James Winters vs. Andrew Greeley: James Winters' Deposition

Winters Deposition, pp. 321-350

1       STATE OF ILLINOIS       )
                                )       SS:
2       COUNTY OF COOK          )

3       IN THE CIRCUIT COURT OF COOK COUNTY
        COUNTY DEPARTMENT       LAW DIVISION
4
        JAMES WINTERS,                          )
5                                               )
                Plaintiff,                      )
6                                               )
        VS.                                     )       No. 82 L 14410
7                                               )
        ANDREW GREELEY,                         )
8                                               )
                Defendant.                      ) 
9

10              The discovery deposition of JAMES WINTERS, 

11      taken under oath on the 2nd day of July, 1985, in 

12      Room 1200, at 111 West Jackson Boulevard, Chicago,

13      Illinois, pursuant to the Rules of the Supreme 

14      Court of Illinois and the Illinois Code of Civil 

15      Procedure, before Linda McMahon, a notary public 

16      in and for the County of Cook and State of Illinois,

17      pursuant to notice.

        APPEARANCES:
18
                WILLIAM D. MADDUX & ASSOCIATES, by
19                      MR. BRUCE M. LANE,
                                for the plaintiff,
20
                MAYER, BROWN & PLATT, by
21                      MR. PATRICK W. O'BRIEN and
                        MS. HOPE G. NIGHTINGALE,.
22                              for the Defendant.

23

24
                       Sullivan Reporting Company
                      Chicago, Illinois   782-4705

PART 11: PP. 321-350

1 or anybody?
2 A No.
3 I have talked with some people at the
4 Sun-Times, who is a writ . er there, but nobody who had
5 any relationship with this particular affair
6 Q The Greeley-Cody affair?
7 A --That's correct.
8 Q It was all on some other subject?
9 A Right.
10 Now, sir, you mentioned earlier about having
11 been in touch with the Tribune in 1980.
12 MR: LANE: Before we get into another subject it
13 might be a good time for lunch.
14 (Whereupon, a lunch
15 recess was taken.)
16 MR. O'BRIEN: Q Mr. Winters, the other day,
17 yesterday to be precise, it is typical of the
18 deposition we move up to a point and then something
19 you say makes me go back to something else, but I
20 believe we had you calling in September of 1980,
21 Pam Zekman?
22 A That's right.
23 Q What was that in connection 'with, sir?
24 A That was my first contact with the Sun-Times
321

1 after I talked to Roy-Larsen in July.
2 Q Was that in connection with setting up what
3 proved to be the
4 A That's correct.
5 Q What did you say to Pam Zekman and what
6 did she say to you?
7 A I gave her a brief verbal outline of the
8 gist of my story and suggested that she and I talk
9 about it, and she said that she would be at a
10 disadvantage in such a discussion because she had not
11 been involved in the Cody investigation in the Sun
12 Times, so she said that either Gene Mustaing or
13 Bill Clements would get back to me about it.
14 Q And those were then with Roy -- those two
15 persons you just named at the Sun-Times, plus Roy
16 Larsen, you knew by then were the three people doing
17 the Cody investigation for the Sun-Times?
18 A I did.
19 Q And her conversation confirmed that?
20 A she didn't confirm it officially.
21 Q She just gave you those names?
22 A Yes.
23 Q Did you believe that Pam Zekman had any
24 connection with the investigation?
322

1 A I did because the Chicago Catholic had
2 identified her as being connected with it in some
3 capacity.
4 Q Now, sit, in the fall you mentioned the
5 Chicago Catholic had identified her, in other words,
6 it is a fact, is it not, that the Catholic
7 Archdiocese of Newspapers roughly in the fall of 1980
8 was beginning to complain about investigations; was
9 that in that time frame, sit?
10 I know they did before the investigation
11 broke. I just can't remember when.
12 A Yes. I believe actually it was in August
13 of 1980 that the Chicago Catholic published a front
14 page story about the ongoing newspaper investigation.
15 Q Did you say the Chicago Catholic?
16 A Yes, I think I said that.
17 Q Yes. And that was an Archdiocese newspaper,
18 was it not?
19 A It was.
20 Q And they did name the Sun-Times?
21 A They did name the Sun-Times.
22 Q But at that point it was not public
23 knowledge, was it, that somehow the U.S. Attorney
24 was investigating it?
323

