Winters Deposition, pp. 31-60
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 2: PP 31-60
1 Q And whatever contact occurred between the 2 National Catholic Reporter and yourself occurred in 3 1979? 4 A Yes, sir. 5 Q Would you tell me what the nature of that 6 contact was and what happened? 7 A I was contacted by the top editor of the 8 NCR who said he was interested in me taking a position 9 there as the editor of a section which they had in 10 the middle of the newspaper which dealt with issues 11 opinion, that sort of thing, features, that sort-of 12 thing. 13 He wanted me to fly out to Kansas City 14 and interview for it. 15 He liked the Magazine quite a lot and 16 he liked my work and I had written for them once. 17 We arranged to do that. I thought about it some 18 more and I decided that I really was not interested 19 in the job after all and called him and told him that. 20 Q And, again, I take it it was not necessarily 21 a monetary thing? 22 A I had no idea. 23 You never even got that far? 24 A I had no idea what they were offering 31 1 along those lines. 2 Q The National Catholic Reporter as of the 3 time you were talking to them, were you aware of 4 any particular conservative and/or liberal approach 5 to Roman Catholics by The National Catholic Reporter? 6 How would you, if you can, 7 characterize that publication? 8 A It has a reputation as a liberal publication, 9 although I really don't read it. 10 Q I don't either. 11 How about the Catholic News Service#, 12 when did that contact take place? 13 A That was the Religious News Service. 14 That also took place in 1979. 15 That was about June of 1979. 16 Q What happened? 17 A Frank Morovick, who at the time was the 18 head of it, contacted me. He had already contacted 19 me to serialize an article I had written in another 20 Notre Dame Magazine and sent it over the Religious 21 News Service, and in our last discussion he mentioned 22 that he had an opening in New York and if I was ever 23 interested, he would put in a note. 24 Q That is New York? 32 1 A That's correct. To come out and see him, 2 to let him know. 3 Q And your reaction was? 4 A I was not interested in it. 5 Q Now, is the Religious News Service a Roman 6 Catholic enterprise, or more general? 7 A It is interdenominational. I believe it 8 is owned by the National Conference of Christians and 9 Jews. 10 Q Sir, anything else in connection with 11 your exploring other employment in journalism prior 12 to July 1980 than that which we have discussed? 13 A These are people that came to me. 14 Q Whatever. Was there any other contact by 15 you initiated by you with respect to other 16 employment other than with the Notre Dame Magazine? 17 A To the best of my recollection, no. is Q Now, sir, back in 1977 you had had an 19 approach to you by-the City News Bureau, is that 20 correct? 21 A Well, I had applied for a job there and 22 they called me. 23 Q Right. And they wanted you to come in or 24 something. You were not turned down in 1977 by the 33 1 City News Bureau? 2 A That's correct. 3 Q But then you did not come in because you 4 took the job at the Notre Dame Magazine? 5 A That's correct. 6 Q Why did you not pursue the City News 7 Bureau situation, sir? 8 A I had already started at the Notre Dame 9 Magazine. I had only been in place for a couple of 10 months. It seemed like a fine opportunity, so I 11 decided to stay where I was. 12 Q You are aware, sir? are you not, that the 13 City News Bureau has, you might say, hatched some 14 very outstanding journalists over the years? 15 A Yes. 16 Q You are aware of that? 17 A I am. 18 Q And knowing that you nevertheless did not 19 pursue the City News Bureau possibility? 20 A That's correct. 21 Q I think Mike Royko was out of the City 22 News Bureau. You know that, don't you, sir? 23 A I am not sure about that. 24 Q Pam Zekman I believe is a graduate of that 34 1 institution. Walter Jacobson, I believe is also a 2 graduate. Did you know any of those facts back when 3 you did not pursue the contact with the City News 4 Bureau? 5 A I don't know who and who are not graduates 6 of City News Bureau specifically. 7 Q No, but you knew, did you not, that it was 8 one of the great training grounds-for many 9 Journalists in the profession of journalism? 10 A It has a reputation along those lines. 11 Q But you knew at the time and you know it 12 today? 13 A Yes. 14 Q Now, sir, you referred to the various 15 profiles you wrote which appeared in the Notre Dame 16 Magazine. 17 When you use the word "profile," 18 sir, what do you mean? 19 A An article about a person. 