Winters Deposition, pp. 1-30
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 1st 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 1: PP 1-30 1 I N D E X 2 WITNESS PAGE 3 JAMES WINTERS 4 Examination by Mr. O'Brien 3 5 Exanination (Cont's.) by Mr. O'Brien 227 6 7 8 9 10 11 12 EXHIBITS 13 MARKED FOR IDENTIFICATION 14 No. 1 84 15 No. 2 123 16 No. 3 228 17 No. 4 265 18 No. 6 [sic] 295 19 No. 7 398 20 21 22 23 24 2
1 (Witness sworn.) 2 JAMES WINTERS, 3 the plaintiff herein, having been first duly sworn; 4 was examined and testified as follows: 5 EXAMINATION 6 BY 7 MR. O'BRIEN: 8 Q Would you state your full name, please? 9 A James Winters. 10 Q And where do you live, sir? 11 A South Bend, Indiana. 12 Q What is your address? 13 A 920 Leland Avenue. 14 Q And how old are you, sir? 15 A 29. 16 Q Do you have a family? 17 A I came from a family. 18 Q Do you have your own wife? 19 A No. 20 Q You are a bachelor? 21 A That's right. 22 Q Now, sir, would you outline for us 23 briefly, your education? 24 A Beginning where? 3
1 Q Starting with high school, where you 2 graduated from, and onward and upward briefly. 3 A I graduated from Brother Rice High School 4 in Chicago in 1973. 5 I then enrolled at Marquette University, 6 College of Journalism, in 1973. 7 In 1974 I transferred to the University 8 of Notre Dame and I graduated from there in 1977. 9 Q So you were at Marquette and then off to 10 Notre Dame? 11 A That's right. 12 Q And your major at Marquette was journalism? 13 A That's correct. 14 Q what was your major at Notre Dame? 15 A American Studies. 16 Q Why did you switch from journalism to 17 American Studies, if you remember? 18 A Notre Dame had no journalism department. 19 Q Why did you --I am recalling at -- strike 20 that question. 21 When you were at Marquette, enrolled 22 in the Journalism School of that institution. was it 23 your intention at that time to become a person in 24 pursuit of a career in journalism? 4 1 A Yes. 2 Q Had your goal changed when you transferred 3 to Notre Dame? 4 A No. 5 Q So ever since you have been a freshman in 6 college at Marquette and then transferred to Notre 7 Dame it has been your goal to have a career in 8 journalism? 9 A Yes. 10 Q Now, sir, after you graduated from Notre 11 Dame -- you gave me the year and I forgot to write 12 it down. 13 A 1977, 14 Q Upon graduation from Notre Dame, sir, 15 before we get to that, during your time at Notre 16 Dame, were you active in any journalistic endeavors 17 As a student? 18 A Yes. 19 Q What were you active in? 20 A I became a staff reporter and finally a 21 senior staff reporter for the Notre Dame observer. 22 I served as a news broadcaster for 23 WSND, the campus radio station, and I worked as a 24 student writer for Notre Dame Magazine. 5 1 Q Did you achieve or gain any kind of awards 2 As a result of your journalistic endeavors while an 3 undergraduate at Notre Dame? 4 A No. 5 Q Are such awards available, I mean, do they 6 give out such awards? 7 A To my knowledge, there is an award that is 8 given to one graduating senior. 9 Q What is that? 10 A I think it is called the Paul Neville 11 Award (phonetic). 12 Q Spell that. 13 A I don't know how it is spelled. 14 Q All right. Sir, now, having received your 15 degree in American Studies from Notre Dame in 1977, 16 having been engaged in the journalistic endeavors as 17 An undergraduate that you described, what did you do 18 upon graduation to actively pursue further a career 19 in journalism? 20 A I applied for a job as a journalist at 21 several publications. 22 Q What publications? 23 A. The Notre Dame Magazine, the Suburban Trib, 24 the Suburban Sun-Times, the Suburban Economist, 6 1 City News Bureau, and perhaps some others. 2 Q Apart from the Notre Dame Magazine all the 3 others listed are Chicago-based enterprises, are they 4 not? 5 A Yes. 6 Q And how many acceptances did you get? 7 A How many offered me a job? 8 Q Yes. 9 A The Suburban Sun-Times offered me a job. 10 I was contacted by both the Economist and the City 11 News Bureau, but that was after I took my job at 12 Notre Dame and was in place there, so I didn't pursue 13 it at all beyond that. 14 I was also offered a job at Culver 15 Military Academy as the editor of their alumni maga 16 zine. So that was another place I applied. 