1 1 COMMONWEALTH of MASSACHUSETTS 2 COUNTY of MIDDLESEX 3 GREGORY FORD, Et Al., Plaintiff, 4 Superior Court Vs
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1 1 COMMONWEALTH OF MASSACHUSETTS 2 COUNTY OF MIDDLESEX 3 GREGORY FORD, et al., Plaintiff, 4 Superior Court vs. Civil Action 5 No. 02-0626 BERNARD CARDINAL LAW, a/k/a, 6 CARDINAL BERNARD F. LAW, Defendants. 7 --------------------------------- PAUL W. BUSA, 8 Plaintiff, 9 vs. Civil Action No. 02-0822 10 BERNARD CARDINAL LAW, a/k/a, CARDINAL BERNARD F. LAW, et al. 11 Defendants. ------------------------------------- 12 ANTHONY DRISCOLL, Plaintiff, 13 vs. Civil Action 14 No. 02-1737 BERNARD CARDINAL LAW, a/k/a, 15 CARDINAL BERNARD F. LAW, et al. Defendants. 16 17 THE SECOND DAY OF THE VIDEOTAPED DEPOSITION OF CARDINAL BERNARD F. LAW, a witness called by 18 the Plaintiffs, taken pursuant to the applicable provisions of the Massachusetts Rules of Civil 19 Procedure, before Kathleen M. Silva, Registered Professional Reporter and Notary Public in and 20 for the Commonwealth of Massachusetts, at the offices of Greenberg Traurig, One International 21 Place, Boston, Massachusetts 02110, on Friday, June 7, 2002, commencing at 9:03 a.m. 22 K. L. GOOD & ASSOCIATES 23 P. O. BOX 6094 BOSTON, MASSACHUSETTS 02209 24 TEL. (781) 598-6405 - FAX (781) 598-0815 2 1 APPEARANCES: 2 Greenberg Traurig (by Roderick MacLeish, Jr., Attorney, Robert 3 Sherman, Attorney, David G. Thomas, Attorney, and Courtney Pillsbury, Attorney) 4 One International Place Boston, Massachusetts 02110 5 Attorneys for the Plaintiffs 6 (by Jeffrey A. Newman, Attorney) One Storey Terrace 7 Marblehead, Massachusetts 01945 Attorneys for the Plaintiff 8 The Rogers Law Firm, PC 9 (by Wilson D. Rogers, Jr., Attorney, Wilson Rogers, III, Attorney, Mark Rogers, Attorney, 10 Francis J. O'Connor, Attorney) One Union Street 11 Boston, Massachusetts 02108 Attorneys for the Defendants 12 Todd & Weld 13 (by J. Owen Todd, Attorney) 28 State Street 14 Boston, Massachusetts 02109 Attorneys for Cardinal Law personally 15 ALSO PRESENT: Rodney Ford 16 Paula Ford Father John Connolly 17 Father Christopher Coyne George Libbares 18 Wayne Martin Sandy Grossman 19 Shirley Fairclough 20 21 22 23 24 3 1 WITNESS 2 Page CARDINAL BERNARD F. LAW, 6 3 Resumed 4 EXAMINATION BY MR. MacLEISH 5 DIRECT EXAMINATION 7 6 INDEX OF EXHIBITS 7 21 Excerpt of Deposition from 21 8 Father Higgins 9 22 Excerpt of Father Higgins 27 Deposition 10 23 Handwritten Document 29 11 24 Letter 61 12 25 Letter, 11/17/77 71 13 26 Letter, 10/4/77 72 14 27 Letter, 12/2/77 76 15 28 Letter, 4/2/79 83 16 29 Memorandum, 4/6/79 93 17 30 Letter, 4/6/79 94 18 31 Letter, 4/12/79 97 19 32 The Homosexual Network 102 20 33 Handwritten Document 104 21 34 Letter, 6/1/83 106 22 35 Handwritten Document 108 23 36 Handwritten Note 110 24 4 1 INDEX OF EXHIBITS 2 37 Handwritten Document 111 3 38 Letter, 7/13/83 112 4 39 Letter, 12/11/84 118 5 40 Memorandum, 7/11/96 130 6 41 Photograph 135 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 5 1 ********* 2 THE VIDEOGRAPHER: We are now recording 3 and on the record. My name is George Labbares. 4 I'm a certified legal video specialist for 5 National Video Reporters, Incorporated. Our 6 business address is 58 Batterymarch Street, Suite 7 243, Boston, Massachusetts 02110. 8 Today is June 7, 2002, and the time is 9 9:05 a.m. This is Volume 2 in the deposition of 10 Cardinal Bernard Law in the following actions 11 being heard in Middlesex Superior Court: Gregory 12 Ford, et al., Plaintiffs, versus Cardinal -- 13 versus Bernard Cardinal Law, a/k/a Cardinal 14 Bernard F. Law, Defendant, Civil Action 02-0626; 15 and Paul W. Busa versus Bernard Cardinal Law, 16 a/k/a Cardinal Bernard F. Law, Defendant, Civil 17 Action 02-0822; and Anthony Driscoll, Plaintiff, 18 versus Bernard Cardinal Law, a/k/a Cardinal 19 Bernard F. Law, Defendant, Civil Action 02-1737. 20 This deposition is being taken at One 21 International Place, Boston, Massachusetts, on 22 behalf of the plaintiffs. 23 The court reporter is Kathy Silva of K. L. 24 Good Associates. Counsel will state their 6 1 appearances and the examination will continue. 2 MR. MacLEISH: Good morning, Your 3 Eminence. Roderick MacLeish, Jr., representing 4 the plaintiffs. 5 MR. THOMAS: David Thomas, also with 6 Mr. MacLeish, representing the plaintiffs. 7 MR. SHERMAN: Robert Sherman, 8 representing the plaintiffs. 9 MR. NEWMAN: Jeffrey Newman, 10 representing the plaintiffs. 11 MR. MARK ROGERS: Mark Rogers, on 12 behalf of His Eminence Bernard Cardinal Law and 13 all defendants. 