cansus House pror to precse - that tme? ) MR. HUEBSCH: That was my-- A. 'm sure pror to that tme. You know MR. BROOKS: ' be more precse wth my but Just -- cannot put a start and stop date on anguage. t. BY MR. BROOKS: Q. Far enough. 0 Q. Why don't we start there and ask the 0 Dd anyone te you around ths date that. queston do you remember - et's start wth the Donad McGure shoud not have young men workng tme perod of December of 00 because that's what for hm n the Cansus House resdence? the specfc e-ma refers to. A. Not to my recoecton.. Do you remember at or about that tme Q And as ndcated on ths e-ma at that J : seeng young men present n the Cansus House n tme Mchae Perko was the superor for Cansus connecton wth actvtes they were performng for House? Father McGure? A. Correct. A. reay can't put a date on t. We Q. Do you remember any conversatons wth taked before and taked about how they were Mchae Perko regardng any restrctons put on J. there and t was an annoyance to me. But you Father McGure's behavor? know how often or when or the dates woud be. beyond my recoecton. Q. Dd you personay have any responsbty ) Q. Let's expore that then. for any oversght of Father McGure at that tme? ' You don't -- you do remember seeng young ] men n the house who were workng wth Father Q. Who had such responsbty? : McGure? A. f anyone the superor. ' A. Oh yes. Q. So that woud be Mchae Perko? : Q. But you don't remember ether specfcay A. Uh-huh. ' - or generay what tme perod you frst startng MR. BROOKS: Shoud we take a break now? What : seeng young men n the house workng wth Father tme s t? ' McGure? MR. HUEBSCH: :. A. No -- woud have to say t was after (A short break was taken.) hs operaton. When he -- forget what t was (Whereupon FLAHERTY Deposton J 0 ether cataract or hp or knee or somethng ke 0 Exhbt Nos. & were marked that and t wascear that he needed hep. And t for dentfcaton.) seems to me -- n fact some reference was made to BY MR. BROOKS: ' t n one of these earer eters that snce he Q. Father Faherty the court reporter has needed hep and the parents had gven permsson handed you what's been marked as Exhbt whch they were workng wth hm. s a February 0 memorandum from Rck McGurn Q. Do you remember -- to Mchae Perko wth a carbon copy to Dck A. The dates can't put - can't say Baumann B-a-u-m-a-n-n. t refers n the frst : whether t happened n ' or ' or 00. paragraph to drectves the provnca s gvng ' Q. Rght. 'm ust askng to the best of hm. :\ your abty as we st here today what you reca. My frst queston to you s do you f you don't reca ust et me know. remember seeng drectves gven to Donad McGure A. That's t. That's t. at or about -- on or about February 0? Q. Do you remember when Father McGUre had A. do not. the operaton to whch you're referrng to? Q. Dd you dscuss any such drectves wth """"y'>'-.. _' "<\"-"...... -""""<.>"""''''<.e.. _".... ":.('"">'c.=<_ ""'w."'"''\""... <t'''''m"_.' "''''.''''''' '_>"w.q"''''m''''''''''''''''''''.''''''''''''''.'''''''' ''''''''''' '''o'''''''''"''''''''''''''''"''. < 0 (Pages to ) McCorke Court Reporters nc. Chcago nos () -00
Mchae Perko? the same tme as Father McGure no one ever tod A. dd not. you that there were any drectve ssues wth Q. Or dd you dscuss any such drectves regard to Father McGure's behavor?. wth ether Father Baumann or Father McGurn? A. No to my-- MR. HUEBSCH: Obecton asked and answered MR. BROOKS: Off the record. twce. But go ahead and answer t agan. (A short break was taken.) THE WTNESS: Not to my recoecton. ' BY MR. BROOKS: BY MR. BROOKS: : Q. Let me hand you what's been marked as O. Dd anyone show you the drectves -- :. 0 Exhbt No. whch s a one-page document wth a 0 A. Absoutey not --. Bates No. whch s entted Drectves. O. Let me fnsh. A. Oh t probaby goes wth the etter we MR. HUEBSCH: Wat a mnute. ust saw. (A short break was taken.) : Q. That s the concuson 'm makng gven BY MR. BROOKS:. ) that the date -- O. These wrtten drectves that we see here A. Yeah. on Exhbt No. were not dstrbuted to you s Q. -- of sgnature here s February th that rght? 0.. A. Not to me. MR. TOOMEY: s that? O. Do you know whether t went to anybody MR. BROOKS: Yes. ese n the Cansus House? BY MR. BROOKS: Q. Have you ooked at ths document? O. Dd anyone ever te you that Donad A. have. McGure was not to spend a nght n the same room Q. Do you know why these drectves were wth any man or woman under the age of 0 years ssued? od? A No asde from the fact that the provnca was unhappy wth hs performance O. Dd anyone ever te you that Donad thnk. McGure was not to have or utze an executve Q. They were unhappy wth hs performance or assstant n the performance of hs dutes or unhappy wth hs behavor? mnstres? MR. HUEBSCH: The queston orgnay was do A No. S you know why ths was ssued? Q. Dd anyone ever te you that Donad.THE WTNESS: do not. McGure was not to have assstance n hs Jesut 0 BY MR. BROOKS: 0 resdence? O. And other than revewng the February th 0 memorandum whch has been O. Do you reca seeng any of Donad marked as No. do you know who was nvoved wth McGure's assstants n hs resdence after ssung these drectves? February th 0? A. Wet ooks to me ke -- what does t A. can't honesty answer the queston wth say there? presented hm wth the drectves the the date no. provnca s gvng hm. That's a know. O. Dd Father McGure frequenty have O. That's your concuson based on your assstance n the Cansus resden.cy durng the revew of No.? tme that you two ved together? A Correc\. A. We yes when he was back from hs O. Do you have any ndependent knowedge as trps. You know the Msson Fdes peope woud be to why these drectves were ssued? ovar at the house whether - whatever you want to A.. do not. ca them assstants or not. O. And whe you were at Cansus House at Q. When we say Msson Fdes peope we're ""''''' '''''''''''''''''''''''''''.'''''''' b'''\ "''''''''''""»M' "o" ="''''*. '" "'W""hM """""''''''''''''''''''\'''''''''''''''''_"''''W''\''''"""""'''M''''.'''' 'OM' ''''''''''''_'''''''"''''' (Pages to ) McCorke Court Reporters. nc Chcago nos () -00 )