20 Q Generally speaking, what are the guidelines 21 to follow in preparing such a profile, if there are 22 any? 23 A Well, I don't know about guidelines. I 24 can tell you what I do. 35 1 I try to interview the people, usually 2 succeed in interviewing the person at some depth. 3 I get as much information as I can about the person 4 and then I sit down and write it. 5 Q Is there any approximate length of profiles 6 destined for publication in the Notre Dame Magazine? 7 A They vary widely. 8 Q From what to what, sir? 9 A we sometimes run one-page profiles. we 10 sometimes run three-page profiles. There is no limit 11 to how long they can be except 72 pages, which is the 12 limit of the Magazine. It would have to be shorter 13 than that. 14 Q A profile could not take up, could it, sir? 15 more than half the Magazine? 16 A Conceivably it could. Why not? 17 Q Do you know of any occasion if any profile 18 took up that much space in a particular issue of the 19 Notre Dame Magazine? 20 A No. 21 Q The profiles that you personally wrote, sir? 22 could you give us an idea of their length in words, 23 let's say? 24 A They tended to be along the lines of 36 1 three pages, or 3,000 words. 2 Q I mean that would have been true of Tully? 3 A Tully was not a profile. That was much 4 larger and it got into things after his death, so it 5 was not a profile. It ran over eight pages. 6 Hugh Macovy is not a profile because 7 it was a story about his murder, so that was not a 8 profile. 9 Q I did not write this down, but you 10 characterized a profile with about 3,000 words? 11 A About that. 12 Q And profiles written by others would run 13 about the same, is that correct? 14 A Some were longer, some were shorter. 15 Q In your own experience -- you have been 16 there at the magazine for about eight years, 17 roughly eight years -- what is the longest profile 18 that you can recall? 19 A Probably five or six pages long in the 20 magazine. 21 Q Which is how many words, sir, approximately? 22 A 5,000 words, something like that. 23 Q Sir, did you ever take any courses in the 24 law as it pertains to journalism? 37 1 A No. 2 Q Sir, addressing your attention to the year- 3 strike that. 4 In connection with this lawsuit, which 5 has been pending almost three years now, in connection 6 with your deposition today, sir, what did you read, 7 if anything at all to prepare yourself? 8 A I looked over the defendant's deposition. 9 Q That is to say the deposition of Andrew 10 Greeley? 11 A That's correct. 12 Q What else, sir, 13 A The material that went with that. 14 Q The exhibits? 15 A Yes, sir, 16 Q Letters back and forth? 17 A Yes. Some correspondence and transcriptions 18 of tapes. 19 Q Some correspondence. When you say "some 20 correspondence," correspondence between whom? 21 A Greeley and I. 22 Q Is that in addition to the exhibits, in 23 other words, at the Greeley deposition, sir, I 24 believe -- and I could be wrong -- most of the 38 1 correspondence between yourself and Greeley is in 2 it as an exhibit one way or the other. 3 A Yes, some was in addition to the exhibits. 4 Q I see. And do you know whether the 5 Greeley correspondence, or the correspondence between 6 yourself and Greeley that was not marked as an 7 exhibit has been produced by your lawyers to us in 8 connection with this case? 9 A I didn't mean that. I meant correspondence 10 in general, not specifically. 11 As far as I know, you have got what 12 you are entitled to. 13 Q All right. What else did you look at? 14 A That is about it. 15 Q Did you look at any newspaper articles or 16 Xerox copies of newspaper articles other than the 17 ones that have been marked as exhibits? 18 A No. 19 Q Apart from talking to your lawyer or 20 lawyers, did you talk to any person other than your 21 lawyers in connection with this deposition? 22 A No. 23 Q of course, you did discuss it with your 24 lawyers, correct? 39 1 A Yes. 2 Q Now, sir, can you tell us when you first 3 heard of the priest Andrew M. Greeley? 4 A It was sometime before 1970. 5 Q How did you hear about him? 6 A He is a well-known person, so I heard about 7 him through the newspapers, or something like that. 8 Q Prior to March of 1980, sir, had you read 9 any books by Father Andrew M. Greeley? 10 A Yes. 11 Q What have you read? 12 A I read his book called "A Young Man Shall 13 See Visions." 14 Q Anything else? 15 A I don't believe so. 16 Q Were you aware of a book entitled "The 17 Making of the Popes 1978"? 18 A Yes, sir, 19 Q That was published, I believe, in 179? 