IICSA Inquiry Roman Church Investigation Wider Hearing 8 November 2019

1 Friday, 8 November 2019 1 I indicate, therefore, there are some additional 2 (10.30 am) 2 statements from the NCSC witnesses, both past and 3 THE CHAIR: Good morning, everyone. Welcome to the final 3 present, from Rachel O'Driscoll, Elizabeth Manero, whom 4 day of this public hearing. Ms Carey? 4 we have heard of, and a past member called 5 Housekeeping 5 Susie Hayward. 6 MS CAREY: Good morning, chair. Before we turn to closing 6 From Ofsted there is a statement of Sean Harford. 7 submissions on behalf of the core participants this 7 Chair, you will be familiar with Adrian Child. There is 8 morning, may I deal with one matter of formality? 8 an additional statement from the former director of 9 During the course of this two-week public hearing, there 9 CSAS. In addition to the statements read out yesterday 10 has been reference to a number of documents, statements 10 in relation to formation, the inquiry intends to publish 11 and exhibits that will be published on the inquiry 11 those statements from Reverend Taylor, 12 website, and a list is going to be published on the 12 Monsignor Whitmore and, indeed, Canon Farrer and 13 website later today, along with the unique Relativity 13 Canon Coyle, whom you heard from yesterday. 14 references for those documents. 14 Chair, in respect of the review by the Westminster 15 A number have already been referred to during the 15 Diocese of the safeguarding file in respect of RC-A711, 16 course of the live evidence, but there are some 16 Monsignor O'Boyle's statement will be published. And in 17 additional statements that I need to deal with this 17 respect of RC-A710's case, the statement of 18 morning. 18 Baroness O'Loan will also be published. All of those 19 The inquiry intends to publish the statements of 19 documents will be available on the inquiry website. 20 Reverend Christopher Thomas at CHC000582, INQ004770, in 20 Chair, it is not the intention of counsel to the 21 relation to the background and structure to the church. 21 inquiry to make any closing submissions to you. Can 22 The statement of Dom Yeo at BNT004910 that gives the 22 I invite, then, that we turn to Mr O'Donnell to make the 23 background to the orders and in particular to the 23 first closing submission? 24 English Benedictine Congregation will be published. 24 THE CHAIR: Thank you, Ms Carey. Mr O'Donnell? 25 I'm told I don't need to read out the URNs. Can 25

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1 Closing statement by MR O'DONNELL 1 began inserting his fingers into her. 2 MR O'DONNELL: Chair, thank you. As you know, I act for the 2 A19 was first able to disclose the abuse 3 Slater & Gordon survivors in this case study. I propose 3 in August 2014. She brought a claim for compensation 4 in this closing to address you, firstly, briefly on 4 which then brought her into contact with various members 5 their evidence and also on the fact that, despite all of 5 of the Roman . She met with the director 6 its promises of learnings and improvement, the fact that 6 of the Catholic Safeguarding Advisory Service, 7 the Roman Catholic Church remains as dangerous a place 7 Colette Limbrick, in April 2019. She was told that 8 for children now as it was before this inquiry began. 8 there was no national or independent body to investigate 9 A19 and 20 first. They were both abused by a Roman 9 complaints within the church and that responsibility for 10 Catholic priest of the Salesian Order, RC-F515. A19 was 10 that was with the individual dioceses. Various 11 treated badly by her father after the death of her 11 exchanges follow and A19 soon came to feel that she was 12 mother, effectively being abandoned by her family and 12 being given the run-around by the church. 13 was left mentally vulnerable as a result. A maternal 13 A20 was also sexually abused by F515 during 14 cousin contacted her and recommended she see F515 who 14 purported counselling sessions that he provided to her 15 was described to her as a psychologist as well as 15 when she was a child. F515 had advised A20's parents 16 a priest. She agreed immediately and she met F515 at 16 that she needed to see him for these sessions every 17 his offices. He arranged to meet her every week 17 Saturday at his offices and also that they shouldn't ask 18 thereafter and began to sexually assault her. He forced 18 her about these sessions, just as A20 was instructed not 19 A19 to remove all of her clothing and then lie on his 19 to speak about them to anyone as well. He met A20 once 20 sofa and told her he was hypnotising her before sexually 20 a week, made her strip naked and lie down before 21 assaulting her. He often plied her with alcohol. On 21 massaging her front and back. Then he penetrated her 22 one occasion, after forcing her to strip and then 22 vagina with his fingers. He always finished by giving 23 sexually assaulting her on his sofa as usual, he grabbed 23 her a chocolate biscuit and a wet kiss on the lips, 24 her and laid her across his lap and struck her 24 before telling her that the sessions were for her own 25 repeatedly on the rear, laughing as he did so. He soon 25 good. They continued like this for years, until A20 was

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1 brave enough to stop attending, after which she told her 1 where the visitors entered the building, another priest 2 mother what F515 had been doing to her. Her mother 2 walked in on them and observed the abuse. Again, chair, 3 complained to a more senior Catholic priest in London. 3 you won't be surprised by now to hear that this priest 4 By now, it will come as no surprise to you, chair, to 4 simply turned around and walked out again without 5 hear A20's mother was told to go away and pray for F515 5 a word. 6 and not to bring any scandal on the church. A20 tried 6 A711 tried to escape F500 after he went on a course 7 to commit suicide on multiple occasions during the 7 to Rome. When he returned, he turned up at her home and 8 weekly abuse. Her education faltered and she left home 8 raped her. She reported the abuse to the church 9 when she was still a child and moved into a squat. She 9 in October 2016. A church safeguarding coordinator 10 continues to suffer, as a result of the abuse, to this 10 contacted her and said she could either go the criminal 11 day. 11 route or let the church investigate her allegations. 12 The panel didn't hear from A19 or A20, but it did 12 She told the panel on 29 October that it was suggested 13 hear from our survivor A711. We say that she was, on 13 to her it would be a less stressful experience to let 14 any view, a calm, dignified and considered witness, even 14 the church, rather than the police, investigate, so of 15 when she was describing being raped by her abuser, F500, 15 course she did. 16 a priest in her . I invite you to make findings 16 Her complaint was transferred from her home diocese 17 about the manner in which A711 gave her evidence for 17 to the Westminster Diocese a few months after she first 18 reasons I will come to shortly. 18 came forward. As she put it in her evidence, she 19 She was 15 years of age when she was groomed by 19 expected to see Catholic safeguarding practice at its 20 F500. He began to sexually abuse her by holding her 20 best, as she had been transferred into Cardinal Nichols' 21 forcefully against his erection when they were both in 21 jurisdiction. Her experience was far from that 22 the swimming pool. The abuse escalated. Soon she was 22 expectation. She described how, "Over the best part of 23 being forced to perform oral sex on him at her local 23 two and a half years, I came face to face with the 24 church priory. On one such occasion, while he was 24 church at its most defensive and protective of its own. 25 abusing A711 in the parlour at the front of the priory, 25 I felt that I was in the wrong and every step in the

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1 process to have information shared with me was an 1 Westminster that made her feel like she was being kicked 2 exhausting battle." 2 from pillar to post. 3 She was told by the safeguarding coordinator of her 3 I referred to A711's demeanour during her testimony 4 own diocese, as you will remember, that 4 as being calm, dignified and considered. I say the same 5 a church-instructed forensic psychologist was going to 5 point applies to her written exchanges with the church, 6 risk assess her abuser and that she would be given 6 all of which were polite, I say, to a fault. 7 immediate verbal feedback from that assessment on 7 Following her efforts with Westminster, A711 was 8 whether or not her abuser had admitted anything during 8 still so frustrated by its lack of any proper response 9 the assessment, which was obviously of massive 9 to her concerns that 11 months ago she made a subject 10 importance to her after the years of abuse. The risk 10 access request, as you know. She discovered she was 11 assessment eventually occurred after her case had been 11 being described by the church behind the scenes as 12 transferred to the Westminster Diocese. 12 "deeply manipulative" and "a needy victim", who was 13 After the transfer, Westminster simply told her that 13 generating a passive-aggressive threat that, "If we 14 there would be no feedback. The whole "One Church" 14 don't do what she wants, she will cause trouble", such 15 approach, as it has been described, was starting to seem 15 that the Westminster Diocese should "keep playing the 16 to her like a nonsense. 16 good practice card if we are to contain this person's 17 In May 2017, she went to Cardinal Nichols in his 17 manipulative behaviour". That last comment came from 18 capacity as of the Westminster Diocese, of 18 Peter Houghton, the chair of the Westminster 19 course, to complain. She then wrote to him again 19 Safeguarding Commission, a man who remains in that post 20 repeatedly, as you heard. She was directed by 20 today. So not only was A711 being given the run-around 21 Cardinal Nichols' private secretary to the National 21 by the Westminster Diocese, she was also being insulted 22 Catholic Safeguarding Commission, but the NCSC told her 22 by its safeguarding team behind the scenes at the same 23 it had no jurisdiction over individual dioceses, 23 time. 24 effectively leaving her with nowhere to go. 24 The panel hasn't heard any further evidence from the 25 So she ended up in a pointless back and forth with 25 survivor A117 in this case study, but, chair, you will

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1 remember hers was the incredibly powerful evidence in 1 covered up or failed to act when hearing about abuse by 2 the Ampleforth and Downside hearings in 2017 when she 2 those within the church's ranks. Yet again, A117 felt 3 described being abused by the English Benedictine 3 like she was being given the run around. She describes 4 Congregation priest, F80, after he groomed her during 4 her experiences of making a formal complaint to the 5 a pilgrimage to Lourdes. The panel will recall her 5 Westminster Diocese as a result of the way in which she 6 evidence on how her complaint was passed between 6 was treated as showing, as she put it, more than 7 Cardinal Hume and the ex-headmaster and and 7 anything, the Catholic Church does not see coverup, 8 Downside, Aidan Bellinger, and how Abbot Bellinger was 8 collusion or awareness of abuse and failing to act as 9 found by both the police and by COPCA to have failed to 9 a safeguarding concern because, to quote them, "it is 10 assist the investigation into her complaint of sexual 10 not criminal". 11 abuse. When A117 has produced an updating statement for 11 So what are the Catholic Church's actual national 12 this fourth case study setting out her experiences since 12 policies on the reporting of child sexual abuse? Well, 13 she gave evidence to the inquiry back in 2017, she 13 two points. Firstly, we say the church's national 14 describes having a meeting with the head of the English 14 policies are simply not fit for purpose. Put simply, 15 in September 2018. She was then contacted 15 because of the widespread use of the word "should" 16 by a safeguarding officer from the Westminster Diocese. 16 rather than "must" throughout those policies, members of 17 As a result, exchanges with the diocese then followed in 17 the church can continually deliberately cover up abuse 18 2018. A117 asked during those exchanges how many of the 18 whilst still claiming full compliance with the 19 diocesan priests were safeguarding trained. She was 19 guidelines. Given the substantial past history of child 20 told that the church couldn't share that information. 20 sexual abuse within the Catholic Church, we say that the 21 She was then told that every diocese was advised on 21 discretionary nature of its national policies means 22 safeguarding by the Catholic Safeguarding Advisory 22 there can't be any genuine determination on the part of 23 Service, CSAS. She was also told that CSAS 23 the church to get to grips with the crisis of 24 recommendations were only ever treated as a guide and 24 child abuse within its ranks. 25 that there was no policy on members of the church who 25 Second, there has been what we say is a wholly

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1 inadequate rollout and implementation of their actual 1 Let's leave that document to one side and consider 2 policies. Neither the National Catholic Safeguarding 2 what actually occurs in practice. The key point here is 3 Commission, the NCSC, nor the Catholic Safeguarding 3 that, as far as we are aware, there's never been 4 Advisory Service have any powers to impose their 4 a member of the Catholic Church who has admitted to 5 policies on individual dioceses or religious orders. 5 sexually abusing children in confession and then 6 That means there's no continuity at all of safeguarding 6 self-reported to the police thereafter. Not one. If 7 practice in the Catholic Church in England and Wales, as 7 a priest hears a penitent -- that's the person who is 8 indeed A711 and A117 have discovered recently, to their 8 confessing -- to abusing children in confession, there's 9 own psychological cost. 9 no penalty or sanction to make that priest insist to the 10 But what does the Roman Catholic Church do when 10 abuser that he reports the abuse on to the proper 11 information about child sexual abuse does come to light? 11 authorities. Canon law only provides one penalty in 12 Well, any assessment of that question I say needs to 12 relation to the confessional, and that penalty applies 13 consider the confessional on which the panel heard 13 to the priest who hears a confession but fails to keep 14 evidence from Monsignor Gordon Read in this case study, 14 it absolutely secret in accordance with the sacramental 15 amongst others. The church has no formal policy on the 15 seal. At present, any priest who hears a penitent 16 seal of confession. The nearest it gets to a formal 16 admitting to abusing children during a confession dare 17 policy is a guidance document produced by the National 17 not go to the police because, if he does, as 18 Catholic Safeguarding Council in June 2019. That 18 Monsignor Gordon Read said in his evidence on 19 guidance effectively says that someone who admits to 19 4 November, the priest will be automatically 20 abusing children during confession should be advised to 20 excommunicated. If a priest hears in confession that 21 repeat their admission to the statutory authorities. 21 a penitent has abused children, the priest can still 22 "Should", not "must". That's it. That guidance is only 22 grant the abuser absolution at the end of 23 five months old, chair. There's no indication of any 23 the confession. He can still forgive the penitent in 24 guidance existing before that document was produced 24 the eyes of God for the sexual abuse he has just heard 25 in July of this year. 25 about, because there is no church rule that stops this.

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1 We say all of this obviously undermines the 1 I have addressed you on, and also about the case of F710 2 paramountcy principle -- the legal principle that the 2 whom I came to represent during the course of this case 3 interests of children must, of course, be given primacy. 3 study. Rather than going into the details of F710's 4 It would appear from his evidence yesterday that 4 case here, which of course were addressed in his 5 Cardinal Nichols himself accepts this, as did 5 evidence yesterday, I would invite you, chair, to 6 Monsignor Read at the end of his evidence on 4 November. 6 conclude that the cardinal's claims to be focused 7 To be clear on this, as matters stand, if a penitent 7 principally on A710's welfare were entirely 8 confesses to a priest that he sexually abused a child, 8 unconvincing. 9 the priest hearing that confession is compelled by Canon 9 It is obvious from Doyle's account of his 10 law not to report that sexual abuse to the police. If 10 conversation with Cardinal Nichols that the cardinal's 11 he does report it, even if that report leads to the 11 overwhelming motivation and concern was to protect the 12 proper criminal conviction of the abuser, he would then 12 . The welfare of A710 was not his focus and his 13 be excommunicated, without due process or disciplinary 13 attempt to persuade you otherwise yesterday was entirely 14 proceedings, the instant the church found out about his 14 implausible. 15 actions. 15 When asked about the impact of the leak, he said the 16 What about the culture within the Catholic Church in 16 person whose confidence had been betrayed most 17 the modern era? It's been said to this inquiry before 17 explicitly was Cardinal Cormac Murphy-O'Connor. 18 that cultural change starts at the top and works down, 18 Everybody was waiting for him to say "and A710", but the 19 the example being from an organisation and institutional 19 words never came. He didn't appear to care whether or 20 leaders. Cardinal Nichols is the most senior 20 not A710 had been betrayed. So we say it seems pretty 21 Roman Catholic in England and Wales and he gave 21 plain on his evidence on these events that the head of 22 evidence, as you know, on Wednesday and Thursday. As 22 the Roman Catholic Church in England and Wales remains 23 well as saying that the church would reject any attempt 23 more concerned with the reputation and well-being of his 24 to compel priests to break the seal of confession, he 24 church leaders than he does with the survivors. 25 was asked about his handling of A711's case, which 25 Cardinal Nichols first gave evidence to the inquiry

