Winters Deposition, pp. 61-90
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 3: PP. 61-90 1 A I don't recall. 2 Q Did you talk with anybody else about your 3 forthcoming trip to interview Father Greeley in 4 Tucson, Arizona? 5 A At what time? 6 Q Prior to leaving. 7 A I am sure I did. 8 Q Do you recall any particular conversation? 9 A No. 10 Q In connection with your trip to Tucson, sir, 11 what, if any, documents did you review? 12 A At what time? 13 Q Prior to going. 14 A I took out a copy of "The Best of Times and 15 the Worst of Times" from the library of Notre Dame 16 and I made a copy of an article that Father Greeley 17 wrote in a book called "Journeys." I may have made 18 other material. I may have produced other material, 19 but I don't recall what. 20 Q In your discussion with Mr. Parent did you 21 discuss what kind of article you had in mind after 22 you interviewed Father Greeley? 23 A After? 24 Q In other words, before you went for the 61 1 interview did your discussion with Parent include any 2 general discussion of the kind of article you had in 3 mind for the Notre Dame Magazine? 4 A Yes. 5 Q What was that discussion? 6 A I told him I wanted to write a definitive 7 profile of Father Greeley that would cover the ball 8 park. 9 Q What did Mr. Parent say? 10 A "Fine." 11 Q A definitive profile? 12 A Yes. 13 Q Did you have a discussion with Mr. Parent 14 About the length of the article? 15 A No, sir. 16 Q Now, following your letter of February 20, 17 1980 to Greeley and his written response, did you have 18 before arriving in Tucson any further discussion with 19 him on the phone? 20 A Yes, sir. 21 Q Approximately when was that, sir. 22 A February or March of 1980. 23 Q Did you call him, or did he call you? 24 A I believe I initiated a contact. 62 1 Q And you got him out in Tucson, Arizona? 2 A I believe so, yes. 3 Q Can you give us the substance of what you 4 said and what he said? 5 A I told him I would need more time to 6 interview him than the time he had set aside in this 7 note here, that I would prefer to have all week if I 8 could, and asked him if there was a good week in wchic 9 that could be possible, and we arranged for me to com 10 out on the 24th of March, 1980, and to stay through 11 the 29th of March or the 30th of March 1980. 12 Q Now, sir, in this conversation did you 13 make it clear that you intended to take up four days 14 of steady -- you were going to interview Father 15 Greeley for four straight days, surely not? 16 A I wanted -- I made it clear to him that 17 I wanted some time from him each day for interviews, is that I had a lot of interviewing in mind. 19 Q Did you tell him how many hours per day? 20 A No, sir. 21 Q You were going to be out there during that 22 time and during that time Father Greeley was going 23 to be teaching? 24 A He was going to be teaching one day on 63 1 A I don't believe so. 2 Q Did you have any conversations -- further 3 conversations before you left with Mr. Ron Parent, 4 or anyone else connected with the Notre Dame Magazine? 5 A Not that I recall. 6 Q Had you commenced to make notes from the 7 reading that you have described before you left for 8 Tucson? 9 A No. 10 Q Did you take with you -- when you went to 11 Tucson what, sir. did you take with you to aid you 12 in the interview of Father Greeley? 13 A I took with me this book by Monskonsi and 14 I took with me this article by -- no, the article 15 is by Greeley, edited by Greg Baum, called "Journeys." 16 It was an autobiographical piece. 17 Q Sir, when did you arrive in Tucson; March 18 24? 19 A March 24, 1980. 20 Q About what time of day? 21 A About in the afternoon. 22 Q And did Father Greeley meet you? 23 A No, sir. 24 Q When did you first get together with 65 1 Father Greeley? 2 A When did I first physically meet him? 3 Q Yes. 4 A About 6:30 that evening. 5 Q 6:30 on the evening of March 24, 1980? 6 A That's right. 7 Q Where did you meet him? 8 A At a restaurant called El Chero in Tucson. 9 Q And had that been arranged before your 10 Arrival? 11 A He mentioned in here that there is a nice 12 Mexican restaurant, but I believe we arranged it on 13 the phone that afternoon. 14 Q Was Tuesday evening March 24? 15 A Monday evening. 16 Q So it is a day earlier than his reference 17 here, but in any event, you had a good Mexican dinner 18 with Greeley at the El Chero restaurant on the 19 evening of March 24, 1980? 20 A That's right. 21 Q And Greeley picked up the tab, or did you? 22 A I did. 23 Q That was a good lawful expense, was it not? 24 A Yes. 66 1 Q How long did you spend with Father 2 Greeley on the evening of March 24, 1980? 3 A Approximately three hours. 4 Q Was all of the time spent at the El Chero 5 restaurant? 6 A No, sir. 7 Q About how long were you at the restaurant? 8 A Two hours and forty-five minutes, maybe. 9 Maybe a little less than that. 10 That is just an approximation. 