1 A No.
2 Q Did you know that in September of 1980?
3 A No.
4 Q Did you know the U.S. Attorney was
5 investigating Cody prior to-8eptember of 1981?
6 A Yes.
7 Q When did you first learn about that, sir?
a A August of '81.
9 Q That was just before the stuff hit the fan,
10 or was that reading the newspaper that you read about
11 it?
12 A No. It was published in the newspaper on
13 September 10, 1981, and I knew about it a few weeks
14 ahead of that.
15 Q From whom, or from what did you learn it?
16 A Dr. Kennedy and Mr. Sherwood.
17 Q You learned about it from Dr. Kennedy
18 separately, or together?
19 A Separately.
20 Q okay. What was -- well, September of 1981,
21 did Sherwood call you?
22 A In September of '81 about this?
23 Q Yes, I am talking about when you learned
24 the U.S. Attorney was into it, and I think you said
325

1 Q Is that what you told-him?
2 A I didn't know anything about it.
3 Q Did you tell him?
4 A He wasn't trying to get information from
5 me. He was simply telling me that he was trying to
6 check this out.
7 Q Okay. So you learned from him that there
8 was something cooking in the U.S. Attorney's office?
9 A That's right. Actually I learned it from
10 Dr. Kennedy. He said that Sherwood had called him
11 and asked him if he knew anything about it, and he
12 did not.
13 Q Kennedy did not?
14 A Right.
15 Q Is that all you learned before it was
16 Published in the Sun-Times?
17 A Yes, sir.
18 Q Have we now covered, sir, all the
19 conversations with the Sun-Times people, or anyone
20 connected with the Sun-Times?
21 A There was a conversation that I forgot which
22 was an informal conversation, and that took place
23 at Notre Dame in October of 1980.
24 It was a Sunday in October. It was
326

1 between me and M. W. Newman.
2 Q M. W. Newman is some sort of a reporter?
3 A At the time his title was special writer.
4 He has been with the Sun-Times since the collapse
5 of the Daily Tribune and before that he was around
6 30 years before that. He came to Notre Dame to write
7 an article for the magazine, architectural critique
8 at the campus. This is one of his specialties.
9 We were having dinner Sunday night and
10 we were talking about a number of things and I had
11 talked to Mustaing and Clements I think by that time,
12 and also Zekman about my prospective meeting and
13 also Fabre, but it had not occurred, and I brought
14 up the subject and told him what the situation was.
15 I told him the whole story basically.
16 Q What did Newman say?
17 A He was very interested in it. He said it
18 was a very good story.
19 Q Now,, sir, you have mentioned a contact I
20 believe with the Tribune in the fall of 1980?
21 A That's correct.
22 Q And how did that contact with the Tribune
23 begin?
24 A I talked to McCrohon.
327

1 Q Spell that.
2 A M-c-C-r-o-h-o-n, in September of 1980.
3 It was about the 27th of the month.
4 Q What was Max McCrohon's job at the Tribune?
5 A He was Editor of the Tribune.
6 Q And you called him?
7 A Yes.
8 Q What did you say to him, sir?
9 A Well, I told him I had this story on the
10 Archdiocese and Father Greeley and that the gist
11 of it was that Greeley had been involved in engineering
12 a newspaper expose of Cardinal Cody, and that that
13 was the gist of it and I wanted to talk to him about
14 it.
15 Q What did he say?
16 A He set up an appointment for 11:00 o'clock
17 on that 27th of September.