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1 during the Birmingham Archdiocese investigation. He 1 as no real change had come from within. I recall saying 2 then issued a press statement on 21 June this year after 2 then it was far more likely the church would continue to 3 that, following your inquiry report on that 3 give the outward appearance of prioritising the 4 investigation. He stated in that press statement that 4 safeguarding of children from sexual abuse whilst, in 5 since 2001, the Catholic Church has adopted the 5 practice, it would do nothing to stop the type of 6 recommendations of the Nolan Review "including passing 6 appalling behaviour about which you have heard evidence. 7 on all allegations of abuse immediately to the police to 7 Two years later, the evidence heard in this final case 8 investigate". Well, that statement appeared to 8 study rather suggests that that submission was accurate. 9 demonstrate a change in the Catholic Church's approach 9 The outward appearance of the Catholic Church during the 10 and culture when it comes to dealing with child 10 period of this inquiry's investigation has been to say 11 safeguarding in the modern era. But the evidence of 11 the right things, to tell everyone it's listening and on 12 A711 that we heard in this case study indicates that 12 a learning curve, whilst, in reality, we see that 13 that statement is actually dishonest. When she reported 13 survivors are still being kicked from pillar to post, 14 being abused, and that included her reporting being 14 criticised behind the scenes by the very individuals who 15 raped by the priest F500, the response of the first 15 are tasked with safeguarding them and ultimately given 16 Catholic Church safeguarding coordinator to whom she 16 the run-around in the hopes their complaints will just 17 spoke was not to pass on the allegations of abuse 17 go away. 18 immediately to the police; instead, she was effectively 18 A117 was told that a failure to report abuse within 19 pressured into not going to the police and having the 19 the church is justified because such a failure isn't 20 church deal with her allegations internally. 20 criminal. The obvious conclusion to draw from this 21 But to conclude, chair, this is the fourth and final 21 final case study is that a failure to report needs to be 22 IICSA investigation into the Roman Catholic Church. The 22 made criminal by means of an externally enforced 23 first took place two years ago, as I have said, in 2017. 23 mandatory reporting law. I'm not going to go on about 24 I addressed you then on the need for the Roman Catholic 24 that again now, but no exceptions to this should be made 25 Church to be forced into a cultural change from outside 25 for what is said in the confessional. As I said to the

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1 panel two years ago, mandatory reporting has worked to 1 the Charity Commission and a body to take control of 2 protect children in other countries and it will work 2 the gaps in legislation which are not filled by Ofsted, 3 here, and listening, indeed, to the often shocking 3 ISI, DfE and the Charities Commission in relation to 4 testimony of Cardinal Nichols on Wednesday and Thursday, 4 suspicions of abuse, particularly in schools. The lack 5 it would appear that the Roman Catholic Church needs to 5 of a safeguarding regulator or powers for these bodies 6 be brought in line by such a law as much now as ever. 6 on safeguarding was demonstrated by failures at 7 Thank you very much. 7 Ealing Abbey and Downside. 8 THE CHAIR: Thank you, Mr O'Donnell. Mr Greenwood? 8 We will recommend the extension of position of trust 9 Closing statement by MR GREENWOOD 9 offences and will expand upon this in our written 10 MR GREENWOOD: Chair and panel, on behalf of the core 10 submission. We agree with Adrian Child when he said to 11 participants that we represent, we say that the 11 you on 13 December 2017, "I don't see any value in 12 Catholic Church has proved itself incapable of 12 tinkering around the edges and saying, 'Here you are, 13 self-governance in the protection of children in its 13 here is a third opportunity post Nolan and Cumberlege. 14 care. We emphasise the impediments to self-governance 14 Go away and sort this out yourself'. There needs to be 15 presented by Catholic teaching, divine law and Canon 15 accountability and some kind of mandatory enforcement". 16 law, its hierarchical structure and reliance on one man 16 That was almost two years ago. 17 at the head of each diocese as decision maker, its 17 During the currency of this inquiry, we saw 18 culture of brotherhood, deference and forgiveness and 18 Peter Houghton, chair of the Safeguarding Commission in 19 its unincorporated status. We recommend, in summary, an 19 Westminster, comment about A711 in May 2017. "We need 20 adoption into law of mandatory reporting as advocated by 20 to keep playing the good practice card if we are to 21 the organisation Mandate Now; the creation of a new 21 contain this person's manipulative behaviour". This is, 22 statutory body with powers to police and enforce basic 22 at best, hypocritical. At worst, it reveals a deep 23 standards of child protection; we envisage a body 23 cynicism towards complainants and safeguarding in 24 similar to the Health and Safety Executive. 24 general. 25 We suggest a review of the powers of 25 Take the troubling evidence of Vincent Nichols as an

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1 example. Mr Altman identified that, in one breath, he 1 the and heads of religious come together at any 2 was announcing publicly positive measures, whilst at the 2 time in the last ten years and demonstrated a commitment 3 same time completely ignoring an intelligent woman with 3 to safeguarding by handing over accused clergy to the 4 a legitimate request for help. 4 police, kicking them out of their church, casting aside 5 If this is the attitude and practice of the leader 5 Canon law secrecy and showing that they had achieved the 6 of the Catholic Church, a man at the heart of Nolan, 6 recommendations of Nolan and Cumberlege in every diocese 7 Cumberlege and well trained in safeguarding, what hope 7 and religious community, we may have given them 8 can we place in anyone else in the church? 8 a chance. The church's processes, training and 9 The inquiry has only had the time and capability to 9 attitudes need radical change. The church is not 10 expose a small fraction of the duplicitous behaviour of 10 radical. It is deeply conservative. It is not fit to 11 the Catholic Church. What would be unearthed if all the 11 be in charge of developing and enforcing its own 12 men in black were genuinely penitent and handed over all 12 safeguarding standards. 13 their scandals to the inquiry? 13 We hear from a number of witnesses that the seal of 14 Catholic organisations have run out of excuses. The 14 confessional cannot be broken and outranks Canon law. 15 time has long gone when those I represent were prepared 15 Rome will never order the breaking of the seal of 16 to give them a chance to get it right. We have seen 16 the confessional where reports of child sex abuse are 17 a painful catalogue of abuse and coverup facilitated by 17 admitted. It has been recorded in evidence to the 18 their internal rules, self-protection and bonds of 18 Australian Royal Commission that some Catholic priests 19 brotherhood. We hear again that more time is needed for 19 would rather be imprisoned than break the sanctity of 20 the Safe Spaces support project, more time for 20 the confessional. The Catholic Church's absolutist 21 Cumberlege, to wait for the general decree, more time 21 position on the confessional highlights the particular 22 for the Ian Elliott review. Even Mr Spears told us, 22 danger of this institution to children in its care. 23 "There is normal time and there is church time". With 23 They accept that it violates the paramountcy 24 the lack of audits between 2015 and 2018, it seems that 24 principle; at the same time, they are prepared, 25 time was standing still for Catholic safeguarding. Had 25 according to Vincent Nichols, to die for it. Even the

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1 Anglican Church is prepared to accept mandatory 1 a bishop or possibly that the bishop will be contacted 2 reporting, with no exception for the confessional. Both 2 by the CDF. This is no sanction at all. Diocesan 3 Eileen Shearer of COPCA and Jane Dziadulewicz, the 3 safeguarding coordinators will remain powerless. Their 4 Clifton safeguarding advisor, made it clear that they 4 bishop will still overrule them. We know from 5 were frustrated that guidance by CSAS was simply that: 5 Jane Bertelson that some bishops are still hostile to 6 advisory only. Common themes emerged from the evidence 6 CSAS and its rules from outside. This is an 7 of the senior social worker, Mr Molesworth, the director 7 organisation that trusts only its own. It prefers those 8 of COPCA, Mrs Shearer, and the Clifton safeguarding 8 who have demonstrated blind loyalty and views inimical 9 advisor. Each cited barriers to achieving good 9 to child safety, like Jane Jones in Birmingham and 10 safeguarding within the EBC abbeys and schools as being 10 Peter Houghton in Westminster. It will try to sideline 11 the CSAS lack of power to enforce the guidance; 11 internal critics, such as Messrs Hayward, Child and 12 exploiting this lack of sanctions by obfuscating on lack 12 Sullivan. Dissent is not encouraged. Whistleblowers 13 of disclosure and access, clergy reluctant to allow 13 are not tolerated. 14 outsiders in. Mr Molesworth himself described 14 I hesitate to pick apart the many written rules and 15 Ampleforth as secretive and resentful of his 15 contradictions which even the chair of the NCSC was 16 presence. They found too much emphasis on forgiveness 16 obviously struggling to interpret, and instead refer you 17 and each asked the panel to implement mandatory 17 to the evidence of Edina Carmi, who expertly established 18 reporting and for a body to be established to hold 18 that there are mostly bad and few good examples among 19 churches to account. 19 the case studies that she audited. 20 It is frankly insulting to those harmed by clergy 20 It was, however, worrying to note that the trends 21 for Gordon Read, the Canon lawyer, to suggest that 21 she identified include: lack of support to victims; poor 22 breaches of the CSAS guidance, even if elevated to Canon 22 record keeping; a reluctance to carry out 23 law status with a general decree, will result in 23 investigations; and conflicts created by clergy being 24 meaningful sanction for a bishop. The only sanction he 24 appointed diocesan safeguarding coordinators. 25 could point to was for the Papal Nuncio to speak to 25 In contrast, Ms Carmi showed us that perpetrators

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1 receive plenty of support with accommodation, legal 1 every one of these measures, the church still firmly 2 costs, treatment, testimonials and an open-ended 2 opposes progress. To date, the only positive step taken 3 commitment. 3 in the UK on these stipulations is to agree the general 4 Indeed, the wide variation in standards from the 4 decree, which in theory obliges church officials to 5 appalling to the good demonstrates that there is no "One 5 co-operate with the police. The lack of substantial 6 Church" policy and no minimum standard. Service levels 6 sanction means that bishops, whom Sister Bertelson 7 are reliant on the vagaries of powerful individuals. 7 believes are opposed to outside imposition of rules, 8 As we said in opening, we need one-nation policies 8 will be able to ignore it. The church has taken no 9 applicable to all institutions that care for children. 9 steps to introduce a compensation scheme. Suspensions 10 It is worth reminding ourselves of the relevant 10 are rare. Dismissals are even rarer. Laicization takes 11 recommendations made in 2014 by the United Nations 11 years. 12 Committee on the Rights of the Child. This is a body 12 Whilst the Catholic Church in the UK espouses good 13 interested in establishing minimum standards of child 13 practice and has set up detailed guidance for its 14 protection. They said the should ensure that 14 bishops, in truth, these can be ignored without real 15 clergy against whom allegations have been proven should 15 sanction. Without state-level enforcement of mandatory 16 be immediately suspended from duty or dismissed, and to 16 reporting, bishops will continue to have the say on 17 take effective measures to ensure that, where credible 17 whether allegations should be reported to the police. 18 allegations are made, the police should be informed 18 The implications of all this are that, so long as 19 immediately. Rather than obstructing the police and 19 the Catholic Church is engaged in the care and education 20 civil authorities, the Holy See should co-operate with 20 of children, it poses an unacceptable risk. We reserved 21 the police in their investigations and should not 21 our position at the outset of this inquiry, but since 22 continue to hide evidence from the police. 22 hearing of the dangers of the confessional, the 23 They said that the Holy See should ensure that 23 powerlessness of the diocesan safeguarding coordinators, 24 a fair and adequate system of compensation is 24 the lack of sanctions for priests, the reluctance to 25 implemented to compensate victims of clergy abuse. On 25 report to police and LADOs, the failure of the church in

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1 the international sphere to take steps to sanction their 1 establish a system of accountability and will deal with 2 own priests, we are firmly of the view that faith-based 2 unincorporated organisations such as churches. Such 3 education is not conducive to the safety of children and 3 a body will establish a register of relevant 4 that schools should be removed from church control and 4 institutions that look after children. It will be an 5 governance. 5 offence to look after children without being on the 6 By any measure, the Catholic Church is not fit to be 6 register. To be on the register, institutions will have 7 entrusted with our children. The Catholic Church is not 7 to introduce corporate status and corporate structure. 8 alone. There are many organisations in the same 8 Regulated institutions will be forced to adhere to 9 category whose disinterest in the safety of children in 9 minimum standards of safeguarding. The body will have 10 their care has been ignored for too long by legislators. 10 the power to prosecute regulated organisations for 11 Self-regulation in safeguarding is a failed experiment 11 breach of this guidance. Fines will be imposed. 12 and we need strong legislation to enforce basic 12 Corporate complaints will be captured by mandatory 13 standards and to impose meaningful sanctions for breach. 13 reporting legislation. The body will gather information 14 A minister at cabinet level to develop and enforce 14 from complainants, regulated institutions and third 15 children's rights would be a step in the right 15 parties. It will have the power to compel disclosure of 16 direction. 16 material. It will liaise with, and assist, civil 17 We invite the panel to consider the creation of 17 authorities, such as the police and social services. It 18 a new statutory body to police and enforce minimum 18 will ensure that the police and statutory organisations 19 national standards in safeguarding. We envisage such 19 are taking appropriate action within reasonable 20 a body having similar powers to the Health and Safety 20 timescales. It will have the power to compel the police 21 Executive. The HSE operates for the safety of workers; 21 to investigate and to refer cases to the CPS. It will 22 children are an even more vulnerable group. The absence 22 have the power to make an award of compensation via 23 of a powerful statutory body dedicated to their 23 a new redress scheme. It will decide the support to be 24 protection is a serious defect. 24 offered to the complainant. It will investigate the 25 The introduction of compulsory incorporation will 25 complaint using the balance of probabilities as

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1 a standard of proof. There will be no statute of 1 Closing statement by MS PATRICK 2 limitations. A scheme will be published to provide 2 MS PATRICK: Chair, panel, as you're aware, I represent D2, 3 adequate compensation for victims of child sex abuse, 3 a core participant in the Archdiocese of Birmingham case 4 which takes into account the effect on quality of life 4 study. I'm led by Ms Gallagher QC, who is unable to be 5 and a series of other relevant factors, as opposed to 5 here today because of a longstanding other commitment. 6 the rigid CICA scheme. 6 She sends her apologies to the inquiry. 7 Complainants will be allowed to take advice from 7 I'm instructed by Jon Wakefield of Bhatia Best 8 lawyers and a contribution towards legal costs will be 8 solicitors, and we have prepared these closing 9 awarded. The cost of the body's work will be assisted 9 submissions together. 10 by levy on these institutions. The cost of awards of 10 In opening, D2 asked the inquiry to think about the 11 support, reparations and legal costs in each individual 11 bishops who were visibly shaken by their viewing of 12 case will be recouped by the state direct from the 12 the Oscar-winning film "Spotlight". Yesterday, the 13 organisation which is vicariously liable for the 13 inquiry heard that watching that film now forms part of 14 perpetrator. 14 the training of some priests. In one powerful scene in 15 Self-regulation has failed. Attitude and practice 15 that film, the Spotlight team meets Phil Saviano, 16 has not improved, even during the currency of this 16 a survivor of child sexual abuse. The actor playing 17 inquiry. Our recommendations are ones of necessity, to 17 Mr Saviano produces a beautiful picture of himself as 18 redress the power imbalance between children and large 18 a smiling child. This is something Mr Saviano does when 19 institutions that would seek, for their own purposes, to 19 he speaks in public. 20 care for children. It is the role of the state to 20 The actor's voice cracks as he tells Phil Saviano 21 protect the weak and vulnerable. No-one else can or 21 his true story. He becomes angry and he asks why it's 22 will do it. Thank you, chair and panel. 22 taken so long for the journalists to care. The first 23 THE CHAIR: Thank you, Mr Greenwood. Ms Patrick? 23 thing he does is thank them for listening. 24 24 A photo of a smiling child plays a part in D2's 25 25 story too. D2 told the inquiry about a trip to