11 Probably a little less than that. 12 Q Did you tape record any of this conversation 13 at the El Chero restaurant? 14 A No, sir. 15 Q You said you spent about three hours with 16 him and you spent two hours and forty-five minutes 17 at the El Chero so that means he drove you somewhere? 18 A He drove me back to my hotel. 19 Q Now, sir. we have got a three-hour 20 conversation. No one else was present, I take it? 21 A other than the waitresses and other 22 restaurant people. 23 Q Now, on the subject of Greeley, apart from 24 exchanges on the weather Or Notre Dame's football 67 1 team and Arizona's football team et cetera, would 2 you give us the 3 what happened the evening, the conversation between 4 yourself and Father Greeley? 5 A Well, he said, "What is this all about?" 6 And I said, "Well, I want to write an article about 7 you for the magazine." And that was about it. 8 Q He told you -- you used the word "profile," 9 didn't you? 10 A I believe I did on that occasion, also, an 11 article profile. 12 Q Did you tell him how long the article you 13 had sort of floating in your mind was going to be? 14 A I said at least 8,000 [possibly 6,000] words. 15 Q And you mentioned clearly, did you not that 16 this was for the Notre Dame magazine? 17 A Yes. 18 Q Did Greeley have anything to may on the 19 subject-of Notre' Dame Magazine that you recall? 20 A Yes, sir. He said it was a -- he said . it 21 was the best Catholic publication we have. He said it 22 was very well done. 23 Q Did be-say it-was the best Catholic 24 publication, or the best University Alumni 68 1 publication? 2 A Catholic. 3 Q Therefore, from that comment, was the Notre 4 Dame Alumni Magazine is a better Catholic Magazine 5 than the Jesuits Magazine of America? 6 A You could certainly infer that. 7 Q Okay. And what else was said on the subject 8 of the Notre Dame Magazine? 9 A He said it was a very fine journal. 10 Q Did he say a very fine journal, or a very 11 fine alumni journal? 12 A Journal. 13 Q Would you describe the Notre Dame Magazine 14 as just a general Catholic journal? 15 A It serves many functions. 16 Q Isn't its primary function as an alumni 17 magazine? 18 A That is one of the functions. 19 Q What are some of the other primary 20 functions? 21 A Well, we try to fulfill some of Notre 22 Dame's mission of service to the Roman Catholic 23 church by providing a journal of opinion and of 24 reporting about the church and about topics of 69 1 interest to Catholics from a Catholic point of view 2 as best you can understand that. That is one thing 3 we do in addition to conventional university 4 publishing. 5 Q Notre Dame Magazine has book reviews, 6 does it not? 7 A It used to. 8 Q Did it in 1980 and 1979? 9 A Yes. 10 Q And did it review "The Making of the Popes 11 1978" by Andrew Greeley? 12 A Yes. 13 Q When did that review come out, if you 14 recall? 15 A December 1979. 16 Q Do you recall who wrote it? 17 A A member of the faculty with a French name-. 18 First name, Jean. 19 Q Was the -- if you recall -- the review 20 favorable, or unfavorable? 21 A I believe it was mixed. 22 Q Do you recall any notes in the review 23 about Cardinal Cody? 24 A I don't. 70 1 Q That is to say in the article itself. 2 A I don't. 3 Q You don't recall. Did you discuss the 4 review of "The Making of the Popes 1978" with Greeley 5 on the occasion of your two hours and forty-five 6 minute conversation at the El Chero restaurant? 7 A Actually it was in the car on the way home. 8 He said he did not like the review. 9 Q What did you say? 10 A I had no response. 11 Q Do you recall what Greeley said about the 12 review of his book, "The Making of the Popes 1978" 13 other than the fact he did not like it? 14 A Yes. He said he didn't understand why a 15 theologian had been assigned to it, or he made some 16 objection About the assignment. 17 Q And you had not read "The Making of the 18 Popes" at this time, had you? 19 A No, I had not. 20 Q Did you have any discussion involving 21 Monsignor Egan with Father Greeley on the evening of 22 March 24; did his name come up? 23 A Yes, his name did come up. He was giving 24 me a list of sources and Monsignor Egan was among them 71 1 Q A list of sources, people to talk about him, 2 Greeley? 3 A That's right. 4 Q Did he expand on this as to why you should 5 see Monsignor Egan? 6 A I don't recall. 7 Q On the subject matter of Greeley suggesting 8 to you sources of information about him, Greeley, who 9 else besides Monsignor Egan that Father Greeley made 10 mention of? 11 A Archbishop Bernardin, Cardinal Cody, Nancy 12 McCreaddy [sic], Bill McCreaddy [sic], Andy Bird, Mary Bird, 13 a man named Saletta. That is his wife. 14 Q Whose wife? 15 A This person named Saletta, I forgot his 16 first name. 17 His sister, Mary Jo Durkin, Jim 18 Andrews, Father Hesburgh. 