18 Q And did you meet with the gentleman at
19 10:00 o'clock on September 27?
20 A 11:00 o'clock, yes.
21 Q And who else was present, if anyone?
22 A No one.
23 Q In his office?
24 A That's right.
329

1 Greeley.
2 Q What kind of things; those letters that we
3 have here?
4 A The letter of August 4, 1980 that I wrote
5 to Father Greeley.
6 Q Did you bring the letter of Father
7 Greeley of July 29th, and the letter of August 4th?
8 A I don't recall. And I showed him that
9 letter and explained the context of it, and his
10 response was, "Well, this was a good letter to write,
11 but if someone here had gotten a letter like that,
12 we would have just laughed at Greeley."
13 Q What letter are you talking about; his
14 letter to you?
15 A That is what he was talking about, yes.
16 From that I would say I must have brought his letter
17 along.
18 Q Did you tell him as you have-told us here
19 at your deposition about the removal of the tapes
20 without signing out for them from the library?
21 A Yes. I did mention it. I did not mention
22 this part of signing out.
23 I mentioned that I had tapes of the
24 archives and I had sent them back.
330

1 Q And did you tell him about telling Father
2 Hesburgh -- the Hesburgh relationship about returning
3 the tapes?
4 A I told him exactly what happened.
5 Q Including the fact of your copying the
6 copies?
7 A I certainly did.
8 Q And did you tell him that you believed that
9 you had permission to do what you had done from
10 Father Greeley?
11 A I did.
12 So after we got the story, to that
13 Point, I told him what the documents indicated and
14 what I had learned from Sherwood about his own
15 activities with Greeley.

16 This took quite a while.
17 Q What did you tell him about Sherwood's
18 activities with Greeley?
19 A I told him what I knew, in other words, I
20 told him that Sherwood had come out to South Bend;
21 that I had met with him; that I had told him that
22 Greeley had been planning in these documents to
23 sponsor an investigative reporter to come in and
24 topple Cody in the worst kind of public scandal; and
331

1 that he was looking for some son of a bitch out of
2 town; and that Sherwood had said that is me; I am
3 Greeley's hired gun.
4 I told the story essentially as it
5 happened.
6 Q Did you intend to let the Tribune editor
7 believe that Greeley was paying Mr. Carlton Sherwood
8 for his work?
9 A No, no.
10 Q The words you used you felt did not mean
11 that?
12 A I was quoting Sherwood. I had no intention
13 beyond that.
14 Q Hired gun, you knew you had no reason to
15 believe that statement was literally true, did you?
16 A Well, I did find out subsequently that
17 Greeley had offered Sherwood a blank check at one
18 point to pick up where he had left off on Cardinal
19 Cody, but at this time I didn't know that at this
20 point in time.
21 Q When did you hear that Father Greeley had
22 offered Sherwood a blank check to continue his
23 investigation of Cody?
24 A In the fall of 1981.
332

1 Q From whom did you hear that?
2 A Carlton Sherwood.
3 Q Was this one of the visits that we previously
4 discussed?
5 A No, this is in 1981, the autumn of 1981.
6 Q By that time the Gannett investigation had
7 petered out about a year, had it not?
8 A About that, yeah.
9 Q what was the occasion of you having a
10 conversation with Mr. Sherwood in the fall of '81?
11 A I don't recall the occasion. Either I
12 called him, or he called me.
13 More likely the latter.
14 Q Did you literally believe that Father
15 Greeley had offered a check payable to the order of
16 Mr. Carlton Sherwood with Mr. Carlton Sherwood to
17 fill in the amount?
18 A That is what he told me.
19 Q That is not -- did you believe that?
20 A Yes.
21 Q What did Mr. Sherwood tell you was his
22 response to that blank-check offer from Father Greeley'
23 A He said that Greeley had been very upset
24 with the fact that Cody was surviving the Sun-Times
333