20 A I was aware of it, yes. 21 Q But you had not read it? 22 A No, sir, 23 Q Have you ever read it? 24 A Yes, sir, 40 1 Q When did you read it? 2 A In 1980. 3 Q In 1980? 4 A Yes, sir, 5 Q In connection with what did you read it 6 in 1980? 7 A In connection with the article that I a planned to write about him for the Notre Dame 9 Magazine. 10 Q Had you read "The Making of the Popes 1978" 11 by Father Greeley prior to first meeting face to. 12 face with Greeley in March of 1980? 13 A No, sir, 14 Q And so you read it after you had talked to 15 Greeley - 16 A That's right. 17 Q -- in Arizona? 18 A That's right. 19 Q When you visited Arizona, that was the 20 first time you have ever met Father Greeley, is it 21 not? 22 A No, it is not. 23 Q When did you first meet him in the flesh? 24 A In 1975. 41 1 Q What happened in 1975? 2 A He was at Notre Dame to give a speech to 3 the Catholic community on urban ministry and I had 4 been assigned to write about that speech and to 5 interview him for a course in news writing. 6 Q That is when you were an undergraduate? 7 A That's correct. 8 So I saw him in the corridor of the 9 Athletic Center at Notre Dame and I approached him and 10 I told him who I was and what I was up to and asked 11 him if he would be interested in sitting for an 12 interview after the speech. 13 Actually, I asked him if he would be 14 interested in an interview and he said, "Maybe after 15 the speech." 16 I said okay. And then I sat through 17 the speech and he left before any interview could 18 take place. 19 Q That was it? 20 A That was it. 21 Q Okay. Now, this book, "The Making of the 22 Popes," that you said you read in connection with the 23 preparation of the profile you were going to do on 24 Greeley, when did you read it, if you recall? 42 1 A I think it was in the summer of 1980. 2 Q June? 3 A I don't know what month it was. 4 Q Was it prior to -- did you read it prior 5 to the time when you first had a draft of something? 6 A Yes. 7 Q Did you buy the book, or take it out of a 8 library somewhere? 9 A My father already owned it. 10 Q Your father already owned it? 11 A Yes. 12 Q Where does he live? 13 A Evergreen Park, Illinois. 14 Q Sir, somewhere I picked up the idea that 15 you have lawyers in your family. 16 A My brother is a lawyer. 17 Q And what is his name? 18 A Tom. 19 Q Where does he practice? 20 A in Chicago. 21 Q And he is by himself, or with a firm? 22 A He is a sole practitioner. 23 Q Where is his office? 24 A Somewhere in the Loop. 43 1 Q Do you know his specialty? 2 A I believe he is a trial lawyer. 3 Q What kind of trials, if there is a kind 4 of trail [sic], that he does, personal injury, criminal? 5 A I really don't know. 6 Q Sir, now directing your attention to - 7 before we get into that -- what writings, if any, 8 sir, have you submitted to any person or entity 9 whatsoever for publication prior to March of 1980 10 that were just rejected, I mean, I asked that 11 question because I understand the path of success 12 in writing is paved-with rejection slips. 13 So have you had any experience in that 14 line, would you tell us about it? 15 A Prior to 1980? 16 Q Yes, prior to, let's say, March of 1980. 17 A I do not recall any piece of writing by me 18 being rejected. 19 Q And what was accepted you have described? 20 A Pretty much. 21 Q Now, sir, directing your attention to 22 events that led up to your appearance in Tucson, 23 Arizona, in March of 1980 where you met Father 24 Greeley, would you give us the background to that 44 1 event, what happened from the beginning? 2 A In June of 1979 I wrote Father Greeley 3 informing him that I would like to wrote a profile 4 of him for the Magazine and that I was interested in 5 coming to see him in Tucson to interview him toward 6 that end. 7 Q That was the first contact in connection a with this affair? 9 A Yes, sir. 10 Q And I show you a document, sir. previously 11 marked and I am not going to mark it again, and it 12 is a document marked at Greeley's deposition and ask 13 you, sir. if that is a copy of the letter you wrote 14 on or about that date? 15 A Yes, sir. 16 Q And I show you the document marked No. 5 17 at Greeley's deposition and ask you if that 18 exhibit dated June 20, 1980 is a copy of a letter 19 answering your letter? 20 A Yes, sir. 21 Q All right. Now, sir. I note that Father 22 Greeley says in his letter to you dated June 20 - 23 Exhibit No. 5 at the Greeley deposition -- he 24 expresses amazement in the second sentence, "I cannot, 45 1 of course, prevent you from doing such a profile, 2 but given the nature of my past relationship with the 3 University of Notre Dame, I cannot imagine that you 4 would expect me to cooperate in my own execution." 