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1 Birmingham arranged by their safeguarding team. In 1 sitting in the public gallery and in the annex today; 2 a wood-panelled room, which smelled like the school 2 real people with lives devastated by abuse in the care 3 where he was raped and abused, D2 opened a file and saw 3 of the church; real people ignored, marginalised and 4 a picture of himself as a boy. Seeing that picture, he 4 disrespected when they reported their abuse to the 5 told the inquiry he became very upset and cried. He 5 church as adults. Behind every criticism laid at the 6 told the inquiry he was gobsmacked when, years later, 6 door of the church in these statements is the personal 7 Jane Jones, the Birmingham safeguarding coordinator, 7 pain of a victim or survivor, the personal pain of 8 told him that that crying had left a priest terrified 8 a formerly smiling child. Behind every recommendation 9 and very disturbed. After the Birmingham hearings, D2 9 request for this inquiry there lies a voice demanding to 10 asked to see the file again. He asked for the four 10 be heard. 11 photographs of himself as a boy held by the archdiocese. 11 In opening, Ms Gallagher QC asked the panel to 12 They were cut from an old file where they had been glued 12 ground its inquiry in realism, to look beyond the 13 for years. They are now the only pictures he has of 13 rhetoric and consider the reality for victims and 14 himself as a child. You can't see those photographs in 14 survivors in their experience of the church. In 15 the public gallery, because D2 is anonymous. They are 15 closing, D2 offers three things: first, some rhetoric 16 important to him in ways he finds very difficult to 16 for the inquiry to question; second, a flavour of 17 explain. 17 the realities experienced by victims and survivors 18 After his statement was read, during the Birmingham 18 interacting with the church; and, finally, a short 19 hearings, D2 said that it was the first time he thought 19 shopping list of actions for the inquiry and the church 20 that people other than his family or his legal team had 20 to address the reality behind the rhetoric. 21 truly heard about his experience as a child and believed 21 First, the rhetoric. In opening, Ms Gallagher 22 him. Being heard is as important to D2 as it was to 22 suggested the inquiry might play a quick game of inquiry 23 Phil Saviano. 23 bingo. We expected a full house of familiar messages 24 The story in Spotlight and the experiences heard by 24 from the church. "We are sorry. We have changed. It 25 this inquiry are the lives of real people: real people 25 will never happen again. We are listening". We will

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1 leave it to the inquiry to decide whether the bingo card 1 his abuse and the devastation in his life that followed 2 is full, but for now, D2 focuses on the last of those 2 are found in the public records of this inquiry. The 3 headlines, one of which dominated the evidence of 3 minutiae of his sexual assault does not make his 4 Cardinal Nichols: "We are listening". Cardinal Nichols 4 suffering more poignant. The harm he suffered is plain. 5 confirmed he experienced a revelation in Rome 5 When asked to recall his childhood now, he weeps. 6 in February 2019 which changed his understanding of 6 Whether poorly articulated or poorly considered, the 7 victims and survivors. The cardinal had learned about 7 cardinal's words are an insult to the survivors of child 8 the lifelong impact of childhood abuse. He now 8 sexual abuse. Are they only to be heard when their 9 understood how victims and survivors live with their 9 experiences are framed in a way the cardinal is willing 10 experiences every day. In opening, Ms Gallagher QC 10 to understand? 11 asked the inquiry to consider why this had proved such 11 The cardinal, it has already been said, described 12 a "road to Damascus" moment for the cardinal; why a man 12 the position of the church post February as having 13 of such experience and responsibility in the church, who 13 a radical new openness to this human tragedy. The 14 had been chair of COPCA, took so long to realise that, 14 inquiry is invited to test this new radical approach 15 to understand the evils of child sexual abuse, you must 15 against the evidence it's heard from victims and 16 consider survivors and their needs. What did the 16 survivors. Mr O'Donnell has already talked powerfully 17 cardinal say? He told your counsel, "The voices I heard 17 about his clients. RC-A710's emails ignored, ignored, 18 in the meeting in Rome were far more explicit in the 18 ignored and ignored again, the cardinal accepting now 19 physical details in which they spoke about their abuse 19 that he failed in a way which was unacceptable, but not 20 than I'd heard when sitting face to face in the years 20 unforgivable. A711, who awaits an apology for 21 I was at Birmingham". 21 a devastating leak which the cardinal deemed, or seemed 22 Now, D2's statement tells of his abuse by lay staff 22 determined to reduce to gossip over a year on, her story 23 and his rape and sexual assault by older children while 23 is not over. Cardinal Nichols promises to meet with her 24 in the care of the Archdiocese of Birmingham, at 24 in December, of course. Cardinal Nichols also gave 25 Croome Court and Besford Court Schools. The horrors of 25 evidence on how important the work of the Survivors

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1 Advisory Panel, the SAP, had been for him and for the 1 D2 to this invitation, the cardinal approached D2 and 2 church. He had learned from victims' thoughts on better 2 his wife in the annex. He took D2's arm and shook his 3 communication and on not leaving God out of 3 hand. 4 the conversation. The cardinal was less comfortable, we 4 D2 tells the inquiry in that statement he felt he 5 heard, with the views from SAP on the church being led 5 couldn't refuse. He had no power and no choice. D2 6 by its insurers. That wasn't his experience, so he 6 felt feelings of self-harm and he had to leave the 7 seemingly hadn't acted on it. Was this view unhelpful 7 building to recover. This happened during the 8 or uncomfortable, and so ignored? Again, is the 8 cardinal's evidence to the inquiry on how he understands 9 victims' view so easily reduced to the messages which 9 the emotional, physical and psychological powerlessness 10 the church finds consistent with its own experience? Is 10 of the victims and survivors of abuse. This was just 11 this the approach which Baroness Hollins told you, on 11 a quick hello, that was all: a quick hello. But it was 12 Day 4, was being exported the world over? 12 also an act which made D2 feel small and powerless. 13 D2, unfortunately, feels that a last key indictment 13 D2 has told the inquiry he believed the cardinal's 14 of this rhetoric is in his experience of attending this 14 handshake came with no thought for him and his pain. 15 hearing on Wednesday. It's been recorded in a statement 15 But he believes it may have let him, the cardinal, feel 16 which has been provided to the inquiry yesterday 16 better about himself or unburdened while giving his 17 morning. D2 finds these hearings exceptionally hard. 17 evidence. D2 asks whether this was, in all the 18 He is a person with learning disabilities and being here 18 circumstances, an act understanding of his needs as 19 makes him think about the abuse he suffered as a child. 19 a victim or a survivor and one which listened truly to 20 On Tuesday, the cardinal asked, through his legal 20 his voice? 21 team, if he could meet with D2 at the hearings to say 21 D2 asks the inquiry to reject this seemingly 22 a quick hello. D2 did not want to be rude and told his 22 apparent radical sea change revelation of February 2019 23 lawyers, us, he would think about it. It was 23 as, at best, a toe dipped in the water of 24 a difficult day and a difficult decision. Yet during 24 the devastation lived each day by survivors; at worst, 25 the morning break on Wednesday, without an answer from 25 the inquiry must ask if the church is adopting a "pick

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1 and mix" approach to survivors' needs, listening only 1 told him to "get on with his life" because "they're all 2 when the messages fit, where they are suitably graphic, 2 dead". In his submissions following the Birmingham 3 or where victim engagement operates as a comfort for 3 hearings, D2 told the inquiry that the actions of 4 a church driven first by self-interest. 4 Jane Jones came from a gap in understanding of 5 A victim-centred approach means victim first, not 5 the church that where perpetrators are dead or otherwise 6 church first. Contact handled poorly is as 6 incapacitated and a prosecution can't pursue, there's 7 re-traumatising for victims as a choice to ignore them 7 a gap in the absence of successful civil proceedings in 8 entirely. 8 the procedures of NCSC and CSAS, which means that 9 The cardinal told the inquiry about meeting a victim 9 victims aren't supported and the church isn't learning 10 where they wept together. D2 asks not for tears from 10 lessons of the past. 11 the cardinal for him or other victims and survivors, but 11 In parts 2, 3 and 5 of her report, Edi Carmi 12 for true empathy, respect and kindness. 12 identifies a very similar hole. She told the inquiry 13 Now, I will stop with the rhetoric. Let's talk 13 this and other failures by CSAS really represented 14 about the survivors' real experiences. Because true 14 missed opportunities to learn lessons. What we say is 15 empathy is not enough. It must come with systems which 15 that failures in policy have direct impact on the lives 16 are transparent, accountable and victim-centred. Yet 16 and experiences of survivors. 17 the reality of the church for victims and survivors has 17 Second, wearing two hats. D2 said this a number of 18 been starkly illustrated in the evidence heard by this 18 times to the inquiry. He was particularly affected by 19 inquiry. The experiences of D2 and the evidence of 19 the evidence heard in Birmingham, that the safeguarding 20 the Birmingham case study are mirrored in the evidence 20 coordinator there had provided considerable financial 21 heard over the last two weeks. We don't repeat 21 and emotional support to a number of accused and 22 everything. I suggest there are two examples 22 convicted abusers, including Sam Penney. He made 23 particularly important to D2. 23 submissions that those functions where the safeguarding 24 First, they are all dead. D2 told the inquiry about 24 coordinator at once is supporting a victim, at the same 25 an occasion when the Birmingham safeguarding coordinator 25 time supporting those who are abusers or accused, needed

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1 to be starkly defined to distinguish the two separate 1 to victims, what concrete, effective action has the 2 jobs. 2 church promised? Well, we are expanding the SAP model 3 On Tuesday, Edi Carmi said the same. D2 also 3 for the regions. However, Baroness Hollins is only now 4 questioned whether a safeguarding coordinator who is 4 conducting a review of the effectiveness of that model, 5 a devoted Catholic or who had played a role in the 5 after it's been earmarked for expansion. Listening more 6 church could do this role properly at all. Edi Carmi, 6 sounds good, but is the church listening well? The 7 in her report, agrees. Based on the evidence in her 7 inquiry is asked to look for examples of where the SAP 8 review, she told the inquiry that clergy simply should 8 has influenced the actions of the church and its 9 not act as safeguarding coordinators. 9 policies and procedures for the better. 10 Edi Carmi, in closing, suggests that the CSAS 10 We have heard enough about the general decree. We 11 procedures don't encourage thinking, but shutting down. 11 say this: whatever it does, will it enshrine in law 12 She said: 12 policies which Edi Carmi has described on Day 7 of these 13 "The service seems to function extremely well when 13 hearings as, at best, an embryo of a policy and 14 it comes to supporting perpetrators, which is in stark 14 procedure fit for purpose? The independent review, we 15 contrast with a lack of support in many cases for, and 15 have had Nolan in 2001, Cumberlege in 2007, now yet 16 a lack of consideration of, perhaps supporting victims, 16 another independent review will seemingly provide the 17 survivors and their families." 17 church with the tools it needs to protect children. 18 Edi Carmi paints a picture familiar to the priests 18 Cardinal Nichols told us the review would protect 19 who were so shaken by their viewing of "Spotlight". 19 children by looking at the position afresh. He wasn't 20 Anybody can watch it and see these themes: church before 20 familiar with the terms of reference, and he didn't 21 victim; abuser before victim; survivors disrespected, 21 comment on the seeming direction that the review need 22 ignored and shut down. It is a damning indictment for 22 not reach specific recommendations or go beyond the "One 23 the church. 23 Church" model. Why has it taken the church so long to 24 A third point for D2 is, what about systems that fit 24 realise its policies may work more for the benefit of it 25 reality? Beyond this radical new approach of listening 25 than victims and survivors? Does the church think it's

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1 doing well? Cardinal Nichols' evidence might suggest 1 D2 will make detailed submissions -- and I am very 2 that, looking at the other countries in the world, 2 conscious of your time and your indulgence, chair -- in 3 England is doing quite well at "getting it", but 3 writing. He has four things he will ask you to consider 4 Sister Bertelson told the inquiry that having a lay 4 today. One and two will be quick. We adopt the 5 chair at all was a courageous act for the Church in 5 suggestions of others that there needs to be an 6 England and Wales. The inquiry will reach its own 6 independent mechanism for the treatment of safeguarding 7 conclusions on what it has heard from Danny Sullivan and 7 to hold the church to account, and that must also 8 Christopher Pearson. Sister Bertelson repeatedly 8 include the handling of reports by adults who are 9 described the "One Church" procedures operating 9 survivors of abuse in historic cases. They must also 10 following Nolan as a "gift". Changing a policy takes no 10 introduce mandatory reporting through statutory means. 11 courage. Living with the legacy of abuse and facing up 11 But, thirdly, a new scheme takes time. No matter 12 to the "gift" of a childhood stolen does. 12 how long, whether it is church time or the time 13 Cardinal Nichols said, "I think getting the task of 13 understood by the rest of us. In the meantime, the 14 safeguarding understood in an utterly positive way is 14 church should not stand still. It should be invited to 15 something we still have to achieve". But is there 15 put its house in order. The part 2 of the Carmi Report 16 a need for speed? Sister Bertelson told the inquiry, 16 provides a helpful blueprint for a start. It need not 17 "A change of mind-set takes time". The contrast between 17 wait another year for its independent review to wind up. 18 the picture painted by the Carmi Report and by the 18 Finally, the church must stop apologising for the 19 corporate witnesses for the church was stark. Change is 19 mistakes of its past while using limitation periods to 20 hard, but the church isn't talking about going to a new 20 halt litigation designed to secure accountability and 21 pizza restaurant or the discontinuation of a new soap. 21 redress for victims and survivors. If it can be done in 22 It is dragging its heels on actions to effectively 22 Scotland, it can be done here. 23 protect children from abuse and to respectfully treat 23 Finally, and thank you for your indulgence, 24 the reports of adults who report bravely as survivors in 24 February 2020 will see the 15th anniversary of the day 25 adulthood. 25 that D2 reported his abuse to the church in Birmingham.