17 Q What was your first title at the Notre 18 Dame Alumni Magazine? 19 A Editorial assistant. 20 Q And what were your duties -- that was 21 starting in 1977? 22 A Starting August 16, 1977. 23 Q What were your duties? 24 A I wrote articles, I edited some articles, 7 1 I produced a section in the back of the magazine on 2 the campus, and I did whatever else was required of 3 me by my superiors. 4 Q All right. Describe briefly -- you are 5 still with the Notre Dame Magazine, are you not? 6 A Yes. 7 Q Describe briefly, sir, and approximately 8 what your various responsibilities have been since 9 August of 1977. 10 A In the summer of 1978 1 became copy editor 11 of the Magazine and assumed expanded responsibilities 12 for the entire editorial product. 13 Specifically, I was required to edit 14 All copy in the Magazine, all articles in the 15 Magazine with the exception of the Class Note 16 Section. 17 I also at that time began to oversee 18 the production of various-special sections in the 19 Magazine in a special issue which we published in 20 December of 1978. 21 Q What was that special issue? 22 A it was on Christmas and children, two 23 topics. 24 Q Sir, then carrying on at Notre Dame Magazine 8 1 what was the next significant change in your 2 responsibilities, if any? 3 A In the summer of 1979 I was appointed 4 Magazine editor for Notre Dame Magazine and became 5 responsible for the editorial product to a great 6 extent, at least in terms of producing it. 7 Q Now, as managing editor, whom did you 8 report to, if you reported to anybody at all? 9 A Ronald H. Parent. 10 Q What is his title? 11 A Editor. 12 Q Was he the top man at the Magazine? 13 A Yes. 14 Q How old is Mr. Parent? 15 A He is deceased, 16 Q When did he become deceased? 17 A August 21, 1982. 18 Q Was he the editor until he became 19 deceased? 20 A Yes. 21 Q Who became editor upon the death of 22 Mr. Parent? 23 A There was an acting editor for about nine 24 months. 9
1 Q Who was that? 2 A Richard W. Conklin. 3 Q Had he been on the Notre Dame Magazine 4 prior to becoming this interim editor? 5 A No. 6 Q Where had he been before, if you know? 7 A He was the Director of Information Services 8 At Notre Dame. 9 Q How old a fellow is Mr. Conklin? 10 A He is in his late 40s 11 Q And how long was he acting editor? 12 A About nine months. 13 Q Then what happened with respect to the 14 position of editor? 15 A Walton R. Collings was hired to fill it. 16 Q Where was he hired from? 17 A Indiana University at South Bend. 18 Q What has been his background before he came 19 to Notre Dame, if you know? 20 A He was a Journalist and University 21 Administrator. 22 Q Are you familiar in a general way with 23 Mr. Collings' journalistic career? 24 A in a general way, yes. 10 1 Q Could you tell us what it was? 2 A He had been editorial page editor of 3 the South Bend Tribune. He had worked briefly for 4 the Philadelphia Inquirer and he worked at IUSB 5 As an assistant to the president. 6 Q How old approximately is Mr. Collings? 7 A 55. 8 Q Did you apply for the job of editor of 9 the Notre Dame Magazine? 10 A Yes. 11 Q What form did that application take; what 12 did you do, in short? 13 A I submitted a resume. I submitted copies 14 Of my articles, articles I had written, and I 15 submitted copies of the Magazine, I believe, although 16 they had those, so I probably did not do that in 17 retrospect. 18 Q And this was in 1982 that you submitted 19 this material? 20 A I think it was in late 182, yes. 21 Q Did you have any conversations about your 22 Application with anybody at all? 23 A Yes. 24 Q With whom? 11 1 A Dr. James W. Frick. 2 Q Who is he, sir? 3 A He is the Vice President for University 4 Relations. At the time he was the Vice President 5 for Public Relations, Alumni Affairs and Development. 