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1 1 COMMONWEALTH of MASSACHUSETTS 2 COUNTY of MIDDLESEX 3 GREGORY FORD, Et Al., Plaintiffs, 4 Superior Court Vs

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1 1 COMMONWEALTH of MASSACHUSETTS 2 COUNTY of MIDDLESEX 3 GREGORY FORD, Et Al., Plaintiffs, 4 Superior Court Vs 1 1 COMMONWEALTH OF MASSACHUSETTS 2 COUNTY OF MIDDLESEX 3 GREGORY FORD, et al., Plaintiffs, 4 Superior Court vs. Civil Action 5 No. 02-0626 BERNARD CARDINAL LAW, a/k/a 6 CARDINAL BERNARD F. LAW, Defendant. 7 --------------------------------- PAUL W. BUSA, 8 Plaintiff, 9 vs. Civil Action No. 02-0822 10 BERNARD CARDINAL LAW, a/k/a CARDINAL BERNARD F. LAW, et al. 11 Defendants. ------------------------------------- 12 ANTHONY DRISCOLL, Plaintiff, 13 vs. Civil Action 14 No. 02-1737 BERNARD CARDINAL LAW, a/k/a 15 CARDINAL BERNARD F. LAW, et al. Defendants. 16 17 THE VIDEOTAPED DEPOSITION OF CARDINAL BERNARD F. LAW, a witness called by the 18 Plaintiffs, taken pursuant to the applicable provisions of the Massachusetts Rules of Civil 19 Procedure, before Kathleen M. Silva, Registered Professional Reporter and Notary Public in and 20 for the Commonwealth of Massachusetts, at the offices of Greenberg Traurig, One International 21 Place, Boston, Massachusetts 02110, on Wednesday, June 5, 2002, commencing at 10:06 22 a.m. 23 K. L. GOOD & ASSOCIATES P. O. BOX 6094 24 BOSTON, MASSACHUSETTS 02209 TEL. (781) 598-6405 - FAX (781) 598-0815 2 1 APPEARANCES: 2 Greenberg Traurig (by Roderick MacLeish, Jr., Attorney, Robert 3 Sherman, Attorney, David G. Thomas, Attorney, Courtney Pillsbury, Attorney, and Gina Dines 4 Holness, Attorney) One International Place 5 Boston, Massachusetts 02110 Attorneys for the Plaintiffs 6 Jeffrey A. Newman, Attorney 7 One Storey Terrace Marblehead, Massachusetts 01945 8 Attorneys for the Plaintiffs 9 The Rogers Law Firm, PC (by Wilson D. Rogers, Jr., Attorney, Wilson D. 10 Rogers, III, Attorney, and Mark C. Rogers, Attorney) 11 One Union Street Boston, Massachusetts 02108 12 Attorneys for the Defendants 13 Todd & Weld (by J. Owen Todd, Attorney) 14 28 State Street Boston, Massachusetts 02109 15 Attorneys for Cardinal Law personally 16 ALSO PRESENT: Colleen Surrette 17 Diane Nealon Rodney Ford 18 Paula Ford Anthony Driscoll 19 Andrew Magni Father John Connolly 20 Father Christopher Coyne Sandy Grossman 21 George Libbares Wayne Martin 22 23 24 3 1 2 WITNESS 3 Page BERNARD F. LAW 10 4 EXAMINATION BY MR. MacLEISH 5 DIRECT EXAMINATION 11 6 7 INDEX OF EXHIBITS 8 1 Complaint and Jury Demand 5 9 2 Answer of the 5 Defendant Bernard 10 Cardinal Law to Plaintiffs' Complaint 11 3 Review Board 36 12 Memorandum, Case No. 62, 2/5/96 13 4 Document 40 14 5 Review Board Meeting Notes, 45 15 6/5/95 16 6 Memorandum 62 17 7 Excerpt of 72 Deposition of Charles 18 Higgins 19 8 The Five Principles to 79 Follow in Dealing with 20 Acusations of Sexual Abuse 21 9 Document 86 22 10 Letter, 6/1/02 115 23 24 4 1 INDEX OF EXHIBITS 2 11 Responses of the Defendant, 135 Bernard Cardinal Law, 3 to Plaintiffs' Requests for Admissions 4 12 Statement, 5/20/02 147 5 6 13 Document 147 7 14 Report to Cardinal Cushing 171 of 1964 Re: Eugene 8 O'Sullivan 9 15 Handwritten Document 181 10 16 Globe Article 184 11 17 Note 199 12 18 Letter, Received 5/2/85 207 13 19 Letter, 5/15/85 217 14 20 Letter, 6/4/85 221 15 16 17 18 19 20 21 22 23 24 5 1 P R O C E E D I N G S 2 (Law Exhibit No. 1, Complaint and 3 Jury Demand, marked for 4 identification.) 5 (Law Exhibit No. 2, Answer of the 6 Defendant Bernard Cardinal Law to 7 Plaintiffs' Complaint, 8 marked for identification.) 9 THE VIDEOGRAPHER: We are now 09:55:40 10 recording and on the record. My name is George 10:06:31 11 Labbares. I'm a certified legal video 10:06:34 12 specialist for National Video Reporters, 10:06:37 13 Incorporated. Our business address is 58 10:06:39 14 Batterymarch Street, Suite 243, Boston, 10:06:43 15 Massachusetts 02110. Today is June 5, 2002, 10:06:46 16 and the time is 10:06 a.m. 10:06:56 17 This is the deposition of Cardinal 10:06:59 18 Bernard Law in the matter of Gregory Ford, et 10:07:02 19 al., Plaintiffs, versus Cardinal Law, a/k/a 10:07:06 20 Cardinal Bernard F. Law, Defendant, and Paul W. 10:07:11 21 Busa, Plaintiff, versus Cardinal -- versus 10:07:16 22 Bernard Cardinal Law, a/k/a Cardinal Bernard F. 10:07:21 23 Law, et al., Defendants, and Anthony Driscoll, 10:07:27 24 Plaintiff, versus Bernard Cardinal Law, a/k/a 10:07:32 6 1 Cardinal Bernard Law, et al., Defendants, in 10:07:37 2 the Commonwealth of Massachusetts, County of 10:07:40 3 Middlesex. 