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1 He was abused decades before he felt able to make that 1 taking the break? 2 call. For each day, week, month of these intervening 2 THE CHAIR: We will hear Mr Jacobs. 3 years and decades, D2 and his family lived with that 3 Closing statement by MR JACOBS 4 legacy of the time he spent as a child in the care of 4 MR JACOBS: Chair, thank you. I appear, instructed by 5 the church. 5 Howe & Co, for 19 individual complainant core 6 The Roman Catholic Church is centuries upon 6 participants in this investigation. I look over, and 7 centuries old. Whether it is one church or it is many, 7 many of them are here today. 8 in any layman's reckoning, it is a global, large and 8 At the outset, I thank the inquiry and its legal 9 powerful institution. The passage of time may mean 9 team on behalf of my clients. My instructions are that 10 little to those who are focused on the longevity and 10 they do not seek to attack Catholicism or the church in 11 legacy of that body. For D2, as he told the inquiry in 11 general. However, they will not tolerate, any longer, 12 his first statement, making it to the end of each day is 12 the church hierarchy's profound and long-term failure to 13 sometimes an act of courage and resilience, yet he and 13 address safeguarding of children in its care. 14 his family counted years while he letters to the church 14 Three of our clients, chair, gave evidence on Days 2 15 went unanswered. 15 and 3 in relation to the institutional responses of 16 To retain the confidence of victims and survivors 16 the Comboni Order and the Catholic Church to child 17 and the wider public, the inquiry must make clear that 17 sexual abuse. Detailed sections of the evidence of 18 there's work needed urgently to ensure a real sea change 18 Frank McGinnis, who died recently, were read out on 19 in the way the church treats victims and survivors. 19 Day 3. In our written submissions, we will refer you to 20 That work will take not courage, but conviction. It 20 the evidence of all of our clients and will address you 21 simply cannot take any more time. Thank you. 21 on a number of further issues that I will not have time 22 THE CHAIR: Thank you, Ms Patrick. Mr Jacobs? 22 to cover today. 23 MS CAREY: Chair, I was just going to interrupt briefly, if 23 The primary focus of this hearing is the 24 I may. I see the time. Would you like to take the 24 institutional responses of the church to allegations of 25 morning break now or hear one more submission before 25 child sexual abuse in this jurisdiction, England and

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1 Wales. The starting point, I say, for the inquiry to 1 submission out. In particular, the evidence relating to 2 consider is the scale of the problem. Now, chair, on 2 our clients will assist the inquiry on this issue and 3 Day 1, you were referred to the Bullivant Report and 3 inform the recommendations that it makes. 4 told that from 1970 to 2015, over 930 complaints were 4 You heard our opening submissions on the first day, 5 made to the Catholic Church in relation to 3,072 5 and your attention was drawn to an important contrast 6 instances of abuse, and that this amounts to 6 between the institutional responses of the Archdiocese 7 approximately 20 complaints a year for over four and 7 of Birmingham and the Comboni Missionary Order, and you 8 a half decades. 8 heard that from my colleague who sits next to me today. 9 The scale of the problem, chair, should be 9 You have heard that Archbishop Longley has travelled 10 considered alongside the scale of the response. You 10 to meet with F48, F49, F53 and F58 at their homes, where 11 will know that the church has failed to implement the 11 he listened to them, unconditionally apologised on 12 "One Church" approach recommended by Lord Nolan 12 behalf of the Catholic Church and offered support. This 13 in September 2001. 13 has had an enormously positive effect on our clients. 14 The Nolan Report was reinforced by the July 2007 14 However, you have heard evidence over the past two 15 Cumberlege Commission Report, recommendation 72 of which 15 weeks of the very different responses of another limb of 16 required the making of a decreta generalia and with 16 the Catholic Church, the Comboni Order. Those responses 17 canonical recognitio to provide for a special 17 were illustrated starkly in the evidence of Mark Murray, 18 territorial law. Chair, as at today's date, some 18 who appeared before you on Day 2. You will recall that, 19 18 years after Nolan and 12 years after Cumberlege, 19 in 2015, Mark Murray confronted his abuser, 20 there is no "One Church" policy in place. 20 Father Nardo, at the Mother House of the order in 21 Since 2016, our central submission before this 21 Verona. We saw a video which showed Father Nardo 22 investigation has been that the Catholic Church is 22 getting down on his knees and apologising to Mr Murray. 23 culturally and structurally incapable of implementing 23 I will quote his evidence. It bears repeating: 24 uniform minimum standards in this jurisdiction. The 24 "As he got up to go, I said to him, 'I forgive you', 25 evidence now before the inquiry has borne this 25 and I was no longer a child, I was the adult. To have

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1 the power to forgive someone is a massive feeling, 1 conducted an audit of orders for this investigation and 2 a massive regaining of the power that you lost through 2 has viewed the safeguarding files of two of our 12 3 abuse. It helped me to completely reconstruct my 3 surviving Comboni survivor clients. Ms Carmi states in 4 identity, completely rephrase Nardo's situation, Nardo's 4 her report there is a cultural issue in the tone of some 5 abuse, Nardo's manipulation of me. It was an extremely, 5 of the responses that suggest insufficient understanding 6 extremely powerful experience. I left that building, 6 of the harm that has been caused, a lack of appreciation 7 I left the chapel as a powerful man, but that was soon 7 about how best to learn from the past and also about how 8 destroyed." 8 best to support survivors of abuse, including the need 9 Mr Murray went on to say that he was subsequently 9 to meet with them and hear what they are saying. The 10 accused of money grabbing by the vice , who told 10 wider Catholic Church has been unable to address these 11 him practically on the steps, "If you are waiting for an 11 concerns. Danny Sullivan, a former chair of 12 apology, you will be waiting a long time and your wait 12 the National Catholic Safeguarding Commission, gave 13 will be in vain". And, to make matters worse, the 13 evidence on Day 3 and confirmed that Cardinal Nichols 14 Comboni Order proceeded to prosecute my client for 14 passed to the Congregation of the Doctrine of the Faith 15 perpetrating abuse on his abuser and, perhaps even more 15 a detailed document on behalf of Brian Hennessy and the 16 extraordinarily, on losing that case, the order then 16 Comboni Survivors Group. Chair, that document contained 17 unsuccessfully sought to appeal. 17 details of hundreds of incidents of sexual abuse 18 Mr Murray has told you that he was re-traumatised by 18 committed by members of the Comboni Order here in this 19 the approach taken by this religious order. This is 19 country in this jurisdiction. 20 a common theme with our clients. You will recall the 20 It is noteworthy, chair, that Cardinal Nichols, the 21 evidence of F6, who was horrified to learn that his 21 President of the Catholic Bishops' Conference and the 22 abuser, whose removal from the seminary he had secured 22 chair of the Catholic Office for the Protection of 23 as the senior prefect of the school as a child, was in 23 Children and Vulnerable Adults was unable to take any 24 fact promoted and sent to work with children in Africa. 24 responsibility for dealing with allegations of 25 This evidence is supported by Ms Carmi, who has 25 child abuse in a seminary in Yorkshire but referred the

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1 matter to a body in the Vatican which, as matters stand, 1 children have not been protected from the abuse of 2 has taken no action. I will refer you in the written 2 priests and clerics. There is also a significant 3 submissions to the references to that evidence. 3 aggravating factor. 4 Yet the Comboni Order today is undeterred. 4 Chair, successive national governments have 5 Mr Altman QC referred you on Day 1 to recent 5 exacerbated the problem by treating the church with 6 correspondence in which the order refused to engage with 6 a deference which would not have been accorded to any 7 our clients pending the outcome of this inquiry process, 7 other institution where children are at risk. We can 8 acting as though it were engaged in a litigation. 8 see the nature of this deference by way of an example. 9 You also heard from F6, on Day 3, that 9 Now, we heard on Day 1 there are 380 religious orders 10 a representative of the Comboni Order, the same man with 10 and 22 dioceses in this jurisdiction. This is similar 11 whom Danny Sullivan corresponded and referred to in his 11 to the number of local authorities. 12 evidence, attended this hearing and refused to even 12 Consider for a moment if chief executives of local 13 acknowledge our clients. So, chair, what conclusions 13 authorities across the country were appointed by the 14 can we draw from the contrast between the egregious 14 head of a very small European country or a city state, 15 conduct of the Comboni Order and the recent exemplary 15 that they held their positions divinely through the will 16 actions of Archbishop Longley? 16 of God, were not subject to external direction or 17 In my submission, it is this dichotomy which more 17 oversight, lived in a society characterised by 18 than anything else demonstrates the fundamental problem 18 deeply-rooted fraternal bonds and were bound by the laws 19 within the Catholic Church in relation to safeguarding. 19 of that small European country to respect the autonomy 20 Chair, it cannot implement a "One Church" policy 20 of a number of subsidiary bodies. Now consider 21 because it is not one church, but many. The church is 21 a scenario where child abuse was, or had been, rife 22 comprised of thousands of autonomous religious orders 22 within that local authority sector and that, over 23 and dioceses, each with their own constitutions, which 23 18 years ago, an inquiry had recommended a unified 24 in turn are protected under Canon law. 24 safeguarding approach, but that this had not been 25 But it is not only this which determines why 25 undertaken.

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1 Would the government of the United Kingdom agree 1 or equipped to bring about safeguarding children. 2 that this was a matter to be resolved by an opaque legal 2 You cannot be satisfied that the motu proprio, "Vos 3 system of a small foreign sovereign state? Chair, I say 3 estis lux mundi" of 7 May 2019 will resolve the 4 of course not. Chair, in this absurd scenario, 4 safeguarding problem. A motu proprio is a measure which 5 legislation would have been passed decades ago. There 5 amends Canon law on a specific issue. In this case, it 6 would have been no need for an inquiry. We say it is 6 merely provides a requirement to report abuse to an 7 not acceptable in the 21st century that we still find 7 ecclesiastical authority. However, you will recall the 8 ourselves in a situation in which the Roman Catholic 8 evidence before you of Ms Carmi. She made the point 9 Church is treated differently to any other organisation 9 that safeguarding roles should not be undertaken by the 10 with the responsibility for the safety of children. 10 clergy because of the likelihood of a conflict of 11 So, chair, it must now be clear from the evidence 11 interest: an obvious point, I would say. 12 before the inquiry in this investigation that the 12 So a fundamental defect in the motu proprio is that 13 Catholic Church is inherently incapable of policing 13 there is no provision within it for oversight by any 14 itself. It follows, then, that you should reject any 14 independent lay body. Similarly, chair, the 15 entreaty made on behalf of the Catholic Church that 15 decreta generalia, approved on 28 June 2019, is no 16 there is a solution in Canon law. 16 satisfactory solution. 17 You heard the evidence of Monsignor Read that Canon 17 As matters stand, the decreta generalia, which took 18 law is not updated when amended, so we cannot be 18 12 years to even propose, has not received canonical 19 entirely clear even what Canon law says. However, from 19 recognition to bring it within universal Canon law. At 20 what we have seen and heard, Canon law has recognised 20 most, all the new local territorial law will do, even if 21 a child as somebody under 14. Grooming is not 21 approved by Rome, is give recourse to the Vatican to 22 recognised. Sexual abuse has been confused with 22 penalise a bishop for breaches of basic safeguarding 23 pornography and is currently treated as a failure to 23 standards in Canon law trials. More importantly, it 24 observe celibacy. This, chair, is not a system that 24 will not empower CSAS or NCSC with compliance powers 25 promotes the paramountcy principle. It is not designed 25 exercised within the UK against a bishop to direct him

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1 in correct case handling. 1 priests and brothers she studied disclosed abusing 2 So the fundamental problem with the recent 2 children in the confessional. You may remember, chair, 3 initiatives from the Vatican is that no general decree 3 Frank McGinnis, whose evidence was read out, disclosed 4 or motu proprio could achieve recognition were it to 4 the abuse he was receiving twice in the confessional and 5 sanction oversight by lay professionals or a lay 5 was rebuked on both occasions. 6 regulatory body. 6 Chair, the cardinal's position under oath is that 7 Danny Sullivan characterised this inability of 7 the church would refuse to follow laws designed to 8 the church to trust lay people with authority as 8 protect children for religious reasons. This, I submit, 9 a reflection of the wider malaise within the 9 must settle the argument as to whether the church or an 10 Catholic Church. This malaise is ongoing. 10 independent lay body should be responsible for 11 Furthermore, the motu proprio and decreta generalia 11 safeguarding. 12 cannot apply to a case where an abuser is protected by 12 So, in light of this, chair, in light of this 13 the sacrament of confession or where abuse is disclosed 13 fundamental difficulty, what conclusions should the 14 in the confessional. Cardinal Nichols told you 14 inquiry draw from the evidence that it has heard over 15 yesterday that any recommendation of the lifting of 15 the last two weeks and in the three other case study 16 the seal would be rejected by the Bishops' Conference. 16 hearings? We say that the safeguarding of the children 17 He made it clear that the church will never permit any 17 of the 3.8 million Catholics in this country cannot be 18 mandatory reporting that encompassed the confessional. 18 in the gift of a foreign sovereign entity. There is 19 That is not only Cardinal Nichols' view, it is the view 19 certainly no evidence from any safeguarding professional 20 of the whole church, and consistent with Canon 983 and 20 before the inquiry which could support this view. Your 21 the dogmas of divine law which you heard about on Day 1. 21 finding should be informed by the fact that the 22 This is, I submit, an insurmountable objectionable to 22 Apostolic Nuncio has told the inquiry that it considers 23 safeguarding. In our written submissions we will refer 23 that domestic laws and internal proceedings of a foreign 24 you to the highly regarded research of Dr Marie Keenan 24 sovereign entity are not the proper object for a British 25 of Dublin University who found eight of the nine abusing 25 inquiry. When questioned by Mr Altman, Cardinal Nichols

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1 stood by the Nuncio's position. 1 As to structure, Sister Bertelson went on to refer 2 The Holy See's lack of co-operation sits uneasily -- 2 to the diversity of guidelines within the episcopal 3 very uneasily, I submit -- with the pronouncements made 3 conferences and religious congregations which she said 4 in the wake of the February 2019 Vatican conference. 4 simply do not match up. 5 The evidence in the investigation has ultimately 5 Chair, you have heard now compelling evidence in 6 supported our primary submission that the culture and 6 four separate case study hearings as to the church's 7 the structure of the Catholic Church inhibit the 7 inability to uniformly impose minimum safeguarding 8 safeguarding of children. This is also the evidence 8 standards. Our clients urge that you recommend that 9 from those who gave evidence on behalf of the church, 9 legislation is drafted now to remove safeguarding of 10 who were candid in acknowledging the problem. 10 children from the church and that safeguarding is placed 11 You will recall the evidence of Sister Jane 11 in the hands of an independent lay regulatory body. 12 Bertelson who sits on the Pontifical Commission for the 12 This will allow the church to adjust its structures, 13 Protection of Minors. She quoted, on Day 6, the Pope's 13 to clean the Sphinx or, as Cardinal Nichols suggested, 14 description of "cleaning the Sphinx with a toothbrush", 14 to polish the inside of the cup, to supplement the 15 that very memorable phrase, in relation to the work the 15 process with spiritual understanding. 16 church must do to reform its massive structures to bring 16 This inquiry process, chair, may have actually 17 about safeguarding. Neither is the delay and the 17 assisted the Catholic Church in understanding the true 18 continuing inability of the church to implement Nolan 18 nature of the problem. Cardinal Nichols told us on 19 and Cumberlege lost on its leading members. Again, 19 Day 8 that there has been a sea change in the way the 20 Sister Bertelson said, "The reason we are here is 20 church views abuse. He said from the periphery, from 21 because the church has hurt and damaged many 21 the perspective of the victim. He talked about 22 individuals. I can't defend the slowness". She went on 22 a forthcoming CDF handbook and a Holy See Task Force, 23 to refer to a cultural problem, saying there was an 23 and said that it is timely to have a radical review. 24 element of, "We need to address this, but we will do it 24 All of this is, of course, encouraging, but, chair, 25 our way". 25 we know from the experiences of Nolan and Cumberlege

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1 that the wheels of the Catholic Church turn very slowly 1 Chair, having heard all the evidence, we submit that 2 and that change within the church will take considerable 2 you must recommend that safeguarding be taken out of 3 time. Furthermore, the church needs time to conduct 3 the hands of the church. This is in the interests of 4 a huge internal task and to slowly recover from the 4 children, it is in the interests of society and it is in 5 reputational damage that this issue has caused, as 5 the interests of the church itself. Unless I can assist 6 Bishop Doyle detailed in his evidence. 6 further, those are my submissions. 7 Chair, in conclusion, I will refer to one of 7 THE CHAIR: Thank you, Mr Jacobs. We will now take our 8 the recurring important themes in this inquiry, which 8 morning break and return at 12.05 pm. 9 has been the importance of listening to survivors. As 9 (11.50 am) 10 such, I would like to conclude with a point that one of 10 (A short break) 11 our clients, Christopher Speight, has asked me to make: 11 (12.07 pm) 12 the Catholic Church breaches domestic employment law 12 THE CHAIR: Mr Collins? 13 through sexual discrimination brought about by 13 Closing statement by MR COLLINS 14 a male-only priesthood. Yet, out of deference to the 14 MR COLLINS: Thank you, chair, thank you, panel. I make 15 church, this is tolerated. The Catholic Church breaches 15 this submission on behalf of the core participants who 16 equalities legislation through refusing to conduct or 16 my firm, Hugh James, represents. I'm sure they would 17 recognise same-sex marriages. Yet again, and out of 17 echo much of what you have already heard this morning, 18 deference, this unlawful conduct is tolerated. The 18 so I will say this: over the course of the last few 19 Catholic Church breaches domestic family law legislation 19 days, we have heard much about cardinals, bishops, 20 through a failure to protect children from abuse at the 20 dioceses, conferences, commissions, priests, and I have 21 hands of priests and clerics, a paramountcy principle. 21 to say, or I have to confess, that I do not pretend, 22 But on this third point, chair, a line must be drawn. 22 even now, to fully understand how the Roman Catholic 23 No deference can ever be given to the Catholic Church 23 Church, in these many guises, actually functions, but it 24 where breaches of domestic law relate to the abuse of 24 is abundantly clear that, when it comes to safeguarding, 25 children. 25 the levers of power are operated by a very small number