6 He has since gone on to another job. 7 Q Whom else did you talk to? 8 A Richard W. Conklin. 9 Q Did Mr. Conklin, after he served as the 10 Acting editor then leave, or did he stay on? 11 A He went back to his position which he always 12 held as Director of Information Services. 13 Q I see. That is unrelated to the Notre 14 Dame Magazine? 15 A It is a separate department. 16 Q All right. Who else did you talk to, sir? 17 A James E. Murphy. 18 Q Who is he? 19 A Associate Vice President of the University 20 Relations. 21 Q Anybody else? 22 A Edward Fisher. 23 Q Who is he? 24 A He is a Professor Emeritus of American 12 1 Studies and he served on the committee to hire a new 2 editor. 3 Q Anybody else? 4 A That is it. 5 Q Did you meet with these people individually, 6 or did you appear before them, or some portion of them 7 As a committee? 8 A I sat in front of them as a committee. 9 Q Did you sit before them as a committee once, 10 or more than once? 11 A Once. 12 Q And approximately when was that; that was 13 like September, the fall of '82 somewhere? 14 A I believe the actual meeting was held in 15 early 1983. 16 Q Is there any record of that meeting, to 17 Your knowledge? 18 A Not to my knowledge. 19 Q How long did it last? 20 A Approximately one hour. 21 Q Would you give us, sir, as best you can 22 recollect the substance of who said what at that 23 meeting, as difficult as I know that is, just the 24 substance. 13 1 If you remember anything specific, we 2 Are entitled to hear that, too. 3 A Each of the interviewers asked me a series 4 Of questions about my responsibilities, about my 5 vision for the Magazine, and I answered them. 6 Q Did any subject matter related directly 7 or indirectly to this lawsuit come up on that 8 occasion? 9 A No. 10 Q Neither they brought it up, nor did you 11 bring it up? 12 A No. 13 Q Was the name Greeley mentioned by anybody 14 At all in the course of this discussion? 15 A I don't believe so. 16 Q Was Father Hesburgh's name mentioned in 17 Any connection whatsoever? 18 A It may well have been, but I don't recall. 19 Q All right. Now, sir, as of the time -- 20 did you get a ruling from the committee at that 21 occasion; did they tell you what they were thinking? 22 A No. 23 Q Did anyone ever tell you why you were not 24 Appointed editor of the Notre Dame Magazine after your 14 1 application? 2 A No, sir. 3 Q Indirectly did you hear? 4 A No, sir. 5 Q Did you have an opinion as to why? 6 MR. LANE: Well, I would object. This is 7 calling for speculation based upon his answers to the 8 other two. 9 MR. O'BRIEN: All right. 10 Q And there is no correspondence informing 11 you of the fact that they had decided to choose 12 Mr. Collings rather than yourself? 13 A No, sir. 14 Q Now, sir. as of 1983 when you submitted 15 your resume and your writings, articles, to the 16 committee as you have described it, did you have any 17 Articles whatsoever that you had written that were 18 published anywhere other than the Notre Dame Magazine 19 to submit to the committee? 20 A Yes, sir. 21 Q What articles would those have been? 22 A Do you want the titles? 23 Q Yes. Let's put it this way, do you have 24 that resume and the list of the articles still in 15 1 your possession? 2 A I had no list of the articles. I merely 3 submitted the articles. 4 Q Do you have that in your possession today? 5 A I submitted them. How could I have them? 6 Q Did you keep copies? 7 A No, sir. a Q You did not? 9 A of that specific set, no, sir. 10 Q Well, come on. Do you today have copies 11 Available to you of those publications bearing your 12 name other than that which appeared in the Notre 13 Dame Lawyer (sic) which you gave to the committee in 14 early 1983? 15 A The Notre Dame Magazine. 16 Q Pardon? 17 A Notre Dame Magazine, You said the Notre 18 Dame Lawyer. 19 Q I'm sorry. With that correction, can you 20 Answer the question? 21 A I have copies of everything that I gave I 22 Am sure. 23 MR. O'BRIEN: All right. I would like now to 24 request copies of all the publications submitted to 16 1 the committee as described by Mr. Winters in early 2 1983. 