1 publication of its expose, and he said he had
2 offered him this blank check to pick up where he had
3 left off.
4 Q In the fall of '81, the Sun-Times expose,
5 was
6 A It had been published.
7 Q And then carried on the day after day after
8 day, as I recall it?
9 A And he said that he had turned it down.
10 Q Now, back to your meeting at the Tribune
11 offices with its editor, Max, tell us what else was
12 said?
13 A That is about it. I was in there an hour
14 and fifteen minutes, but I didn't really get the
15 whole story out even in that amount of time.
16 Things had not been completed.
17 He was putting off appointments and things. He said,
18 "This is going to take a lot longer than I thought it
19 was." And he was calling off appointments and things
20 like that, but at 12:15 he had to go to lunch, so he
21 said to me, "I would like you to meet with Bernie
22 Judge, who is our editor," and he called Bernie
23 Judge and he said, "Bernie, there is a gentleman here
24 named Jim Winters. He is the Managing Editor of
334

1 Notre Dame Magazine and he has been working on a
2 story about Father Greeley, but it has become much
3 more than that,and I would like you to talk to him
4 this afternoon."
5 He set up an appointment with me and
6 Bernie Judge for about 3:30 that afternoon.
7 Q Did you meet at 3:30 that afternoon with
8 Bernie Judge?
9 A I did.
10 Q Was anyone else present other than yourself
11 and Mr. Judge?
12 A No, sir.
13 Q Was it in Mr. Judge's office?
14 A Yes, sir.
15 Q About how long did it last?
16 A 45 minutes.
17 Q Before we leave Max, the Editor, did you
18 leave any documentation of any kind at Max's?
19 A No, sir.
20 Q Did he leave the room or have custody of
21 any of these documents at any time during the time
22 you were with him?
23 A No, sir.
24 Q Now, back to you and Judge.
335

1 A okay.
2 Q What happened; who said what to whom in
3 substance?
4 A I said who I was and all that and he wanted
5 to know-what it was all about and I said, "Gee, I
6 just spent an hour and fifteen minutes with McCrohon
7 talking about this."
8 And he said, "Why don't you give me a
9 15-minute version." So I gave him a 10-minute
10 version, which was the best I could do.
11 Q Would you tell us what you said, the
12 substance of what you said?
13 Give us a 3-minute version of the
14 10-minure version.
15 A Basically what I have been saying all along.
16 Q Which was?
17 A Which was that I had begun this work on this
18 article about Greeley; had talked to him about going
19 to his archives; had gone to the library; had gotten
20 the material; copied it; and so forth.
21 Then I told him what the material
22 revealed and I told him what Sherwood had said about
23 his own role with Greeley.
24 Q What did you tell him the material revealed;
336

1 what was it?
2 A I told him that the material revealed that
3 Greeley in October of 1977 communicated to his
4 publishers a proposal to sponsor an investigative
5 reporter to go into Chicago to topple Cardinal Cody
6 in the worst kind of public scandal, and that that
7 was part of this larger scheme of Greeley's to, in
8 his words, rig the Papal election; he called it a
9 conspiracy.
10 Q The Papal election of 1978?
11 A The Papal election of 1978.
12 Q And what was Mr. Judge's reaction to that?
13 A He said, "He wanted to rig the Papal
14 election? That is crazy."
15 Q And what else did he say?
16 A Well, I responded to that. I said, "Well,
17 maybe it was, but Greeley took steps to bring it
18 about."
19 Q Such as?
20 A Well, he set up that committee for the
21 responsible elections of the Pope. That was in the
22 papers. And that materialized. He talked to
23 Cardinals about it. He talked to Hans Kuhn (phonetic)
24 about it. He was going around the world essentially
337