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1 of people. Maybe that helps to explain why the Roman 1 and survivors. 2 Catholic Church has failed when it's come to 2 I ask myself, what is leadership in the Roman 3 safeguarding and continues to fail when it comes to 3 Catholic Church? And I would like to repeat a quote, 4 safeguarding. Those failures arise from a failure of 4 give a quote, from Cardinal Newman, who converted from 5 leadership which is the fruit of a dysfunctional 5 the Anglican Church to the Roman Catholic Church in the 6 culture. 6 mid 19th century, and he was appointed as a cardinal in 7 It is patently apparent that the Roman Catholic 7 1879. He said this: 8 Church in this country is incapable of fulfilling its 8 "Among the obligations of a cardinal, I am pledged 9 safeguarding obligations. Those safeguarding 9 never to let my high dignity suffer in the eyes of men 10 obligations can only be met when the culture is right 10 by fault of mine, never to forget what I have been made 11 and when there is the right leadership. 11 and whom I represent, and if there is a man who more 12 It was very telling yesterday, I thought, towards 12 requires the support of others in satisfying the duties 13 the end of Cardinal Nichols' evidence, when he was asked 13 for which he was not born and in making himself more 14 about mandatory reporting and the seal of confession. 14 than himself, surely it is I." 15 He said, and I quote: 15 That speaks of humility. It speaks of humility to 16 "The history of the Catholic Church has a number of 16 me. That is my understanding. 17 people who have been put to death in defence of the seal 17 The leadership of the Roman Catholic Church needs to 18 of confession. It might come to that." 18 express humility because there can be no other way. If 19 He went on, but for my purposes, we will leave it at 19 the Roman Catholic Church is to genuinely embrace 20 that. 20 safeguarding, given all the opportunities it has had so 21 That patently demonstrates that the Roman Catholic 21 far -- with Nolan and Cumberlege -- it has got to find 22 Church has hitched its star to a wagon where the primacy 22 a new way, and it is quite clear, I would submit, that 23 of the Roman Catholic Church and the interests of its 23 it's incapable of doing it by itself. 24 priests are paramount at the expense of all else, and in 24 And so it is inevitable that there is going to have 25 this context, the interests of children, young people 25 to be statutory intervention. A regulator or

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1 a commissioner is going to have to be appointed by 1 to accept that. It cannot, as we heard earlier on, 2 parliament to ensure that the Roman Catholic Church 2 simply "pick and mix". It's not going to work. 3 meets the most minimum standards of when it comes to 3 What is going to be required, in my submission, if 4 safeguarding. 4 there is to be statutory regulation, is some minimum 5 How those various orders and dioceses and various 5 standards, and we will expand on this in the written 6 bodies come to terms with that will be of their 6 submission. But getting back to culture and leadership, 7 choosing, but if they are to have a future, a future 7 one of those minimum standards should be that child 8 that enables them to work with children and to have 8 safety is embedded in institutional leadership, 9 a future, then they are going to have to embrace those 9 governance and culture, and I will repeat that because 10 minimum standards, and maybe, from what you have heard, 10 I say this goes to the heart of what you are looking at: 11 you may be of the opinion that maybe there is a chance 11 child safety is embedded in institutional leadership, 12 there, but that chance will never flourish unless the 12 governance and culture. 13 Roman Catholic Church conforms to what is expected by 13 Such standards, or something very similar, would 14 our society in the 21st century. There can be no other 14 provide a benchmark by which the Roman Catholic Church 15 way. 15 can measure itself. It also provides a benchmark for 16 It is no good for a cardinal to say, "If we don't 16 a regulator or commissioner to judge or to measure the 17 like it, we will reject it". That is not acceptable. 17 Roman Catholic Church by. 18 It is not acceptable in the civilised world in the 18 That must surely be the way to go. 19 21st century. 19 If the Roman Catholic Church chooses not to, then it 20 The issue is not what is said in confession. The 20 has to live with the consequences. I am sure you are 21 seal of confession is not a talisman. Mandatory 21 not going to simply produce a retread of Nolan and 22 reporting, in itself, is no panacea, but it's an 22 Cumberlege, because it is patently apparent, as I have 23 expedient part, an important part, an integral part, of 23 said, in all that you have heard, from the evidence 24 what safeguarding is all about. 24 submitted to you, that mandatory regulation with 25 It is essential that the Roman Catholic Church comes 25 mandatory reporting is going to be necessary.

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1 I would like to close on this note, to pick up on 1 of Sister Bertelson, the "scourge" of child abuse. We 2 what the cardinal said to you yesterday, as it was 2 have heard evidence from a number of witnesses with 3 telling when he talked about the history of the church, 3 regards to the implementation or, in some cases, lack of 4 but very revealing. Perhaps it was unfortunate for him 4 implementation of Cumberlege and Nolan. Perhaps of more 5 to have said it in the context of this inquiry, because 5 significance is that of recommendation 72 of Cumberlege, 6 it reminded me of the German theologian 6 namely, to make a decreta generalia and obtain canonical 7 Dietrich Bonhoeffer, who was executed in Flossenbuerg 7 recognitio within 12 months. 8 concentration camp in 1945 for standing up against 8 Yet, here we are, 12 years later, and that has not 9 tyranny, oppression and wrong. He went to his death 9 been achieved. It would certainly seem that the words 10 because of his faith and because of what he thought he 10 of Mr Spear were correct when he observed in his 11 was fighting for and for what he thought he was going to 11 evidence that, "There is normal time and there is church 12 his death for. He said this: 12 time". 13 "The ultimate test of a moral society is the kind of 13 However, now, 12 years on, the Bishops' Conference 14 world that it leaves to its children." 14 of England and Wales have finally drafted a general 15 That is my submission, chair. 15 decree, but that, of course, is not the end of 16 THE CHAIR: Thank you, Mr Collins. Mr Brodie? 16 the matter. This now requires to be approved by the 17 Closing statement by MR BRODIE 17 Holy See. 18 MR BRODIE: Thank you, madam chair, and members of 18 Cardinal Nichols, in his evidence, was unable to 19 the panel. In my opening at the beginning of these 19 give us any indication as to when that may occur, other 20 hearings, I noted that we are now 18 years from the 20 than that he has been advised it is soon. He was not 21 report of Lord Nolan and 12 years from the report of 21 able to elaborate if that was soon in real time or 22 Baroness Cumberlege, yet, once again, we find ourselves 22 church time. 23 here going over much of the same ground. This, in my 23 However, as I say, they have now done it and it is 24 submission, shows the extent to which the Roman Catholic 24 of fundamental importance to the church in England and 25 Church has failed to properly address, to use the word 25 Wales. However, they are answerable to the Holy See and

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1 they may well choose to veto the entire project. It may 1 slowly and it must therefore be for the state to 2 have been, of course, that the Apostolic Nuncio and 2 intervene and oil those wheels by means of legislation 3 another official from the Holy See would have been able 3 to ensure that safeguarding reporting within the church 4 to assist with regards to the timescale or likely 4 is adequate. 5 implications of the general decree. However, as the 5 In my opening, I noted that many victims have 6 inquiry is well aware, despite requests made through the 6 experienced a negative response when dealing with the 7 proper diplomatic channels, the Nuncio and the Holy See 7 Catholic Church upon reporting their abuse. G1, when he 8 declined to provide a statement to this inquiry. 8 reported his abuse, was ignored, dismissed, insulted and 9 G1 sees this as a significant failure, and submits 9 even threatened. During the course of these hearings, 10 that this has caused further distress to many victims 10 we have heard from a number of victims and survivors who 11 and survivors, and this is something that the inquiry 11 have had similar responses. We heard of the shocking 12 should note in its findings. 12 experience of RC-A711, who was subject to appalling 13 Madam chair, I submit that the time taken to 13 treatment at the hands of the Westminster Safeguarding 14 implement recommendation 72 is indicative of 14 Commission -- being ignored or described as 15 the church's inadequate response to child sexual abuse. 15 "passive-aggressive", "needy" and "deeply manipulative" 16 In her evidence regarding the implementation of 16 by members of the clergy and the commission. This, 17 Cumberlege, Sister Bertelson noted that, "It is not the 17 sadly, is an experience shared by G1, albeit in 18 way, for centuries, that our church has functioned". 18 a different diocese. 19 That may well be so, madam chair, but in my submission 19 We heard from Cardinal Nichols that, having been 20 this area is far too important to be allowed to stall 20 made aware of these comments, he did not discuss them 21 any further. Neither those children currently involved 21 with the head of the commission nor take any 22 with the Catholic nor victims and survivors can wait 22 disciplinary action against those involved. Similarly, 23 centuries for change. They have already waited over 23 in G1's case, no action was taken against the 24 a decade for Cumberlege to be implemented and they are 24 safeguarder who had treated him so badly. 25 still waiting. The wheels of the church may well turn 25 These incidents, in my submission, beg two

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1 questions. Firstly, how many other victims have been 1 human capacity, the capacity to trust another person". 2 spoken about in this way by members of the clergy and 2 So bearing Cardinal Nichols' words in mind, is it any 3 safeguarding commissions; secondly, following on from 3 surprise that many victims and survivors communicate 4 that, how can any survivor have confidence in coming 4 regularly, if for nothing more than to be reassured that 5 forward to report their abuse to the church? 5 they are not, once again, being ignored? However, it 6 Madam chair, safeguarding should provide a safe 6 appears that a simple kind word in an email is beyond 7 space and understanding environment. When victims and 7 some members of the church, and that has certainly been 8 survivors report abuse, they are entitled to expect to 8 the experience of G1. 9 be treated with care and understanding. It can take 9 As Ms Carmi noted in her evidence, many victims find 10 victims and survivors many years to find the confidence 10 the response of the church to be distressing. Some find 11 and trust to speak out about the abuse that they have 11 it worse than the original abuse that they suffered. 12 suffered. Many have spent their lives being ignored, 12 Madam chair, in the context of that culture, how can 13 written off and told they are lying. It is simply not 13 the church be trusted to respond appropriately to 14 acceptable for anyone, let alone those charged with 14 allegations? 15 safeguarding, to insult and berate victims and survivors 15 Turning again to the evidence of Ms Carmi, she was 16 the way some in the church do. Many survivors are 16 asked by counsel to the inquiry the one thing that 17 simply seeking recognition and support. These 17 struck her from her review of 36 case files. To that 18 incidents, I submit, madam chair, show that the church 18 question, Ms Carmi gave this response: 19 is out of step with the rest of society when it comes to 19 "Well, the overall thing is the fact that, actually, 20 dealing with the question of child sexual abuse. 20 the service seems to function extremely well when it 21 I pose the question: in what other professional 21 comes to supporting perpetrators, and which is in stark 22 environment would such language have gone unchecked? 22 contrast to the lack of support in many cases for, and 23 Madam chair, I suggest it demonstrates a further lack of 23 lack of consideration of, perhaps supporting 24 understanding of the needs of victims. Cardinal Nichols 24 victims/survivors and their families." 25 himself has noted that "abuse shatters the most precious 25 Sadly, madam chair, I feel that all too often that

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1 is exactly the position. It was certainly sadly the 1 a culture of safeguarding and, in my submission, allows 2 experience of G1 who was provided with no support from 2 allegations to pass without proper scrutiny, it prevents 3 the diocese, even after his abuser was convicted; while, 3 appropriate safeguarding to be put in place and 4 on the other hand, the abuser, throughout the process, 4 ultimately places children in danger. This, 5 including after conviction, was provided with a great 5 madam chair, cannot be tolerated. 6 deal of support and care. 6 Another area that we have heard much of in the 7 In my submission, this goes back to a matter 7 evidence during the course of these hearings is the way 8 I raised in my opening, that of the church perceiving 8 that the church responds to claims in litigation. We 9 itself as a family. In that context and culture, it is 9 have heard much of the legalistic and aggressive way the 10 natural, perhaps, that the greatest focus of the church 10 church will enter into litigation which, on its face, 11 is on helping those who are most closely connected to 11 seems contrary to the model response you may well expect 12 it. In this regard, Ms Carmi expressed her concerns of 12 from a religious organisation. 13 a potential conflict of interest when a safeguarding 13 We have heard much about the reliance on, or at 14 coordinator is a member of clergy. However, she went 14 least the threat of reliance on, the defence of 15 further than that and said that there is potentially an 15 limitation. We heard from Ms Perrin of the Catholic 16 issue with safeguarding within the church itself. She 16 Insurance Service who told us that this is a matter for 17 put it this way: 17 the diocesan insurers to consider the use of such 18 "I think there is an intrinsic problem, particularly 18 defences. 19 given the systematic position of where a safeguarding 19 Therefore, those whom I represent would favour 20 coordinator is working as part of a church, answerable 20 a change in the law in England and Wales in relation to 21 to clergy, who very often have quite strong personal 21 limitation as a defence in child sexual abuse cases. As 22 links with the alleged perpetrators. It feels like 22 the inquiry will be aware, the law in Scotland was 23 a conflict of interest." 23 recently changed in respect of limitation in terms of 24 As I have said in my opening submissions, the 24 the Limitation (Childhood Abuse) (Scotland) Act 2017. 25 family-like nature of the church is not conducive to 25 This legislation has given a great deal of comfort to

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1 victims and survivors in Scotland in bringing an action 1 law should a priest choose to break the seal of 2 against the church. 2 confession. 3 It is, in my submission, madam chair, in the 3 We heard that a priest who disclosed reporting of 4 interests of justice that the law in England and Wales 4 child sexual abuse which he heard in the confessional 5 should be similarly amended. The current postcode 5 would be automatically excommunicated and that only the 6 lottery for victims cannot be right, particularly given 6 Holy See can lift such an excommunication. It is 7 the way that many abusers were moved from diocese to 7 interesting to note, though, that those who commit child 8 diocese and country to country. 8 sexual abuse are not subject to automatic 9 Victims and survivors must have recourse to the 9 excommunication under Canon law. 10 courts to have any confidence that their voices will be 10 We also heard from Ms Carmi in respect of 11 heard. 11 the sacramental seal. In both her report and in her 12 Turning now, if I may, madam chair, to the sacrament 12 evidence to this inquiry, she raised concerns regarding 13 of the seal of the confession. This is a matter we have 13 the seal of the confessional in relation to the 14 heard lots about over the course of the hearings. We 14 paramountcy principle. She said that in all other areas 15 have heard from Monsignor Read, who noted that the 15 of life, if something is said that is a disclosure, you 16 sacramental seal is an ancient and fundamental matter of 16 have to report it. 17 the church doctrine. Madam chair, as I said in my 17 I ask, madam chair, why is it that a confession made 18 opening, that is something which was exploited in the 18 in this particular kind of state is not subject to the 19 case of G1, to further exert power over him following 19 same paramountcy principle. G1 agrees with Ms Carmi's 20 the abuse he suffered within the confessional box. 20 interpretation and finds it remarkable that a priest is 21 We heard from Monsignor Read that the seal of 21 prohibited by Canon law from disclosing such 22 the confessional is so fundamental that, in his view, 22 information. In light of the evidence of Monsignor Read 23 not even the Pope could change what is said about the 23 that not even the Pope can change this, and the evidence 24 sacramental seal. We were also told by Monsignor Read 24 that we heard from Cardinal Nichols that any 25 of the severe and automatic nature of penalties in Canon 25 recommendation to break the seal would be rejected, G1