5 Then he goes on to talk about "any 6 fair profile would have to discuss why I am not on 7 the faculty of Notre Dame," and he wants an ironclad 8 guarantee that he won't be skewered. Copies of that 9 went to Monsignor John Egan, copy of Greeley's 10 letter. 11 Who was John Egan. I know he was. 12 Monsignor Egan, but what was his position that is 13 relevant in June of 1979 in connection with Notre 14 Dame? 15 A He was the Assistant to the President. 16 Q And Monsignor Egan, to your knowledge, sir, 17 had formerly been in Chicago, had he not? 18 A That's right. 19 Q When you received Exhibit No. 5, sir, what 20 did you do, or whom did you talk to, if anyone, in 21 connection with the contents of Exhibit No. 5? 22 A Well, I must have talked to Ron Parent and 23 told him that Father Greeley was not interested in 24 pursuing this-without this ironclad guarantee and I 46 1 was not interested in giving him any ironclad 2 guarantee. 3 I also recall discussing it with 4 Monsignor Egan informally over breakfast sometime 5 later. 6 Q How much later? 7 A About a month later. 8 Q To the best of your recollection, sir, what 9 was the substance of what you said and what Monsignor 10 Egan said? 11 A Monsignor Egan mentioned that he had gotten 12 this letter and termed it insulting. 13 Q He termed the letter insulting? 14 A He termed it insulting. 15 Q What did you say? 16 A I don't recall my response, if any. 17 Q In other words, then this exchange of 18 correspondence in June of 1979 got nowhere? 19 That was the end of it for the time 20 being? 21 A That's correct. 22 Q Did you talk to Father Hesburgh about 23 this matter? 24 A No, sir. 47 1 Q Did you discuss with anyone the nature of 2 Greeley's past relationship with the University of 3 Notre Dame? 4 A I believe Monsignor Egan may have brought 5 it up at that breakfast. 6 Q What did he say in substance? 7 A I don't recall exactly what he said at that 8 breakfast with regard to this matter. 9 Q Did you learn from your conversation with 10 Monsignor Egan, or possibly anyone else that there 11 had once been a discussion between Notre Dame on the 12 one hand and Father Greeley on the other hand of 13 Greeley being on the faculty? 14 A Yes. 15 Q what did you learn about that? 16 A I had discussed it with both Father 17 Greeley - 18 Q You discussed it with Greeley when you 19 visited him in March of 1980 at Tucson? 20 A That's correct. 21 Q Who else did you discuss the matter with 22 at Notre Dame? 23 A With Dick Conklin, with Father James T. 24 Burtchall, B-u-r-t-c-h-a-1-l. 48 1 Q Were the conversations that you had on the 2 subject matter just alluded to with Conklin at one 3 time, or were they separate conversations? 4 A They were separate. 5 Q Let's take the first one. Who was that 6 with? 7 A Dick Conklin. 8 Q About when was that? 9 A That was prior to my trip to Tucson. 10 Q Was it in the year 1980? 11 A Yes. 12 Q Where did it take place? 13 A In Conklin's office. 14 Q And he was then the editor? 15 A No, sir. 16 Q Conklin was back in that other job, 17 University Relations, or something? 18 A Director of Information Services. 19 Q Was anyone else present? 20 A No, air. 21 Q Would you give us the substance of what 22 Mr. Conklin said on the subject matter of Greeley's 23 possible connection with Notre Dame and what you said? 24 A Well, I didn't say much of anything. 49 I 1 He asked me to listen to what he had to say on the 2 subject. 3 He said that there had been two 4 occasions when Father Greeley and Notre Dame had 5 discussions about his coming to Notre Dame in some 6 capacity. 7 One he remebered [sic] was in the late 8 '60s and the other was sometime in the 1970s. Both had 9 gotten nowhere ultimately. 10 Q Did Mr. Conklin have any unkind or 11 uncharitable remarks to make about Andrew Greeley on 12 that occasion? 13 A It would depend on what you mean by 14 unkind. 15 Q Well, let's think in terms of -- 16 A He didn't call him any names, or anything 17 like that. 18 Q Did he allocate some blame to Andrew 19 Greeley for the apparent collapse of the talks? 20 A He did convey the distinct impression that 21 Greeley was to blame for the collapse of the talks. 22 Q In what way, sir, if you recall? 23 A His information was that in the second 24 instance in any event, his information was that 50 1 Father Greeley was asking for a tenure research 2 appointment and that Father Burtchall's reply was 3 that Notre Dame does not give tenure research 4 appointments; why don't you come, do your research, 5 and we will talk about tenure later. 