1 trying to drum it up.
2 Q Why do you refer to it as a conspiracy?
3 A Because he did.
4 Q And taking apart the word he dictated -
5 if he did and perhaps he did -- into his tape
6 recorder, leaving that to one side, sir, what is
7 wrong with somebody attempting to advance the cause
8 they believe by talking to people who might have some
9 influence about bringing it about?
10 A Nothing wrong with it particularly I don't
11 Suppose, but I am not making a value judgment on it.
12 I am telling this man of what Greeley did and what
13 he said he did. I was not there to denounce him.
14 I was simply there to tell him what I knew.
15 Q But don't you think the -- would you
16 consider, if five people met in a closed room to
17 seek the nomination of Pat O'Brien -- which is
18 a highly unlikely event -- that they would be engaged
19 in a plot?
20 A That is the extent of your question?
21 Q Yes.
22 A No.
23 Q If you discovered a diary of one of the
24 people in the room who said it's been a wonderful
338

1 night plotting to elect O'Brien, would you then
2 because the word "plot" had been used call it a
3 conspiracy?
4 A He consistently-used the term conspiracy.
5 He talked about all sorts of schemes that he was using.
6 I was just reporting what Greeley said. I wasn't
7 characterizing it.
8 Q He had not said any of this in any public
9 material, had he?
10 A No.
11 Q Have you ever detected in Father Greeley a
12 kind of -- for lack of a better term I
will call it --
13 Irish sense of humor; did you consider the possibility?
14 A I did not consider from my reading of those
15 documents that they were in any sense
in jest.
16 Q I think Father Greeley had admitted that he
17 desired very much to see Cardinal Cody out as Cardinal
18 of the Archdiocese of Chicago. That is a public
19 record I believe.
20 I believe it is also true that

21 Father Greeley favored the election of a liberal
22 Pope as opposed to a, quote, "conservative person,"
23 as a Pope.
24 You knew that, didn't you, before you
239

1 ran across these tapes?
2 A I did.
3 Q You knew that what I just said was true,
4 didn't you?
5 A I suppose so, yes.
6 Q Okay. Back to Bernie Judge. What else
7 was said on that occasion? I think you reported a
8 conversation that Bernie Judge said in respect to your
9 statements about Greeley's plot to depose Cody and
10 elect a liberal Pope as being crazy?
11 A I said it might be crazy, but he took overt
12 steps to bring it about.
13 Q And what overt steps did you refer to
14 intend to refer to?
15 A I inteded [sic] to refer to the ones I just told
16 you about, the setting up of the committee, and the
17 going around the world, talking to people about it.
18 Q Around the world. I think I have caught
19 you, sir, in an Irish rhetoric, or overstatement.
20 We have Father Greeley's travels in
21 the period '75 to '77 confined to, were they not,
22 to New York and Europe?
23 A To the best of my knowledge, yes.
24 Q Anything else occur on this occasion with
340

1 Bernie Judge?
2 A Yeah. He said, "What do you want to do?"
3 And I said, "I want to come to work for the Tribune
4 and work the story for you." I handed him my resume
5 and clips and so forth and he looked them over and
6 he said, "Brother Rice, huh." And he told me that
7 he had gone to Mount Carmel. That kind of thing.
8 He said that he had a problem with
9 me working the story because I was part of the
10 story. And I said, "No, I may be a part of the
11 story behind the story, but I am not part of the,
12 story; that Greeley had done all of these things with
13 out Any involvement on my part." And he agreed with
14 that.
15 He said that he would get back to me
16 very soon about it, and that is how we wrapped up
17 the meeting.
18 Q When you say you had asked for a job, did
19 you say anything about why you might need a job if
20 they took over the material and worked it up into a
21 story?
22 A I had brought that up with McCrohon. I
23 explained all of that to McCrohon. I am sure of
24 that.
341

1 Q What was it you explained to him?
2 A I explained to him what had happened with
3 Father Hesburgh exactly as it had happened, and it
4 was implicit in that that Father Hesburgh may not
5 be pleased with the eventuality.
6 Q You told them, didn't you, in substance
7 that if they took the material to do the story and
8 it was identified to you, you would be out of a job
9 at Notre Dame and you would need a job somewhere?
10 A That was my assumption, yeah.
11 Q And you told them that, didn't you?
12 A It was clear to me that Notre Dame was not
13 the place in which to publish the story under the
14 circumstances, and I was not going to publish it as
15 an unemployed person. So that was the essence of it.
16 I was applying for a job there. I thought I had to
17 tell them why I wanted one in this particular
18 instance, why that was so necessary.
19 Q And was publication of the materials
20 involving Greeley necessary before you would
21 consider working for the Tribune?
22 A No, sir.
23 Q Okay. That was just a little extra thing
24 that you
342