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1 submits that the civil law, that is to say the law of 1 a hostile environment for survivors. 2 England and Wales, must step in. Legislation must be 2 Madam chair, finally, I wish to submit 3 introduced to make the reporting of such disclosures and 3 recommendations on behalf of G1. G1 would recommend 4 allegations, even when taking place in the confessional, 4 that legislation be brought in to allow for a system of 5 are reported and that there must be sanctions where that 5 mandatory safeguarding reporting and that there should 6 fails to happen. 6 be statutory oversight of same with criminal penalties 7 Madam chair, I would now like to turn to a number of 7 for individuals who fail to report and financial 8 findings that G1 would invite you and your panel to make 8 penalties for organisations who fail to do so; that the 9 following these hearings. G1 invites you to find that 9 current structure of safeguarding within the church 10 the Roman Catholic Church has failed to provide a safe 10 should be replaced with a national independent secular 11 environment for children, that it has failed to provide 11 safeguarding commission. Alternatively, that the 12 an adequate structure and framework for safeguarding, it 12 current safeguarding commissions should be subject to 13 has failed to follow and implement within a reasonable 13 a statutory oversight and that no member of the clergy 14 and acceptable timeframe the recommendations of 14 should be allowed to serve on such a safeguarding 15 Cumberlege, that it has in the past sought to suppress 15 commission. 16 allegations of abuse, that it has placed its own 16 He recommends a change in the law in terms of 17 reputation above the interests of survivors, that it has 17 limitation to reflect the current position in Scotland 18 failed to offer adequate support, redress and apologies 18 in terms of the Limitation Act 2017. 19 to survivors, that it has placed the needs of abusers 19 He recommends that the Roman Catholic Church 20 and alleged abusers above those of victims and 20 introduce a centralised, electronic database detailing 21 survivors, that the seal of the confessional is contrary 21 the history of the movements of priests and members of 22 to the paramountcy principle and prevents an obstacle to 22 religious orders. 23 effective safeguarding and that the structures and 23 Finally, that the Roman Catholic Church in England 24 cultures of the Roman Catholic Church does not allow for 24 and Wales comply with and meet as a minimum the 25 a safe place for children and also provides for 25 standards set out in the UN Convention on the Rights of

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1 the Child report in 2014, namely, to take steps to 1 relation to the recommendations which this inquiry might 2 ensure that victims of sexual abuse should receive 2 make. 3 redress, including fair, adequate and enforceable right 3 The Catholic Council will also co-ordinate responses 4 to compensation and as full a rehabilitation as 4 from the dioceses and the religious orders who provided 5 possible, regardless of whether perpetrators of such 5 safeguarding files to Ms Carmi for the purpose of her 6 acts have been brought to justice. Accordingly, 6 report, as well as providing some responses from CSAS 7 measures should be taken to ensure the physical and 7 and the NCSC to other elements of that report. 8 psychological recovery and social reintegration of 8 The panel will be aware that Ms Carmi's report was 9 victims of abuse. This, madam chair, I submit, is not 9 not disclosed to core participants until very shortly 10 a lot for a victim to ask for. 10 before, and in part during the course of, this hearing. 11 Finally, madam chair, I wish to leave you with 11 All those institutions are now in the process of 12 a message/plea from G1. He simply asks you to bring 12 considering her full report very carefully, and their 13 forward recommendations to address the issues we have 13 detailed responses will be provided in writing. 14 heard so much about to at least in part help provide 14 But I would like to take this opportunity to focus 15 survivors with dignity. Thank you, madam chair. 15 on a number of specific steps that are already in train 16 THE CHAIR: Thank you, Mr Brodie. Finally, Ms Gallafent? 16 in relation to matters arising from Ms Carmi's report, 17 Closing statement by MS GALLAFENT 17 as well as some of the other evidence heard over the 18 MS GALLAFENT: Chair, members of the panel, good afternoon. 18 last fortnight. 19 We are grateful for the opportunity to provide the 19 Starting, if I may, with the Conference of 20 inquiry in due course with written closing submissions 20 Religious, they have noted the good practice that 21 following the conclusion of this hearing, and we will do 21 Ms Carmi identified in relation to the safeguarding 22 so. 22 files disclosed by the , known as the 23 As I have previously indicated, our primary focus 23 Jesuits. They have invited the safeguarding coordinator 24 will be to assist the inquiry on the suggestions that 24 of the Jesuits to the Conference of Religious 25 have been made by a wide range of individuals in 25 Safeguarding Committee -- I'm going to call it CORSC --

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1 to enable them to consider how good practice points can 1 cross-referencing, signposting and accessibility. They 2 be further disseminated to CoR's membership. CORSC will 2 will also be considering whether there should be any 3 also be meeting next Tuesday, 12 November, to reflect on 3 form of separate publication targeted at different user 4 the criticisms of congregations that have come out of 4 groups. 5 the inquiry's hearings and to decide what actions the 5 Now, this work will obviously need to take into 6 congregations should be taking in the light of these and 6 account the existing, well-regarded leaflet, "Hurt by 7 what preparation CORSC should be doing now to contribute 7 Abuse" which, as you heard from Mr Marshall, had been 8 to the independent review to be conducted by 8 prepared by the Survivors Advisory Panel. That's aimed 9 Ian Elliott. 9 at those who may wish to make a report of abuse, but 10 Later next week, on Thursday, a CoR general meeting 10 Mr Marshall also referred to a parallel leaflet which 11 is taking place where the general secretary and 11 they designed for those against whom allegations had 12 president will be speaking about this hearing and 12 been made. It doesn't appear that Ms Carmi was aware of 13 emphasising to all congregations that they need to be in 13 either of those two parallel leaflets and sources of 14 a state of readiness to reform and improve their 14 information, but they are clearly an element in 15 approach to safeguarding. Father Paul Smyth will be 15 considering the adequacy and the target audience for the 16 following this up in writing to all members of CoR. 16 national policies. 17 The Bishops' Conference will also be meeting in 17 Ms Carmi also identified a very specific issue in 18 plenary session on 25 to 28 November, when there will be 18 relation to the use of the CM1 form. She described it 19 a day devoted to the topic of safeguarding. That will 19 as an extremely useful form which prompts good practice. 20 include a review of these hearings again, it will 20 According to the national policy on the management of 21 include input from the NCSC and CSAS and further formal 21 allegations in relation to children, this form should be 22 safeguarding training for bishops. 22 used to record all casework. Because of the limits of 23 So far as national policies and procedures are 23 Ms Carmi's terms of reference -- we don't currently know 24 concerned, CSAS will be reviewing the structure of 24 the reason for its underuse, as she found. We don't 25 the current national procedures manual to ensure 25 know whether it is a lack of familiarity with it,

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1 a resistance in principle to its prescriptive nature or 1 protection is not a huge area of her expertise. 2 some other reason. Clearly, it is essential for us to 2 It is not immediately obvious to us that her 3 ascertain this in order to assist us in improving 3 suggestion of removing a third party's personal data 4 compliance with the national guidance in the light of 4 before disclosure to a complainant could assist, given 5 Ms Carmi's report. So CSAS will be following this issue 5 it is that very data that the complainant would be 6 up with all safeguarding coordinators as a matter of 6 typically seeking. These are obviously important and 7 urgency. 7 fundamental questions that aren't restricted to the 8 CSAS will also be considering whether a national 8 church. These are much more widespread questions that 9 policy should be created to cover the procedure which 9 require careful consideration more broadly. So CSAS 10 dioceses and religious orders should follow where 10 will be raising these issues with the national LADO 11 a complaint is made in relation to the handling of 11 network and other relevant organisations with a view to 12 a safeguarding allegation. In addition, it will be 12 ascertaining comparative practice in this context. 13 reviewing whether there is merit in a specific policy to 13 There's obviously considerable benefit in seeking to 14 cover the situation where a complaint is made that 14 tap into other organisations', external to the church, 15 a priest or a member of a religious order has failed to 15 experience and expertise on what is clearly a difficult 16 report safeguarding concerns to the appropriate person. 16 issue. 17 Another important issue which CSAS will be 17 The final immediate area that CSAS will be 18 considering arises from the evidence of A711 and one of 18 considering, in the light of all the evidence in this 19 the files provided to Ms Carmi by the Institute of 19 investigation, is the role of the safeguarding 20 Our Lady of Mercy. This is the extent to which the 20 coordinator. The panel may recall that in the report of 21 content of a risk assessment of an alleged perpetrator 21 the Cumberlege Commission, the responsibilities of 22 could, and should, be shared with a complainant. 22 the commission and the safeguarding coordinator were 23 Ms Carmi agreed this issue engages the legislative 23 identified in an annex. Those included supporting 24 framework for data protection and whilst she suggested 24 victims, supporting abusers, coordinating responses to 25 the problem could be overcome, she accepted data 25 allegations and risk management. As part of CSAS's

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1 engagement with Ian Elliott's independent review, it 1 the deepest regret and sorrow, for which 2 will reflect upon the ways in which those differing 2 Cardinal Nichols unequivocally apologised again 3 responsibilities should be distributed between different 3 yesterday. Thank you very much. 4 individuals and, in particular, how small safeguarding 4 THE CHAIR: Thank you, Ms Gallafent. That concludes the 5 teams might address some of the potential tensions that 5 closing statements. Ms Carey, do you wish to say 6 arise in this context. 6 anything else? 7 This will be raised at the next meeting of 7 MS CAREY: No, there is nothing on behalf of counsel to the 8 safeguarding coordinators which is scheduled for 8 inquiry. Thank you. 9 22 November 2019. 9 Closing remarks by THE CHAIR 10 The Catholic Council will, of course, provide the 10 THE CHAIR: Thank you. In that case, I would like to extend 11 inquiry with appropriate updates on all of these points, 11 our thanks as a panel. We are most grateful to all of 12 which are mostly taking place over the next couple of 12 the witnesses who have come to testify before the 13 months. As and when the expected order of recognitio is 13 inquiry over the last ten days, the complainant core 14 received from the Holy See, I can also assure you the 14 participants and those witnesses from the institutions 15 inquiries will be the first to be informed. 15 and all others from whom we have heard. 16 Can I then conclude by echoing the words of 16 We are also grateful to those who have gathered and 17 Cardinal Nichols yesterday, by welcoming the spotlight 17 sent evidence to the inquiry for the purposes of this 18 shone by the church by this inquiry, however painful 18 investigation. Today marks the end of the substantive 19 that process may be. In saying that, we fully recognise 19 hearings into the response of the Roman Catholic Church 20 that the process will inevitably have been far more 20 in England and Wales into child sexual abuse. The 21 painful for the victims and survivors, not only those 21 inquiry has now held four public hearings for this 22 who have been involved directly in this investigation, 22 investigation, and we will, of course, review all of 23 but for all of those who may have been following the 23 the material and evidence and prepare a further report 24 inquiry's progress by attending or viewing from afar. 24 which will set out our findings from this final hearing 25 Their pain and suffering remains a matter of 25 into current safeguarding practices within the Roman

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1 Catholic Church in England and Wales and we anticipate 1 Closing statement by MR O'DONNELL ...... 3 2 that the report will be published in the late summer of 2 3 2020. 3 Closing statement by MR GREENWOOD ...... 17 4 The panel and I wish to extend a special thanks to 4 5 each of the victims, survivors and complainants for 5 Closing statement by MS PATRICK ...... 28 6 their help and courage in giving us their individual 6 7 accounts. We could not have conducted this 7 Closing statement by MR JACOBS ...... 42 8 investigation without their contributions, so thank you. 8 9 We also wish to thank the institutions for their 9 Closing statement by MR COLLINS ...... 56 10 co-operation in gathering the evidence from a large 10 11 number of witnesses, covering such a broad range of 11 Closing statement by MR BRODIE ...... 61 12 topics. 12 13 Finally, to thank all of the representatives for 13 Closing statement by MS GALLAFENT ...... 73 14 their assistance and to all of the inquiry staff for 14 15 ensuring the smooth progress of the hearings. 15 Closing remarks by THE CHAIR ...... 80 16 With that, I will now draw the hearings to a close 16 17 and thank everyone very much. Thank you. 17 18 (12.45 pm) 18 19 (The hearing concluded) 19 20 20 21 21 22 I N D E X 22 23 23 24 Housekeeping ...... 1 24 25 25

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A 55:24 62:1 63:15 acknowledge 47:13 adults 30:5 39:24 amended 49:18 A117 8:25 9:11,18 64:7,8 65:5,8,11 acknowledging 40:8 46:23 69:5 10:2 11:8 16:18 65:20,25 66:11 53:10 advice 27:7 amends 50:5 A19 3:9,10,19 4:2 68:21,24 69:20 act 3:2 10:1,8 34:12 advised 4:15 9:21 amounts 43:6 4:11 5:12 70:4,8 71:16 73:2 34:18 37:9 39:5 11:20 62:20 Ampleforth 9:2 A20 4:13,18,19,25 73:9 76:7,9 80:20 41:13 68:24 72:18 advisor 21:4,9 21:15 5:6,12 abused 3:9 4:13 9:3 acted 33:7 advisory 4:6 9:22 ancient 69:16 A20's 4:15 5:5 12:21 13:8 15:14 acting 47:8 11:4 21:6 33:1 Anglican 21:1 58:5 A710 14:12,18,20 29:3 41:1 action 26:19 38:1 76:8 angry 28:21 A710's 14:7 abuser 5:15 7:6,8 47:2 64:22,23 advocated 17:20 annex 30:1 34:2 A711 5:13,17,25 12:10,22 13:12 69:1 afar 79:24 78:23 6:6 8:7,20 11:8 37:21 44:19 45:15 actions 13:15 30:19 afresh 38:19 anniversary 40:24 15:12 18:19 32:20 45:22 51:12 67:3 36:3 38:8 39:22 Africa 45:24 announcing 19:2 77:18 67:4 47:16 75:5 afternoon 73:18 anonymous 29:15 A711's 8:3 13:25 abusers 36:22,25 actor 28:16 age 5:19 answer 33:25 abandoned 3:12 69:7 71:19,20 actor's 28:20 aggravating 48:3 answerable 62:25 Abbey 18:7 78:24 acts 73:6 aggressive 68:9 67:20 abbeys 21:10 abusing 5:25 11:20 actual 10:11 11:1 ago 8:9 15:23 17:1 anticipate 81:1 abbot 9:7,8 12:5,8,16 51:25 addition 2:9 77:12 18:16 48:23 49:5 Anybody 37:20 abbots 21:11 52:1 additional 1:17 2:1 agree 18:10 24:3 apart 22:14 able 4:2 24:8 41:1 accept 20:23 21:1 2:8 49:1 apologies 28:6 62:21 63:3 60:1 address 3:4 30:20 agreed 3:16 77:23 71:18 absence 25:22 36:7 acceptable 49:7 42:13,20 46:10 agrees 37:7 70:19 apologised 44:11 absolutely 12:14 59:17,18 65:14 53:24 61:25 73:13 Aidan 9:8 80:2 absolution 12:22 71:14 79:5 aimed 76:8 apologising 40:18 absolutist 20:20 accepted 77:25 addressed 14:1,4 albeit 64:17 44:22 absurd 49:4 accepting 32:18 15:24 alcohol 3:21 apology 32:20 abundantly 56:24 accepts 13:5 adequacy 76:15 allegation 77:12 45:12 abuse 4:2 5:8,10,20 access 8:10 21:13 adequate 23:24 allegations 6:11 Apostolic 52:22 5:22 6:2,8 7:10 accessibility 76:1 27:3 64:4 71:12 15:7,17,20 23:15 63:2 9:11 10:1,8,12,17 accommodation 71:18 73:3 23:18 24:17 42:24 appalling 16:6 23:5 10:20,24 11:11 23:1 adhere 26:8 46:24 66:14 68:2 64:12 12:10,24 13:10 accorded 48:6 adjust 54:12 71:4,16 76:11,21 apparent 34:22 15:7,17 16:4,18 account 14:9 21:19 admission 11:21 78:25 57:7 60:22 18:4 19:17 20:16 27:4 40:7 76:6 admits 11:19 alleged 67:22 71:20 appeal 45:17 23:25 27:3 28:16 accountability admitted 7:8 12:4 77:21 appear 13:4 14:19 30:2,4 31:8,15,19 18:15 26:1 40:20 20:17 allow 21:13 54:12 17:5 42:4 76:12 31:22 32:1,8 accountable 35:16 admitting 12:16 71:24 72:4 appearance 16:3,9 33:19 34:10 39:11 accounts 81:7 adopt 40:4 allowed 27:7 63:20 appeared 15:8 39:23 40:9,25 accurate 16:8 adopted 15:5 72:14 44:18 42:17,25 43:6 accused 20:3 36:21 adopting 34:25 allows 68:1 appears 66:6 45:3,5,15 46:8,17 36:25 45:10 adoption 17:20 alongside 43:10 applicable 23:9 46:25 48:1,21 achieve 39:15 51:4 Adrian 2:7 18:10 Alternatively 72:11 applies 8:5 12:12 49:22 50:6 51:13 achieved 20:5 62:9 adult 44:25 Altman 19:1 47:5 apply 51:12 52:4 54:20 55:20 achieving 21:9 adulthood 39:25 52:25 appointed 22:24