6 He said that this had led to a blow-up 7 on the part of Father Greeley and that that was the 8 end of the discussion. 9 Q Are there tenure [sic] professors at the 10 University? 11 A There are tenure [sic] professors. I believe 12 they are teaching professors. 13 Q Conklin, I take it, did not indicate to you 14 in any way that he, Conklin, had been involved in 15 the matter? 16 A No. 17 Q Okay. Have you now given us the substance 18 of that conversation with Father Burtchall? 19 A Yes. 20 Q What is his position at Notre Dame? 21 A He is a Professor of Theology. 22 Q And you talked with him? 23 A Yes, sir. 24 Q Where did you talk with the Professor? 51 1 A I called him on the phone. 2 Q It was a phone conversation? 3 A Yes, sir. 4 Q And that also occurred in the year 1980? 5 A July 31, 1980. 6 Q This was after you had talked to Greeley 7 and after you visited Rosary College? 8 A Yes, sir. 9 Q And you called him? 10 A Yes, sir. 11 Q Was anyone else present? 12 A No, sir. 13 Q Was it just the two of you on the line? 14 A Yes, sir. 15 Q Would you give us the substance of what 16 you told Father "B" and what he said to you? 17 A He said to me -- I said to him, "Father, 18 I am doing this profile of Father Greeley for the 19 Magazine." 20 He said, "That is a terrible idea. 21 He is a very sick guy." 22 And I said, "Well, I would like to 23 talk to you about his application for appointment 24 here at Notre Dame." 52
1 And he said he would talk to me on a 2 background basis about it. 3 Q Which you understood it was not to be 4 quoted? 5 A He didn't want to be quoted. 6 Q or identified? 7 A In the article, yeah. And he said 8 basically gave the same scenario to Conklin; that he 9 had been -- he was making demands that could not be 10 met by the University, and that he then attacked 11 Burchall, among others, at the University for the 12 collapse of the proposal. 13 And he said, "He is a very sick guy. 14 He has never been able to hold a position of 15 responsibility. 16 Q Did Father "B" provide you with any further 17 data as to his statement about Father Greeley being 18 a very sick man? 19 A No, sir. 20 Q Just a flat out statement? 21 A That is right. 22 Q And what did you say? 23 A I had no comment on that. 24 Q How old a fellow is Father "B" 53 [Note: p. 53 is bound following p. 71 in the physical transcript.] 1 A He is about 50. 2 Q Is he head of the Department, did you say, 3 of Theology? 4 A No, sir. He was the head of the Department 5 and then he became the Professor for seven years. 6 Now he is a Professor of Theology. 7 Q Do you have any idea whether Father "B" 8 knew about the tenure position of Father Greeley in 9 the Sociology Department at the University of 10 Arizona? 11 A I have no firsthand knowledge that he did. 12 Q In July 1980 you knew that to be the fact, 13 did you not? 14 A I did. 15 Q Did you tell that to Father "B"? 16 A No, sir. 17 Q Sir, we have discussed the letters of '79. is Then you reopened the subject, did you not, in 19 February of 1980? 20 A No, sir. 21 Q You didn't? 22 A No, sir. 23 Q What happened in 1980 that led to your 24 appearance in Tucson, Arizona? 54 1 A Something happened in 1979 and that was 2 that I sent a letter to Father Greeley asking him to 3 write an article for Notre Dame Magazine. 4 Q That is the letter that has been previously 5 identified as Greeley Exhibit No. 6. 6 I show it to you, sir. It is a letter 7 dated December 5, 1979 and ask you, sir. if you wrote 8 Exhibit No. 6 on or about the date it bears to the 9 Reverend Andrew Greeley? 10 A Plaintiff's Exhibit, yes. 11 Q Okay. I note, sir. that you mentioned in 12 paragraph 2 of this Exhibit 6, "I am looking for an 13 article around 3,000 words." 14 Is that about standard for articles 15 apart from the exceptions that you have given for 16 articles in the Notre Dame Magazine? 17 A There is no standard. The articles range 18 across the board, a number of words. 19 Q Sir, why did you write your letter of 20 December 5, 1979, what led you to write Andrew Greeley? 21 A We had a discussion among the staff at a 22 staff meeting about an article dealing with Notre 23 Dame in the 1980s. 24 We thought we would have somebody come 55 1 in and look around and give some sort of evaluation 2 as to where the University was going in the coming 3 decade and I mentioned Father Greeley as a potential 4 person who could do that, and that is what led to the 5 letter. 6 Q Who was at the meeting of the staff of the 7 Notre Dame Magazine that you just referred to? 8 A I assume that the whole staff was there. 