1 A The circumstances came together like this
2 and that is what happened.
3 Q All right. So what further was said by
4 either-you or Mr. Judge on the occasion of your
5 meeting?
6 A That is all I recall. That was about a
7 45-minute meeting.
8 Q Did you leave anything with him, anything
9 at all, any documents?
10 A No. I did show him those documents, but I
11 took them back.
12 Q Did anyone take any of the documents that
13 You showed Mr. Judge out of the office while you were
14 there at the Tribune?
15 A No.
16 Q When you were talking to Mr. Judge, did you
17 know what lawyer was the principal lawyer for the
18 Chicago Tribune?
19 A I did.
20 Q Who was that?
21 A Don Rubin.
22 Q Did you know what reputation, if any, Don
23 Rubin had with respect to Cardinal Cody?
24 A I did.
243

1 Q And what was that that you knew?
2 A He was his lawyer.
3 Q We are talking about 1980; this is 1980?
4 A Yes.
5 Q What happened next, if anything, in
6 connection with you and the Chicago Tribune?
7 A Judge called me at my parents house and he
8 set up a meeting between me and McCrohon and Judge
9 for the next day at 2:00 p.m.
10 That is the next thing that happened.
11 Q The next day at 2:00 p.m., did you meet
12 with Messrs. McCrohon and Judge?
13 A I did.
14 Q How long did the meeting last?
15 A About 15 minutes to a half-hour.
16 Q Was anyone else present?
17 A Just the three of us.
18 Q Who said what in substance at this
19 meeting?
20 A Max McCrohon said that he was very
21 interested in the Tribune pursuing the story and he
22 wanted to pursue it with me as a freelancer, and
23 they would pay me money.

24 He would draw up a contract for the
344

1 work that I had done prior to our meeting, and also
2 for the work that I would do subsequently. He said
3 it would be a substantial loan of money.
4 Q Did he say how much?
5 A No, he didn't. That was his phrase, "a
6 substantial amount of money."
7 Q What else was said?
8 A Well, I said, "I had told Bernie that I was
9 looking for a job here. That is essentially what
10 the proposal was. What happened to that?"
11 And he said, "Well, I have got a
12 problem with that." Or he said actually, "Bernie has
13 a problem with that, and that is I have a hiring
14 freeze on him. We are not hiring anybody now."
15 He mentioned the recession hit the Midwest hard and
16 it was giving the Tribune problems and it was across
17 the board, the hiring freeze.
18 So they could not hire me, as he saw
19 it, under those circumstances.
20 I pointed out to him that this was
21 putting me at some risk; that I essentially would be
22 unemployed; I would have to leave Notre Dame and go
23 to work for them as a freelancer which would have some,
24 you know, finished time, and then I would be out of
345

1 work.
2 Q And the freelance offer, as you understood
3 it, was confined entirely to the Greeley situation?
4 A Yes. And they said, "oh, with all the
5 publicity you will get from this story, you will be
6 able to land a job here or-somewhere or at a paper
7 of a comparable size." That was what McCrohon said.
8 Judge thought that this was really a
9 great idea for me to do and that it was a roll-the-dice,
10 but you are only 24 years old, so why not roll
11 it. That kind of thing.
12 I said, "Well, is there anything open
13 on Tempo, or Business, or anything."'
14 And they said, "No, it is an across
15 the-board freeze."
16 McCrohon said that Bernie had an idea
17 that they would write a story about me and how all
18 this came about. He thought that would be a good
19 story.
20 So I said I would think about it and
21 get back to them.
22 Q Did that conclude the meeting?
23 A That is the gist of the meeting.
24 Q Did the subject matter of the Sun-Times'
346