3 MR. LANE: For the record, when the deposition 4 is done and written up, if you'take a look at the 5 transcript and give me a letter on every request for 6 production, or any supplementation to request for 7 production, I will be happy to do it rather than rely 8 upon my notes that I take today. 9 MR. O'BRIEN: I think it is pretty clear, but 10 I cannot force you to do anything. I think we are 11 entitled to it like tomorrow, be that as it may. 12 Q Now, sir, would you tell us your best 13 recollection of what articles you had written other 14 than articles in Notre Dame Magazine by early 1983? 15 A I wrote an article that was published in 16 the Chicago Tribune on November 24, 1975 that was 17 About my grandfather. 18 Q Do you recall the date of that? 19 A November 24, 1975. 20 Q What was the nature of that article? 21 A It was entitled "Thanksgiving With the Old 22 Guy," and it was a memoir of my grandfather on the 23 occasion of Thanksgiving holiday. 24 Q What section of the newspaper did that 17 1 appear in? 2 A on the Perspective page. 3 Q How long was it? 4 A It ran three pages in typescript. 5 Q What was the occasion for -- let's strike 6 that. 7 How did it come about that the Tribune 8 printed this thing by yourself entitled "Thanksgiving 9 With the old Guy"? 10 A I submitted it to them. 11 Q Whom did you address it to? 12 A The editor of the Perspective page. 13 Q And the next thing you knew it was printed? 14 A No, sir, they contacted me. 15 Q Then what happened? 16 A They said that they were interested in 17 printing it. is Q Then what happened? 19 A I said terrific. 20 Q And anything else before it was printed? 21 A Well, they agreed to pay me $25. That is 22 all. 23 Q In connection with this material printed 24 on November 24, 1975, sir, did the subject in any way 18 1 of this lawsuit -- of course, it couldn't have come 2 up in 1975. 3 Do you recall whom you talked to? 4 A His first name was Bill. He was an editor 5 of that section. 6 Q And this would have been while you were still 7 At Notre Dame? 8 A Bill Plunkett. 9 Q So in 1975 you were then a sophomore or 10 Junior at Notre Dame? 11 A I was a junior. 12 Q All right. Sir, what other articles, let's 13 Just address ourselves generally to the problem, 14 because as of 1983, 1 am assuming any articles of 15 substance that you considered of substance you 16 submitted copies of them to the committee, did you not? 17 A Yes. 18 Q So what other articles did you submit to 19 the committee in early 1983? 20 A I submitted to them a cover story I wrote 21 for the Magazine called Tom Tully, A Forgetten Hero, 22 which was the cover story of the April 1979 issue. 23 Q That is the Notre Dame Magazine? 24 A That's correct. 19 1 Q What else? 2 A I submitted to them an article entitled, 3 "The Unquiet Death of Hugh Macovy," February 1979. 4 Q Of the Notre Dame Magazine? 5 A That's correct. 6 Q Who is Hugh Macovy? 7 A He was a young man who was murdered in 8 New York. 9 Q What else? 10 A I submitted a profile of Moose Krause. 11 He was the athletic director. 12 Q And that was also an article that appeared 13 in Notre Dame? 14 A Yes. I submitted a profile of Monsignor 15 Egan, which ran in the Magazine in October 1978. 16 I think among that material was a 17 profile of Elizabeth Crisman, another Notre Dame 18 Professor Emeritus, and a profile of Edward Fisher, 19 A Professor Emeritus at Notre Dame; a profile of 20 Emil T. Hoffman, a Professor of Chemistry at Notre 21 Dame. 22 I submitted the article I wrote for the 23 Tribune. 24 Q The one you referred to already? 20 1 A That's correct. 2 I submitted versions of my article on 3 Tully, which had been run in the Philadelphia Inquirer. 4 The same version that was run in the Herald Examiner. 5 And I submitted a piece called "Closing Time," which 6 had been run on the back page of the Magazine in 7 July 1980. 8 Q By "Magazine," you mean the Notre Dame 9 Magazine? 