9 Q How many people is that? 10 A Four editors and an art director and a 11 secretary. The secretary would not be present at 12 meetings like this. 13 Q And that includes Ron? 14 A Ron Parent, Harry Temple, John Monskonski, 15 Tom Nelson, and myself. 16 Q Did anyone bring up the opinion of Father 17 "B" in connection with the staff's notion of 18 approaching Father Greeley to write a feature for 19 the Notre Dame Magazine? 20 A No, sir. 21 Q Was Father "B's" comment mentioned by 22 anybody? 23 A Father "B" had not made his comment yet. 24 Q That's right. That was July 1980. 56 1 And was there general agreement that 2 there would be a need if Father Greeley agreed to 3 write this article? 4 A There was a general agreement that we should 5 ask him to. 6 Q Were you asking other people simultaneously 7 in order to cover yourself? a A No, sir. 9 Q Was such an article run, that is to say, 10 a feature on prospects for Notre Dame in the '80s? 11 A No, sir. 12 Q Did you receive an answer to -- the next 13 thing that happened, sir. was it not, a phone 14 Conversation between yourself and Greeley? 15 A That's right. 16 Q You called him, or he called you? 17 A He called me. 18 Q And this was a call in response to your 19 letter of December 5, 1979? 20 A That's right. 21 Q Would you give us the substance of what you 22 said and what Greeley said on the occasion of that 23 phone call? 24 A He said, "I don't have time to write, but 57 1 I will be interviewed." I said, "Oh, I guess I 2 would be interested in doing that." 3 And I told him that I would contact 4 him sometime after the New Year to arrange something. 5 Q And what was your next contact with Father- 6 this, I take it, was a short conversation then? 7 A Yeah, it was not very long. 8 Q Did you discuss where he would be 9 interviewed? 10 A No. 11 Q Okay, Did he tell you his schedule for the 12 year, you know, when he is in Chicago and when he is 13 in Arizona? 14 A He may have mentioned that he was going to 15 Tucson during the first six months of 1980. 16 Q All right. And what was the next event; 17 was there another phone call? 18 A No, sir. 19 Q Now, I show you a document marked Exhibit 20 6A at the deposition of Father Greeley, purporting 21 to be a letter to Greeley from you, dated February 22 20,1980, with attached response from Greeley at the 23 bottom of the letter and ask you, sir. if No. 6 is a 24 copy of the letter you sent to Greeley and a fair 58 1 copy of what he sent back to you by way of response 2 to it? 3 A Yes, that's right. 4 0 Now, you say in the first sentence, 5 "I enjoyed talking to you a few weeks ago about my 6 chance to interview you for Notre Dame Magazine.'; 7 Was there any other phone conversation 8 between yourself and Greeley other than that which you 9 have testified to? 10 A No, sir. 11 Q So there was nothing specific in any plan 12 you had presented to Father Greeley? 13 A No, sir. 14 Q Now, sir. in the December 5th letter, 1979, 15 you recall that where you asked for an article of 16 around 3,000 words that examines Notre Dame's place 17 in higher education as the decade begins, and I think 18 your testimony was that Greeley said to you in 19 response to your letter of December 5, 1979, that, 20 "I am too busy to write anything, but I can be 21 interviewed. I will submit to an interview." 22 A "I don't have time to write, but I will 23 be interviewed." 24 Q Now. as of the writing of your letter of 59 1 February 20, 1980, what was on the table, to wit, 2 an interview about Notre Dame's place in higher 3 education? 4 A What the interview was about was unclear. 5 Q Unclear. In other words, had you been 6 specific about the interview other than in what you 7 said in your letter of December 5, 1979? 8 A He was changing the subject. We were no 9 longer talking about an article about Notre Dame in 10 the '80s. We-were talking about an interview and 11 what the interview was going to be about was not 12 stated by him and was not stated by me. 13 Q Okay. So when you got this affirmative 14 response from Father Greeley, I take it, you 15 discussed it with somebody on the staff? 16 A I probably discussed it with Ron Parent. 17 Q Because you had to get expenses or approval 18 to go to Tucson, did you not? 19 A Yes. 20 Q And what did you tell Mr. Parent? 21 A I told him what had happened in that 22 conversation as I recounted it here, that he would 23 be interviewed. 24 Q What did Mr. Parent say, if you recall? 60
previous next
Electronic edition copyright © 1998 Ingrid H. Shafer
Posted 21 August 1998