14 MR. WILSON ROGERS, III: Wilson Rogers, 15 III, on behalf of His Eminence Bernard Cardinal 16 Law and all defendants. 17 MR. ROGERS: Wilson D. Rogers, Jr., on 18 behalf of His Eminence Cardinal Law and all 19 defendants. 20 MR. TODD: Owen Todd appearing for the 21 Cardinal personally. 22 23 CARDINAL BERNARD F. LAW, Resumed 24 7 1 2 DIRECT EXAMINATION BY MR. MacLEISH, cont. 3 Q Good morning, Your Eminence, and thank you for 4 returning this morning for your deposition. 5 During your deposition that we had on 6 Wednesday, there was a variety of references to 7 your existing policy that you're proposing for 8 the Boston Archdiocese. 9 Do you recall that testimony that you gave 10 on Wednesday? 11 A I do. I do. You'll refresh me if I don't. 12 Q Today we're going to be focusing on events 13 principally between 1977 and 1993. We're not 14 going to be going up to the current date. So if 15 I could respectfully request in your answers if 16 we could try and focus on the dates which are 17 going to be in question, which are, again, 1977 18 to 1993. 19 Does that sound fair? 20 A Surely. 21 Q Now, you said at the last deposition -- I want to 22 give you this opportunity -- that you were going 23 to do some thinking about another priest in 24 Jackson, Mississippi, of which you may have been 8 1 aware was involved in the molestation of 2 children? 3 A During my time. 4 Q During your time. That's exactly right. 5 Have you now had the opportunity to do that? 6 A I have, Mr. MacLeish, and I don't have a name to 7 bring forward. 8 Q Now, Cardinal Law, you attended the Pontifical 9 College of Josephinum. Have I pronounced that 10 correctly? 11 A That's correct. 12 Q In Columbus, Ohio. Is it not a fact that Father 13 Broussard, the same Father Broussard that you 14 later learned had been involved in sexual 15 misconduct when you were in Jackson, Mississippi, 16 as vicar general, was one of your seminarian 17 classmates? 18 A Not a classmate, but he also was at the 19 Josephinum, yes. 20 Q You were in the class of 1961; is that correct? 21 A That's correct. 22 Q He was in the class of 1964? 23 A I believe that's correct. I wouldn't be certain 24 of his ordination class, but -- 9 1 Q And the total number of seminarians who were 2 there at the time was approximately how many, 3 Your Eminence? 4 A In the theology department? 5 Q Yes. 6 A That would have been six years. I would hazard 7 that in that department, that six-year 8 department, there would have been -- which would 9 have been the two years of philosophy and the 10 four years of theology -- there would have been 11 around 100, perhaps a few more. 12 MR. MacLEISH: Mr. Todd? 13 MR. TODD: Mr. MacLeish, you started 14 off asking the Cardinal whether he had reflected 15 more on that one subject. 16 MR. MacLEISH: Certainly. 17 MR. TODD: And in the past, you've 18 invited him to make any additions. I believe 19 there is another further reflection the Cardinal 20 had, so at a convenient time. 21 MR. MacLEISH: Fine. 22 Q I'll certainly afford you the opportunity, if we 23 could just continue with this, and then I am 24 going to give you the opportunity to modify, 10 1 change or supplement any of the answers that you 2 gave -- 3 A Thank you. 4 Q -- on Monday. 5 You knew Father Broussard when you were a 6 seminarian, though; is that correct? 7 A I did. 8 Q And you were friends with Father Broussard when 9 you were a seminarian; is that correct? 10 A Yes. 11 Q Were you close friends with Father Broussard when 12 you were a seminarian? Would you use that term 13 to describe your relationship? 14 A We were certainly not distant, but we were not 15 the closest of friends, yes. 16 Q And you knew, when Father Broussard was at the 17 seminary in Columbus, Josephinum, you knew that 18 Father Broussard was the high school choir 19 director for what I think was called, at the 20 time, Unchanged Voices. 21 Do you recall that? 22 A I don't, but he had a very good voice, and so it 23 would have been likely to have been the case, but 24 I don't recall that. 11 1 Q When you learned in -- let me just back up for a 2 second. The Josephinum Seminary also had a 3 school that was in some way associated with it or 4 attached to it; is that correct? 5 A Well, the Josephinum, somewhat unique in the 6 country, had a minor seminary, which was four 7 years of high school, and the first two years of 8 college; and then it had a major seminary, which 9 was two years of -- the last two years of college 10 and the four years of theology.