10 A Yes. I may have submitted a piece of 11 George Craig, who was a Professor of Biology at 12 Notre Dame. 13 There may have been other material that 14 I don't recall. 15 Q And at the time you submitted this material 16 that you have described, although you may have 17 forgotten some, could you estimate as of that time 18 early 1983, about how much money, apart from your 19 salary at the Notre Dame Magazine you had made from 20 your journalistic endeavors? 21 You mentioned the $25 for the one 22 article. What was the grand total in round numbers? 23 A Apart from my salary? 24 Yes. 21 1 A Maybe $300. 2 Q Now, sir, following your graduation from 3 Notre Dame and your employment by the Notre Dame 4 Magazine, what additional professional -- journalistic 5 professional I mean -- training did you get, if any, 6 mean, what courses, whatever? 7 A Well, I took two graduate-level courses at 8 Notre Dame. one was called mass Media and one was 9 on photography. 10 Q Two courses at Notre Dame? 11 A Yes, sir. 12 Q Okay. Did you at any time commence a 13 master's degree in journalism? 14 A No, sir. 15 Q Was that available at Notre Dame? 16 A In journalism, no, sir. 17 Q Did you attend any seminars on journalism 18 since 1977 when you graduated from Notre Dame? 19 A There was a seminar at Notre Dame sometime 20 within the last few years on journalism, which I did 21 Attend portions of. 22 Q Are you aware of something called The 23 Society of Professional Journalists? 24 A Yes, sir. 22 1 Q How are you aware of it? 2 A Just from my general knowledge. 3 Q Are you a member? 4 A No, sir. 5 Q Are you aware of the qualifications, if 6 Any, for membership? 7 A No, sir. 8 Q Are you aware of the fact that I think 9 this organization is sometimes called S.D., is that 10 right? 11 A Sigma Delta. 12 Q Is that related to The Society of 13 Professional Journalists? 14 A Yes. 15 Q Are you aware of any publications with 16 respect to journalism by The Society of Professional 17 Journalists, or any other organization? 18 A Do you mean books, or magazines? 19 Q Articles, whatever. 20 A No. 21 Q Sir, as a lawyer, and your counsel would 22 surely agree with me, we have Canons of Professional 23 Responsibility that we as lawyers are supposed to 24 uphold and follow. 23 1 Are you aware of any similar body of 2 rules for the guidance of journalists in the exercise 3 of their professional journalism? 4 A No, sir. 5 Q Have you ever applied at any school, any 6 university, rather, that has a journalism school for 7 Additional courses in journalism? 8 A No, sir. 9 Q What universities to your knowledge, sir, 10 in Illinois or Indiana do offer courses in 11 professional journalism and degrees in such? 12 A Undergraduate, or graduate? 13 Q Both. 14 A Northwestern. 15 Q Is this undergraduate or graduate? 16 A Northwestern offers both to my knowledge. 17 The University of Illinois. is Q Both? 19 A I believe. 20 Indiana University in Bloomington. 21 I believe that Southern Illinois University has a 22 program. 23 Q Both undergraduate and graduate? 24 A That I don't know. 24 1 Q Now, the University of Indiana at 2 Bloomington, how far is that from South Bend? 3 A I would say it is at least a three-hour 4 drive. 5 Q I take it during all relevant times, sir, 6 you have lived in South Bend? 7 A What do you mean by "relevant times"? 8 Q Since working for the Notre Dame Magazine. 9 A Yes, sir. 10 Q Do you own a house, or live in an apartment? 11 A Apartment. 12 Q Have you ever been married? 13 A No, sir. 14 Q Now, sir, prior to, let's say, July of 1980, 15 did you apply anywhere at all -- did you apply 16 Anywhere at all for a job as a journalist? 17 You have described what you did in 18 1977. Now, I want to address myself to the period 19 After you went to work for the Notre Dame Magazine 20 and up to July of 1980 what effort, if any, did you 21 make to pursue a career in journalism at some place 22 other than the Notre Dame Magazine prior to July of 23 1980 and after you started to work for the Notre 24 Dame Magazine? 