1 investigation of Cody come up at the meeting at the
2 Tribune?
3 A Yes.
4 Q What was said on that subject, if anything?
5 A Judge predicted in my meeting with him that
6 they would never publish anything. He said, "If
7 Cody knows one thing, it is money, and they will never
8 be able to track it all down." So he predicted they
9 would never publish anything.
10 Q Did the subject of Mrs. Wilson come up?
11 A Yes.
12 Q What was said about that subject?
13 A McCrohon said, "This woman, she is not
14 a young woman anymore, is she?"
15 And I said, "No, I think she is in her
16 50s." That is what I thought at the time.
17 Q All right. What else?
18 A Well, as I recall, that was about it
19 other than I informed them of the fact that the
20 Sun-Times and Gannett had been investigating Cardinal
21 Cody's association with Mrs. Wilson and the
22 possibility she was the recipient of money from him.
23 Q Anything else said on the subject of the
24 fact that the Cardinal knows money?
347

1 A Not to my recollection.
2 Q Now, sir, back to the meeting, is there
3 anything further on the meeting involving the three
4 people; McCrohon, Judge, and yourself?
5 A Not that I recall at the moment.
6 Q Did you hear again any characterization
7 either from Bernie Judge or from McCrohon of the
8 alleged Greeley plot as crazy?
9 A No, sir. They had evidently changed their
10 minds about that. McCrohon had never characterized it
11 as crazy. He never characterized it. He thought it
12 was interesting from the very beginning.
13 Judge evidently had surrendered that
14 point of view pretty thoroughly by that date.
15 Q When you say evidently, because he did not
16 bring it up again?
17 A He didn't bring it up again and he was
18 talking about pursuing the story and so forth.
19 Q The story we are talking about is the
20 alleged plot to get Cody, is that correct?
21 A That's correct.
22 Q Did anyone say anything to the effect that,
23 well, this is such a hot story that we will go after
24 it ourselves; the plot, that is?
348

1 A They did mention that they wanted me to
2 work with two Tribune reporters, Jim Yunger and
3 Bruce Buursma. That was the arrangement. I would be
4 a freelancer working with those two guys.
5 Q And Bruce Buursma is the Tribune Religion
6 Editor, is he not?
7 A Yes.
8 Q And you turned that down?
9 A I told them I would think about it and get
10 back to them.
11 Q You thought about it and then what
12 happened?
13 A On the day after Labor Day I called Judge
14 and I told him that I had thought about his proposal
15 over the weekend and I had decided not to accept it.
16 He asked why. And I said that I could not live with
17 the employment situation that he was proposing.
18 Q Which, again, is the freelance aspect,
19 no guarantees, no future?
20 A Essentially unemployment.
21 Q And they had not mentioned what they meant
22 by substantial sums, had they?
23 A No.
24 Q Did you tell them how much you were making
349

1 at Notre Dame Magazine?
2 A No.
3 Q Did they ask you?
4 A No.
5 So he said, "Well, gee, you are asking
6 a lot. You are asking for a job, for a story." And
7 I said, "No, that is not how I perceived it at all;
8 that that assumes that I am never going to do anything
9 again once this story is over with."
10 He said, "Well, I want you to talk to
11 McCrohon about this. That is who you talked to
12 first. I want you to talk to him now."
13 He tried to get McCrohon on the
14 phone while I was still on the line and came back and
15 said, "McCrohon is busy right now. He will be in
16 touch with you this afternoon."
17 Q That was at your parents' house?
18 A No, I was calling from the office at Notre
19 Dame.
20 Q Did he get in touch with you?
21 A No, sir, not that afternoon.
22 Q Well, did he get in touch with you?
23 A Yes, sir.
24 Q When?
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Electronic edition copyright © 1998 Ingrid H. Shafer

Posted 26 August 1998