10:07:43 4 This deposition is being taken at One 10:07:45 5 International Place, Boston, Massachusetts, on 10:07:51 6 behalf of the plaintiffs. The court reporter 10:07:51 7 is Kathleen Silva with K. L. Good and 10:07:54 8 Associates of Post Office Box 6094, Boston, 10:07:58 9 Massachusetts 02209. 10:08:03 10 Counsel will now state their 10:08:07 11 appearances and the court reporter will 10:08:09 12 administer the oath. 10:08:10 13 MR. MacLEISH: Roderick MacLeish, 10:08:12 14 Jr., for the plaintiffs. 10:08:12 15 MR. THOMAS: David Thomas for the 10:08:16 16 plaintiffs. 10:08:17 17 MR. SHERMAN: Robert Sherman for the 10:08:19 18 plaintiffs. 10:08:19 19 MR. NEWMAN: Jeffrey Newman for the 10:08:19 20 plaintiffs. 10:08:21 21 MR. MARK ROGERS: Mark Rogers on 10:08:21 22 behalf of all defendants, including His 10:08:23 23 Eminence, Cardinal Bernard Law. 10:08:24 24 MR. ROGERS III: Wilson Rogers, III, 10:08:26 7 1 on behalf of Cardinal Bernard Law and all the 10:08:27 2 defendants. 10:08:29 3 MR. ROGERS, JR.: Wilson Rogers, Jr., 10:08:29 4 on behalf of His Eminence, Cardinal Law, and 10:08:31 5 all the defendants. 10:08:32 6 MR. TODD: Owen Todd on behalf of the 10:08:34 7 Cardinal personally. 10:08:36 8 MR. MacLEISH: Before you do the 10:08:39 9 oath, we have some stipulations for the record. 10:08:39 10 As I understand it, we are stipulating that all 10:08:40 11 objections except as to form and motions to 10:08:42 12 strike are reserved in this case until the time 10:08:44 13 of trial. 10:08:45 14 Mr. Todd, you also want to make 10:08:47 15 another stipulation? 10:08:49 16 MR. TODD: That prior stipulation 10:08:49 17 will apply to the audio-visual deposition as 10:08:51 18 well. 10:08:54 19 MR. MacLEISH: That's correct. 10:08:54 20 Mr. Rogers, you also wanted to make a 10:08:55 21 continuing objection on First Amendment 10:08:57 22 grounds; is that correct? 10:08:59 23 MR. ROGERS: Yes. We would interpose 10:09:00 24 an objection as to any questions going to the 10:09:02 8 1 internal workings of the Church, and to obviate 10:09:05 2 the need of raising it on an ongoing basis, I'd 10:09:08 3 like to agree we have a continuing objection to 10:09:11 4 this line of inquiry. 10:09:12 5 MR. MacLEISH: We have such an 10:09:13 6 agreement. 10:09:15 7 Could you swear the witness in. 10:09:15 8 MR. TODD: And the objection of one 10:09:16 9 party will stand for all parties, correct? 10:09:18 10 MR. MacLEISH: That's acceptable. 10:09:20 11 MR. ROGERS: Did we -- is it clear on 10:09:22 12 the record that this deposition applies in four 10:09:24 13 cases? 10:09:26 14 MR. MacLEISH: Yes, it is. 10:09:27 15 MR. ROGERS: I'm not sure when we 10:09:28 16 did -- 10:09:29 17 MR. MacLEISH: Yes, it is. That's my 10:09:30 18 prior agreement with your son. It also applies 10:09:32 19 to the case of Andrew Magni as well. 10:09:33 20 Are we ready to swear the witness in? 10:09:36 21 BERNARD F. LAW 22 was sworn on oath by the reporter. 23 ********* 24 9 1 DIRECT EXAMINATION BY MR. MacLEISH 10:09:49 2 Q Good morning, Your Eminence. 10:09:49 3 A Good morning. 10:09:51 4 My name is Eric MacLeish and I'm counsel 10:09:52 5 for the plaintiffs in these actions. To my 10:09:54 6 right is Paula Ford, who is also a plaintiff. 10:09:57 7 To my left is David Thomas, Robert Sherman, 10:09:59 8 Mr. Rodney Ford, who is also a plaintiff, 10:10:01 9 Attorney Jeffrey Newman, Andrew Magni, who is a 10:10:04 10 plaintiff in another case, but is here by 10:10:07 11 agreement of the defendants, and Anthony 10:10:08 12 Driscoll. Both Mr. Magni and Mr. Driscoll are 10:10:11 13 victims of Father Shanley. 10:10:14 14 I'd like to thank you first for coming in 10:10:16 15 here, and as is typical in depositions, I'd 10:10:18 16 like to go over a few ground rules.
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