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Epiq Europe Ltd www.epiqglobal.com Lower Ground, 20 Furnival Street (+44)207 4041400 [email protected] London EC4A 1JS IICSA Inquiry Roman Catholic Church Investigation Wider Hearing 8 November 2019 Page 85 capacity 7:18 66:1 15:12 16:7,21 central 43:21 charge 20:11 4:9,12 5:6,24 6:8 66:1 22:19 27:12 28:3 centralised 72:20 charged 65:14 6:9,11,14,24 7:14 captured 26:12 35:20 45:16 50:5 centuries 41:6,7 Charities 18:3 8:5,11 9:20,25 card 8:16 18:20 51:1,12 52:15 63:18,23 Charity 18:1 10:7,17,20,23 31:1 54:6 64:23 66:17 century 49:7 58:6 CHC000582 1:20 11:7,10,15 12:4 cardinal 6:20 7:17 69:19 80:10 59:14,19 chief 48:12 12:25 13:14,16,23 7:21 9:7 13:5,20 cases 26:21 37:15 certainly 52:19 child 2:7 4:15 5:9 14:22,24 15:5,16 14:10,17,25 17:4 40:9 62:3 66:22 62:9 66:7 67:1 10:12,19,24 11:11 15:20,22,25 16:2 31:4,4,7,12,17 68:21 chair 1:3,6 2:7,14 13:8 15:10 17:23 16:9,19 17:5,12 32:9,11,18,21,23 casework 76:22 2:20,24 3:2 5:4 18:10 20:16 22:9 19:6,8,11,23 20:4 32:24 33:4,20 casting 20:4 6:2 8:18,25 11:23 22:11 23:12,13 20:9 21:1 23:6 34:1,15 35:9,11 catalogue 19:17 14:5 15:21 17:8 27:3 28:16,18,24 24:1,4,8,12,19,25 38:18 39:1,13 category 25:9 17:10 18:18 22:15 29:14,21 30:8 25:4,6,7 30:3,5,6 46:13,20 51:14,19 Catholic 3:7,10 4:5 27:22,23 28:2 31:15 32:7 33:19 30:14,18,19,24 52:25 54:13,18 4:6 5:3 6:19 7:22 31:14 39:5 40:2 41:4 42:16,25 31:13 32:12 33:2 57:13 58:4,6,8 9:22 10:7,11,20 41:22,23 42:2,4 44:25 45:23 46:25 33:5,10 34:25 59:16 61:2 62:18 11:2,3,7,10,18 42:14 43:2,9,18 48:21 49:21 60:7 35:4,6,17 36:5,9 64:19 65:24 66:2 12:4 13:16,21 46:11,16,20,22 60:11 62:1 63:15 37:6,20,23 38:2,6 70:24 79:17 80:2 14:22 15:5,9,16 47:13,20 48:4 65:20 68:21 70:4 38:8,17,23,23,25 cardinal's 14:6,10 15:22,24 16:9 49:3,4,11,24 70:7 73:1 80:20 39:5,9,19,20 40:7 32:7 34:8,13 52:6 17:5,12,15 19:6 50:14 52:2,6,12 childhood 31:8 40:12,14,18,25 cardinals 56:19 19:11,14,25 20:18 54:5,16,24 55:7 32:5 39:12 68:24 41:5,6,7,14,19 care 14:19 17:14 20:20 24:12,19 55:22 56:1,7,12 children 3:8 11:20 42:10,12,16,24 20:22 23:9 24:19 25:6,7 37:5 41:6 56:14 61:15,16,18 12:5,8,16,21 13:3 43:5,11,12,20,22 25:10 27:20 28:22 42:16 43:5,22 63:13,19 65:6,18 16:4 17:2,13 44:12,16 46:10 30:2 31:24 41:4 44:12,16 46:10,12 65:23 66:12,25 20:22 23:9 24:20 47:19,20,21,21 42:13 65:9 67:6 46:21,22 47:19 68:5 69:3,12,17 25:3,7,9,22 26:4,5 48:5 49:9,13,15 careful 78:9 49:8,13,15 51:10 70:17 71:7 72:2 27:18,20 31:23 51:8,10,17,20 carefully 74:12 53:7 54:17 55:1 73:9,11,15,16,18 38:17,19 39:23 52:7,9 53:7,9,16 Carey 1:4,6 2:24 55:12,15,19,23 80:4,9,10 82:15 42:13 45:24 46:23 53:18,21 54:10,12 41:23 80:5,7 56:22 57:2,7,16 chance 19:16 20:8 48:1,7 49:10 50:1 54:17,20 55:1,2,3 Carmi 22:17,25 57:21,23 58:3,5 59:11,12 52:2,8,16 53:8 55:12,15,15,19,23 36:11 37:3,6,10 58:17,19 59:2,13 change 13:18 15:9 54:10 55:20,25 56:3,5,23 57:2,8 37:18 38:12 39:18 59:25 60:14,17,19 15:25 16:1 20:9 56:4 57:25 59:8 57:16,22,23 58:3 40:15 45:25 46:3 61:24 63:22 64:7 34:22 39:17,19 61:14 63:21 68:4 58:5,5,17,19 59:2 50:8 66:9,15,18 68:15 71:10,24 41:18 54:19 55:2 71:11,25 76:21 59:13,25 60:14,17 67:12 70:10 74:5 72:19,23 74:3 63:23 68:20 69:23 children's 25:15 60:19 61:3,25 74:21 76:12,17 79:10 80:19 81:1 70:23 72:16 chocolate 4:23 62:11,22,24 63:18 77:19,23 Catholicism 42:10 changed 30:24 31:6 choice 34:5 35:7 63:25 64:3,7 65:5 Carmi's 70:19 74:8 Catholics 52:17 68:23 choose 63:1 70:1 65:16,18 66:7,10 74:16 76:23 77:5 cause 8:14 Changing 39:10 chooses 60:19 66:13 67:8,10,16 carry 22:22 caused 46:6 55:5 channels 63:7 choosing 59:7 67:20,25 68:8,10 case 2:17 3:3 7:11 63:10 chapel 45:7 Christopher 1:20 69:2,17 71:10,24 8:25 9:12 11:14 CDF 22:2 54:22 characterised 39:8 55:11 72:9,19,23 78:8 13:25 14:1,2,4 celibacy 49:24 48:17 51:7 church 1:21 3:7 4:5 78:14 79:18 80:19

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81:1 82:3,5,7,9,11,13 Committee 23:12 15:21 55:10 79:16 confused 49:22 church's 10:2,11 82:15 74:25 concluded 81:19 Congregation 1:24 10:13 15:9 20:8 clothing 3:19 common 21:6 concludes 80:4 9:4 46:14 20:20 54:6 63:15 CM1 76:18 45:20 conclusion 16:20 congregations 54:3 church-instructed co-operate 23:20 communicate 66:3 55:7 73:21 75:4,6,13 7:5 24:5 communication conclusions 39:7 connected 67:11 churches 21:19 co-operation 53:2 33:3 47:13 52:13 conscious 40:2 26:2 81:10 community 20:7 concrete 38:1 consequences CICA 27:6 co-ordinate 74:3 comparative 78:12 conducive 25:3 60:20 circumstances Colette 4:7 compel 13:24 26:15 67:25 conservative 20:10 34:18 colleague 44:8 26:20 conduct 47:15 55:3 consider 11:13 12:1 cited 21:9 Collins 56:12,13,14 compelled 13:9 55:16,18 25:17 30:13 31:11 city 48:14 61:16 82:9 compelling 54:5 conducted 46:1 31:16 40:3 43:2 civil 23:20 26:16 collusion 10:8 compensate 23:25 75:8 81:7 48:12,20 68:17 36:7 71:1 Comboni 42:16 compensation 4:3 conducting 38:4 75:1 civilised 59:18 44:7,16 45:14 23:24 24:9 26:22 conference 46:21 considerable 36:20 claim 4:3 46:3,16,18 47:4 27:3 73:4 51:16 53:4 62:13 55:2 78:13 claiming 10:18 47:10,15 complain 7:19 74:19,24 75:17 consideration claims 14:6 68:8 come 5:4,18 11:11 complainant 26:24 conferences 54:3 37:16 66:23 78:9 clean 54:13 16:1 20:1 35:15 42:5 77:22 78:4,5 56:20 considered 5:14 8:4 cleaning 53:14 57:2,18 59:6 75:4 80:13 confess 56:21 32:6 43:10 clear 13:7 21:4 80:12 complainants confesses 13:8 considering 74:12 41:17 49:11,19 comes 15:10 37:14 18:23 26:14 27:7 confessing 12:8 76:2,15 77:8,18 51:17 56:24 58:22 56:24 57:3 59:3 81:5 confession 11:16,20 78:18 clearly 76:14 77:2 59:25 65:19 66:21 complained 5:3 12:5,8,13,16,20 considers 52:22 78:15 comfort 35:3 68:25 complaint 6:16 9:6 12:23 13:9,24 consistent 33:10 clergy 20:3 21:13 comfortable 33:4 9:10 10:4 26:25 51:13 57:14,18 51:20 21:20 22:23 23:15 coming 65:4 77:11,14 59:20,21 69:13 constitutions 47:23 23:25 37:8 50:10 comment 8:17 complaints 4:9 70:2,17 contact 4:4 35:6 64:16 65:2 67:14 18:19 38:21 16:16 26:12 43:4 confessional 11:13 contacted 3:14 6:10 67:21 72:13 comments 64:20 43:7 12:12 16:25 20:14 9:15 22:1 clerics 48:2 55:21 commission 7:22 completely 19:3 20:16,20,21 21:2 contain 8:16 18:21 client 45:14 8:19 11:3 18:1,3 45:3,4 24:22 51:14,18 contained 46:16 clients 32:17 42:9 18:18 20:18 43:15 compliance 10:18 52:2,4 69:20,22 content 77:21 42:14,20 44:2,13 46:12 53:12 64:14 50:24 77:4 70:4,13 71:4,21 context 57:25 61:5 45:20 46:3 47:7 64:16,21 72:11,15 comply 72:24 confidence 14:16 66:12 67:9 78:12 47:13 54:8 55:11 78:21,22 comprised 47:22 41:16 65:4,10 79:6 Clifton 21:4,8 commissioner 59:1 compulsory 25:25 69:10 continually 10:17 close 61:1 81:16 60:16 concentration 61:8 confirmed 31:5 continue 16:2 closely 67:11 commissions 56:20 concern 10:9 14:11 46:13 23:22 24:16 closing 1:6 2:21,23 65:3 72:12 concerned 14:23 conflict 50:10 continued 4:25 3:1,4 17:9 28:1,8 commit 5:7 70:7 75:24 67:13,23 continues 5:10 57:3 30:15 37:10 42:3 commitment 20:2 concerns 8:9 46:11 conflicts 22:23 continuing 53:18 56:13 61:17 73:17 23:3 28:5 67:12 70:12 77:16 conforms 59:13 continuity 11:6 73:20 80:5,9 82:1 committed 46:18 conclude 14:6 confronted 44:19 contradictions

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22:15 costs 23:2 27:8,11 critics 22:11 34:1,4,5,12,13,17 33:24 contrary 68:11 Council 11:18 74:3 Croome 31:25 34:21 35:10,19,23 declined 63:8 71:21 79:10 cross-referencing 35:24 36:3,17 decree 19:21 21:23 contrast 22:25 counsel 2:20 31:17 76:1 37:3,24 40:1,25 24:4 38:10 51:3 37:15 39:17 44:5 66:16 80:7 crying 29:8 41:3,11 62:15 63:5 47:14 66:22 counselling 4:14 CSAS 2:9 9:23,23 D2's 28:24 31:22 decreta 43:16 contribute 75:7 counted 41:14 21:5,11,22 22:6 34:2 50:15,17 51:11 contribution 27:8 countries 17:2 39:2 36:8,13 37:10 damage 55:5 62:6 contributions 81:8 country 46:19 50:24 74:6 75:21 damaged 53:21 dedicated 25:23 control 18:1 25:4 48:13,14,19 52:17 75:24 77:5,8,17 Damascus 31:12 deemed 32:21 Convention 72:25 57:8 69:8,8 78:9,17 damning 37:22 deep 18:22 conversation 14:10 couple 79:12 CSAS's 78:25 danger 20:22 68:4 deepest 80:1 33:4 courage 39:11 cultural 13:18 dangerous 3:7 deeply 8:12 20:10 converted 58:4 41:13,20 81:6 15:25 46:4 53:23 dangers 24:22 64:15 convicted 36:22 courageous 39:5 culturally 43:23 Danny 39:7 46:11 deeply-rooted 67:3 course 1:9,16 6:6 culture 13:16 15:10 47:11 51:7 48:18 conviction 13:12 6:15 7:19 13:3 17:18 53:6 57:6 dare 12:16 defect 25:24 50:12 41:20 67:5 14:2,4 32:24 49:4 57:10 60:6,9,12 data 77:24,25 78:3 defence 57:17 coordinating 78:24 54:24 56:18 62:15 66:12 67:9 68:1 78:5 68:14,21 coordinator 6:9 7:3 63:2 64:9 68:7 cultures 71:24 database 72:20 defences 68:18 15:16 29:7 35:25 69:14 73:20 74:10 Cumberlege 18:13 date 24:2 43:18 defend 53:22 36:20,24 37:4 79:10 80:22 19:7,21 20:6 day 1:4 5:11 31:10 defensive 6:24 67:14,20 74:23 Court 31:25,25 38:15 43:15,19 33:12,24 34:24 deference 17:18 78:20,22 courts 69:10 53:19 54:25 58:21 38:12 40:24 41:2 48:6,8 55:14,18 coordinators 22:3 cousin 3:14 60:22 61:22 62:4 41:12 42:19 43:3 55:23 22:24 24:23 37:9 cover 10:17 42:22 62:5 63:17,24 44:4,18 46:13 defined 37:1 77:6 79:8 77:9,14 71:15 78:21 47:5,9 48:9 51:21 delay 53:17 COPCA 9:9 21:3,8 covered 10:1 cup 54:14 53:13 54:19 75:19 deliberately 10:17 31:14 covering 81:11 currency 18:17 days 42:14 56:19 demanding 30:9 CoR 75:10,16 coverup 10:7 19:17 27:16 80:13 demeanour 8:3 CoR's 75:2 Coyle 2:13 current 69:5 72:9 dead 35:24 36:2,5 demonstrate 15:9 core 1:7 17:10 28:3 CPS 26:21 72:12,17 75:25 deal 1:8,17 15:20 demonstrated 18:6 42:5 56:15 74:9 cracks 28:20 80:25 26:1 67:6 68:25 20:2 22:8 80:13 created 22:23 77:9 currently 49:23 dealing 15:10 46:24 demonstrates 23:5 Cormac 14:17 creation 17:21 63:21 76:23 64:6 65:20 47:18 57:21 65:23 corporate 26:7,7,12 25:17 curve 16:12 death 3:11 57:17 described 3:15 6:22 39:19 credible 23:17 cut 29:12 61:9,12 7:15 8:11 9:3 correct 51:1 62:10 cried 29:5 cynicism 18:23 decade 63:24 21:14 32:11 38:12 corresponded criminal 6:10 10:10 decades 41:1,3 43:8 39:9 64:14 76:18 47:11 13:12 16:20,22 D 49:5 describes 9:14 10:3 correspondence 72:6 D 81:22 December 18:11 describing 5:15 47:6 crisis 10:23 D2 28:2,10,25 29:3 32:24 description 53:14 CORSC 74:25 75:2 criticised 16:14 29:9,15,19,22 decide 26:23 31:1 designed 40:20 75:7 criticism 30:5 30:15 31:2 33:13 75:5 49:25 52:7 76:11 cost 11:9 27:9,10 criticisms 75:4 33:17,21,22 34:1 decision 17:17 despite 3:5 63:6