25 1 A Two magazines and one news service 2 approached me and asked me if I would be interested 3 in working for them. 4 They were U.S. Catholic, The National 5 Catholic Reporter, which is actually a weekly 6 newspaper rather than a magazine, and the Religious 7 News Service. 8 Q Was that by correspondence, or by -- how 9 was this contact made? 10 A The Religious News Service contacted was 11 over the phone. I believe so was the U.S. Catholic 12 And The National Catholic Reporter contact. 13 Q Let's start with the U.S. Catholic. When 14 was that contact made with you by phone, sir? 15 A It was in early 1979. 16 Q Was there more than one contact, one 17 conversation? 18 A Yes. 19 Q And how long -- what time period were your 20 discussions during this time period? 21 Did these discussions with the U.S. 22 Catholic take place other than 179, or are all in 23 179? 24 A Yes, I believe so. 26 1 Q Was it with one person, or more persons 2 that you talked to? 3 A One person. 4 Q And all by phone? 5 A No, sir. 6 Q Did you make a visit, or did someone visit 7 you? 8 A I met with one person. 9 Q Where? 10 A At her home. 11 Q And where does she live? 12 A In Chicago. 13 Q Who was the person? 14 A Anne Wolf. 15 Q Was anybody else present? 16 A No, sir. 17 Q And what was Anne Wolf's job at U.S. 18 Catholic? 19 A She was an editor. 20 Q Is that a full-time job for Anne Wolf, as 21 you understood it? 22 A I believe so. 23 Q Is the U.S. Catholic located in Chicago? 24 A Yes. 27 1 Q Where did this meeting take place? 2 A In her home. 3 Q Was anyone else present -- I think I asked 4 you this. 5 A No, sir. 6 Q How long did it last? 7 A About an hour and a half. 8 Q Can you give us the substance of what 9 happened during this; who said what, the substance 10 between yourself and Anne Wolf on the occasion of 11 your meeting in her home? 12 A It was a routine job-interview. She asked 13 me questions about my work and I answered them. 14 She also asked questions about my faith and I 15 Answered them. 16 Q How -- would she make sure you are a 17 Catholic? 18 A Yes, sir. 19 Q Anything else? 20 A That was the gist of it. 21 Q And what was the upshot of that meeting? 22 A She was very interested in me and that 23 was the impression 1 left with. 24 However, I was not interested in 28 1 working for U.S. Catholic particularly. 2 Q Why is that, sir? 3 A I thought that the job I had was better. 4 Q Did she offer you more money? 5 A No, sir? 6 Q About the same money? 7 A About the same. She really didn't offer 8 me money in terms of a salary. She gave a ball park 9 figure. 10 Q It was in the same ball park you were 11 already playing? 12 A Yes, sir? 13 Q Is the U.S. Catholic -- I am not familiar 14 with it -- would it -- can you characterize the 15 U.S. Catholic, as in the Catholic circles, as being 16 one myself, is it a left-wing, liberal Catholic 17 publication, or is it,--right-wing conservative, because 18 I think we all recognize the various groups are not 19 unknown even in the Roman Catholic group. 20 How would you characterize the U.S. 21 Catholic? 22 A I really don't know. 23 Q Had you ever read it before? 24 A I looked at it. I don't recall reading more 29 1 than a couple of articles in it. 2 Q Do you recall if the U.S. Catholic had a 3 position on women on the altar, do you recall that? 4 A I have no idea. 5 Q Female altar persons, do you recall whether 6 the U.S. Catholic had a position on that? 7 A I could not tell you. 8 Q Did you conclude the interview by telling 9 her you were not interested? 10 A No, sir. I called her a couple of days 11 later and told her that. 12 Q Okay. Now, let's address -- and this all 13 occurred in 1979? 14 A Yes, sir. 15 Q Now, the National Catholic Reporter, first, 16 what is the National Catholic Reporter? 17 A It is a weekly newspaper. 18 Q Where does it have its headquarters? 19 A Kansas City, Missouri. 20 Q What year were you in touch with the 21 National Reporter? 22 A 1979. 23 Same year? 24 A That's right. 30
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Electronic edition copyright © 1998 Ingrid H. Shafer
Posted 21 August 1998