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Epiq Europe Ltd www.epiqglobal.com Lower Ground, 20 Furnival Street (+44)207 4041400 [email protected] London EC4A 1JS IICSA Inquiry Roman Catholic Church Investigation Wider Hearing 8 November 2019 Page 89 escalated 5:22 exceptionally 33:17 exploited 69:18 77:15 film 28:12,13,15 escape 6:6 exceptions 16:24 exploiting 21:12 failing 10:8 final 1:3 15:21 16:7 espouses 24:12 exchanges 4:11 8:5 exported 33:12 fails 12:13 71:6 16:21 78:17 80:24 essential 59:25 77:2 9:17,18 expose 19:10 failure 16:18,19,21 finally 30:18 40:18 establish 26:1,3 excommunicated express 58:18 24:25 42:12 49:23 40:23 62:14 72:2 established 21:18 12:20 13:13 70:5 expressed 67:12 55:20 57:4 63:9 72:23 73:11,16 22:17 excommunication extend 80:10 81:4 failures 18:6 36:13 81:13 establishing 23:13 70:6,9 extension 18:8 36:15 57:4 financial 36:20 estis 50:3 excuses 19:14 extent 61:24 77:20 fair 23:24 73:3 72:7 European 48:14,19 executed 61:7 external 48:16 faith 46:14 61:10 find 49:7 58:21 events 14:21 Executive 17:24 78:14 faith-based 25:2 61:22 65:10 66:9 eventually 7:11 25:21 externally 16:22 faltered 5:8 66:10 71:9 Everybody 14:18 executives 48:12 extraordinarily familiar 2:7 30:23 finding 52:21 evidence 1:16 3:5 exemplary 47:15 45:16 37:18 38:20 findings 5:16 63:12 5:17 6:18 8:24 exercised 50:25 extremely 37:13 familiarity 76:25 71:8 80:24 9:1,6,13 11:14 exert 69:19 45:5,6 66:20 families 37:17 finds 29:16 33:10 12:18 13:4,6,22 exhausting 7:2 76:19 66:24 33:17 70:20 14:5,21,25 15:11 exhibits 1:11 eyes 12:24 58:9 family 3:12 29:20 Fines 26:11 16:6,7 18:25 existing 11:24 76:6 41:3,14 55:19 fingers 4:1,22 20:17 21:6 22:17 expand 18:9 60:5 F 67:9 finished 4:22 23:22 31:3 32:15 expanding 38:2 F48 44:10 family-like 67:25 firm 56:16 32:25 34:8,17 expansion 38:5 F49 44:10 far 6:21 12:3 16:2 firmly 24:1 25:2 35:18,19,20 36:19 expect 65:8 68:11 F500 5:15,20 6:6 31:18 58:21 63:20 first 2:23 3:9 4:2 37:7 39:1 42:14 expectation 6:22 15:15 75:23 79:20 6:17 14:25 15:15 42:17,20 43:25 expected 6:19 F515 3:14,16 4:13 Farrer 2:12 15:23 28:22 29:19 44:1,14,17,23 30:23 59:13 79:13 4:15 5:2,5 father 3:11 44:20 30:15,21 35:4,5,6 45:21,25 46:13 expedient 59:23 F53 44:10 44:21 75:15 35:24 41:12 44:4 47:3,12 49:11,17 expense 57:24 F58 44:10 fault 8:6 58:10 79:15 50:8 52:3,14,19 experience 6:13,21 F6 45:21 47:9 favour 68:19 firstly 3:4 10:13 53:5,8,9,11 54:5 29:21 30:14 31:13 F710 14:1 February 31:6 65:1 55:6 56:1 57:13 33:6,10,14 45:6 F710's 14:3 32:12 34:22 40:24 fit 10:14 20:10 25:6 60:23 62:2,11,18 64:12,17 66:8 F80 9:4 53:4 35:2 37:24 38:14 63:16 66:9,15 67:2 78:15 face 6:23,23 31:20 feedback 7:7,14 five 11:23 68:7 70:12,22,23 experienced 30:17 31:20 68:10 feel 4:11 8:1 34:12 flavour 30:16 74:17 77:18 78:18 31:5 64:6 facilitated 19:17 34:15 66:25 Flossenbuerg 61:7 80:17,23 81:10 experiences 9:12 facing 39:11 feeling 45:1 flourish 59:12 evils 31:15 10:4 29:24 31:10 fact 3:5,6 45:24 feelings 34:6 focus 14:12 42:23 ex-headmaster 9:7 32:9 35:14,19 52:21 66:19 feels 33:13 67:22 67:10 73:23 74:14 exacerbated 48:5 36:16 54:25 factor 48:3 felt 6:25 10:2 34:4 focused 14:6 41:10 exactly 67:1 experiment 25:11 factors 27:5 34:6 41:1 focuses 31:2 example 13:19 19:1 expertise 78:1,15 fail 57:3 72:7,8 fighting 61:11 follow 4:11 52:7 48:8 expertly 22:17 failed 9:9 10:1 file 2:15 29:3,10,12 71:13 77:10 examples 22:18 explain 29:17 57:1 25:11 27:15 32:19 files 46:2 66:17 followed 9:17 32:1 35:22 38:7 explicit 31:18 43:11 57:2 61:25 74:5,22 77:19 following 8:7 15:3 exception 21:2 explicitly 14:17 71:10,11,13,18 filled 18:2 36:2 39:10 65:3

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Epiq Europe Ltd www.epiqglobal.com Lower Ground, 20 Furnival Street (+44)207 4041400 [email protected] London EC4A 1JS IICSA Inquiry Roman Catholic Church Investigation Wider Hearing 8 November 2019 Page 96 put 6:18 10:6,14 re-traumatising recommendation regard 67:12 reluctant 21:13 40:15 57:17 67:17 35:7 30:8 43:15 51:15 regarded 51:24 remain 22:3 68:3 reach 38:22 39:6 62:5 63:14 70:25 regarding 63:16 remains 3:7 8:19 read 1:25 2:9 11:14 recommendations 70:12 14:22 79:25 Q 12:18 13:6 21:21 9:24 15:6 20:6 regardless 73:5 remarkable 70:20 QC 28:4 30:11 29:18 42:18 49:17 23:11 27:17 38:22 regards 62:3 63:4 remarks 80:9 82:15 31:10 47:5 52:3 69:15,21,24 44:3 71:14 72:3 regions 38:3 remember 7:4 9:1 quality 27:4 70:22 73:13 74:1 register 26:3,6,6 52:2 question 11:12 readiness 75:14 recommended 3:14 regret 80:1 reminded 61:6 30:16 65:20,21 real 16:1 24:14 43:12 48:23 regularly 66:4 reminding 23:10 66:18 29:25,25 30:2,3 recommends 72:16 regulated 26:8,10 removal 45:22 questioned 37:4 35:14 41:18 62:21 72:19 26:14 remove 3:19 54:9 52:25 realise 31:14 38:24 reconstruct 45:3 regulation 60:4,24 removed 25:4 questions 65:1 78:7 realism 30:12 record 22:22 76:22 regulator 18:5 removing 78:3 78:8 realities 30:17 recorded 20:17 58:25 60:16 reparations 27:11 quick 30:22 33:22 reality 16:12 30:13 33:15 regulatory 51:6 repeat 11:21 35:21 34:11,11 40:4 30:20 35:17 37:25 records 32:2 54:11 58:3 60:9 quite 39:3 58:22 really 36:13 recouped 27:12 rehabilitation 73:4 repeatedly 3:25 67:21 rear 3:25 recourse 50:21 reinforced 43:14 7:20 39:8 quote 10:9 44:23 reason 53:20 76:24 69:9 reintegration 73:8 repeating 44:23 57:15 58:3,4 77:2 recover 34:7 55:4 reject 13:23 34:21 rephrase 45:4 quoted 53:13 reasonable 26:19 recovery 73:8 49:14 59:17 replaced 72:10 71:13 recurring 55:8 rejected 51:16 report 13:10,11,11 R reasons 5:18 52:8 redress 26:23 27:18 70:25 15:3 16:18,21 Rachel 2:3 reassured 66:4 40:21 71:18 73:3 relate 55:24 24:25 36:11 37:7 radical 20:9,10 rebuked 52:5 reduce 32:22 relating 44:1 39:18,24 40:15 32:13,14 34:22 recall 9:5 16:1 32:5 reduced 33:9 relation 1:21 2:10 43:3,14,15 46:4 37:25 54:23 44:18 45:20 50:7 refer 22:16 26:21 12:12 18:3 42:15 50:6 61:21,21 raised 67:8 70:12 53:11 78:20 42:19 47:2 51:23 43:5 47:19 53:15 65:5,8 70:11,16 79:7 receive 23:1 73:2 53:23 54:1 55:7 68:20 70:13 74:1 72:7 73:1 74:6,7,8 raising 78:10 received 50:18 reference 1:10 74:16,21 76:18,21 74:12,16 76:9 range 73:25 81:11 79:14 38:20 76:23 77:11 77:5,16 78:20 ranks 10:2,24 receiving 52:4 references 1:14 Relativity 1:13 80:23 81:2 rape 31:23 reckoning 41:8 47:3 relevant 23:10 26:3 reported 6:8 15:13 raped 5:15 6:8 recognise 55:17 referred 1:15 8:3 27:5 78:11 24:17 30:4 40:25 15:15 29:3 79:19 43:3 46:25 47:5 reliance 17:16 64:8 71:5 rare 24:10 recognised 49:20 47:11 76:10 68:13,14 reporting 10:12 rarer 24:10 49:22 reflect 72:17 75:3 reliant 23:7 15:14 16:23 17:1 RC-A710's 2:17 recognitio 43:17 79:2 religious 11:5 20:1 17:20 21:2,18 32:17 62:7 79:13 reflection 51:9 20:7 45:19 47:22 24:16 26:13 40:10 RC-A711 2:15 recognition 50:19 reform 53:16 75:14 48:9 52:8 54:3 51:18 57:14 59:22 64:12 51:4 65:17 refuse 34:5 52:7 68:12 72:22 74:4 60:25 64:3,7 70:3 RC-F515 3:10 recommend 17:19 refused 47:6,12 74:20,24 77:10,15 71:3 72:5 re-traumatised 18:8 54:8 56:2 refusing 55:16 reluctance 22:22 reports 12:10 20:16 45:18 72:3 regaining 45:2 24:24 39:24 40:8

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Epiq Europe Ltd www.epiqglobal.com Lower Ground, 20 Furnival Street (+44)207 4041400 [email protected] London EC4A 1JS IICSA Inquiry Roman Catholic Church Investigation Wider Hearing 8 November 2019 Page 98 seen 19:16 49:20 sexually 3:18,20,23 situation 45:4 49:8 74:15 76:17 77:13 63:8 73:17 82:1,3 sees 63:9 4:13 5:20 12:5 77:14 speed 39:16 82:5,7,9,11,13 self-governance 13:8 Slater 3:3 Speight 55:11 statements 1:10,17 17:13,14 shaken 28:11 37:19 slowly 55:1,4 64:1 spent 41:4 65:12 1:19 2:2,9,11 30:6 self-harm 34:6 share 9:20 slowness 53:22 sphere 25:1 80:5 self-interest 35:4 shared 7:1 64:17 small 19:10 34:12 Sphinx 53:14 54:13 states 46:3 self-protection 77:22 48:14,19 49:3 spiritual 54:15 status 17:19 21:23 19:18 shatters 65:25 56:25 79:4 spoke 15:17 31:19 26:7 Self-regulation Shearer 21:3,8 smelled 29:2 spoken 65:2 statute 27:1 25:11 27:15 shocking 17:3 smiling 28:18,24 spotlight 28:12,15 statutory 11:21 self-reported 12:6 64:11 30:8 29:24 37:19 79:17 17:22 25:18,23 seminary 45:22 shone 79:18 smooth 81:15 squat 5:9 26:18 40:10 58:25 46:25 shook 34:2 Smyth 75:15 staff 31:22 81:14 60:4 72:6,13 sends 28:6 shopping 30:19 soap 39:21 stall 63:20 step 6:25 24:2 senior 5:3 13:20 short 30:18 56:10 social 21:7 26:17 stand 13:7 40:14 25:15 65:19 71:2 21:7 45:23 shortly 5:18 74:9 73:8 47:1 50:17 steps 24:9 25:1 sent 45:24 80:17 show 65:18 society 48:17 56:4 standard 23:6 27:1 45:11 73:1 74:15 separate 37:1 54:6 showed 22:25 59:14 61:13 65:19 standards 17:23 stipulations 24:3 76:3 44:21 74:22 20:12 23:4,13 stolen 39:12 September 9:15 showing 10:6 20:5 sofa 3:20,23 25:13,19 26:9 stood 53:1 43:13 shows 61:24 solicitors 28:8 43:24 50:23 54:8 stop 5:1 16:5 35:13 series 27:5 shut 37:22 solution 49:16 59:3,10 60:5,7,13 40:18 serious 25:24 shutting 37:11 50:16 72:25 stops 12:25 serve 72:14 side 12:1 somebody 49:21 standing 19:25 story 28:21,25 service 4:6 9:23 sideline 22:10 soon 3:25 4:11 5:22 61:8 29:24 32:22 11:4 23:6 37:13 significance 62:5 45:7 62:20,21 star 57:22 stressful 6:13 66:20 68:16 significant 48:2 sorrow 80:1 stark 37:14 39:19 strip 3:22 4:20 services 26:17 63:9 sorry 30:24 66:21 strong 25:12 67:21 session 75:18 signposting 76:1 sort 18:14 starkly 35:18 37:1 struck 3:24 66:17 sessions 4:14,16,18 similar 17:24 25:20 sought 45:17 71:15 44:17 structurally 43:23 4:24 36:12 48:10 60:13 sounds 38:6 start 40:16 structure 1:21 set 24:13 72:25 64:11 sources 76:13 starting 7:15 43:1 17:16 26:7 53:7 80:24 similarly 50:14 sovereign 49:3 74:19 54:1 71:12 72:9 setting 9:12 64:22 69:5 52:18,24 starts 13:18 75:24 settle 52:9 simple 66:6 space 65:7 state 27:12,20 structures 53:16 severe 69:25 simply 6:4 7:13 Spaces 19:20 48:14 49:3 64:1 54:12 71:23 sex 5:23 20:16 27:3 10:14,14 21:5 speak 4:19 21:25 70:18 75:14 struggling 22:16 sexual 9:10 10:12 37:8 41:21 54:4 65:11 state-level 24:15 studied 52:1 10:20 11:11 12:24 60:2,21 65:13,17 speaking 75:12 stated 15:4 studies 22:19 13:10 16:4 28:16 73:12 speaks 28:19 58:15 statement 1:22 2:6 study 3:3 8:25 9:12 31:15,23 32:3,8 Sister 24:6 39:4,8 58:15 2:8,16,17 3:1 9:11 11:14 14:3 15:12 42:17,25 46:17 39:16 53:11,20 Spear 62:10 15:2,4,8,13 17:9 16:8,21 28:4 49:22 55:13 63:15 54:1 62:1 63:17 Spears 19:22 28:1 29:18 31:22 35:20 52:15 54:6 65:20 68:21 70:4 sits 44:8 53:2,12 special 43:17 81:4 33:15 34:4 41:12 subject 8:9 48:16 70:8 73:2 80:20 sitting 30:1 31:20 specific 38:22 50:5 42:3 56:13 61:17 64:12 70:8,18

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