19 It was a long list. There may have 20 been others. I am sure there were others. I can tell 21 you a few more. Charles Shamabrook, John Shea. 22 I will keep trying. 23 Q Was this list given to you while you were at 24 dinner, or in the car driving home? 72 1 A At dinner. 2 Q Do you recall anything else other than what 3 You have testified to, brought up at that dinner? 4 A Yes. 5 Q Would you tell us what it is, sir? 6 A As soon as I said what I was doing, he said, 7 "Can I see the quotes?" 8 Q What did that mean to you, sir? 9 A I took it to mean, can I see the quotations 10 that I would be using in my article before they were 11 published. 12 Q His, or others, or whose, or all? 13 A That was not clear. 14 Q What did you say in response, if anything? 15 A I said I cannot do that. 16 Q And what did Father Greeley say? 17 A He said, "It is not that I don't trust you, 18 but, you see, I have been burned before." 19 Q And by that you understood him to mean 20 burned by Notre Dame, or some of its representatives, 21 or burned in general by somebody, or what? 22 A I believe he specifically mentioned burned 23 by Not re Dame before. 24 Q Now, based upon your journalistic experience, 73 1 sir, when somebody is quoted directly in an article, 2 how do you make sure that where you put quotation 3 marks around something said, that you have got it 4 right? 5 A If you have it on tape, you don't have any 6 Problem with that. 7 Q And did you mention the subject of taping 8 with Father Greeley that evening? 9 A No, I don't recall doing that, no. 10 Q Is it your practice when interviewing 11 somebody either to have a tape of what the person 12 said, or to verify the quote with the person being 13 quoted? 14 That is two questions. 15 A Yes, it is. 16 Q Apart from the tape recorder as you have 17 described, sir, do you have a practice with respect 18 to quoting somebody in an article and you don't 19 have a tape to verify the exact words? 20 A If I interview a person and I do not tape 21 them? 22 Q Yes, sir, 23 A Do I call them and verify the quote? 24 Q Yes, sir, 74 1 A No, sir. 2 Q You rely on your notes? 3 A No, sir. 4 Q You take shorthand? 5 A No, sir. 6 Q Speedwriting? 7 A No, sir. I write fast. 8 Q Okay. Is there any practice in connection 9 with profiles in the Notre Dame Magazine about 10 Quoting the subject of a profile; the interview 11 Quote, is there a guideline, or any kind of practice 12 that the Magazine employs? 13 A I don't know what you are getting at. 14 No, would be the simplest answer to that. 15 Q Now, sir. did you take notes during this 16 meeting at the El Chero restaurant and in the car 17 Afterwards? 18 A I wrote down all the names that he gave me 19 to talk to further for this profile and I also wrote 20 down one or two things that he particularly wanted 21 me to write down that he was saying that night. 22 Q Such as, sir. 23 A well, he had a definition of his status 24 within the Archdiocese which he kind of said, and it 75 1 was a fairly elaborate definition which employed 2 Latin, and he said you can use that if you want and 3 So I wrote it down. 4 Q Was this in connection with his standing 5 within the Chicago Archdiocese? 6 A Yes. 7 Q I mean was he, as you understood it, trying 8 to make clear to you that he was a priest in good 9 standing with the Archdiocese of Chicago? 10 A That was already clear. 11 Q Did you write that down? 12 A I think I did, yeah. 13 Q That is one item. What other items? 14 A There may have been one or two others, but 15 I was not taking notes throughout the conversation. 16 Q Did you preserve those notes? 17 A I believe so. 18 Q Where are they now, if you know? 19 A They would be at my attorney's. 20 Q The notes of that night? 21 A The notes from that night would have been on 22 a rough sheet of paper. They would not have been 23 anything formal. 24 Q Did you turn them over to your attorney? 76 1 A As I recall, I kept any piece of paper that 2 I took notes on in the course of putting together 3 this article and all those notes I turned over to the 4 attorneys. 5 Q How many pages were the notes you took. that 6 night? 7 A Including the names, ten little sheets. 8 I remember now I was writing. 9 Q Like a little notebook like this? 10 A Yes. 11 Q Four inches by two and a half? 12 A That's: right 13 Q And you slipped out this little notebook and 14 started writing? 15 A That's right. 16 Q In any event, you preserved those notes of 17 that evening and you did turn them over to your 18 attorney? 19 A Yes. 20 Q And the one thing that would characterize 21 those notes taken that night -- it is informal - 22 but it does include a list of names? 23 A I could identify them to the best of my 24 knowledge, yes. 77 1 MR. O'BRIEN: I note for the record that we have 2 not had any such document or documents produced to us 3 and I do believe they were covered in our request 4 to produce. 5 MR. LANE: We indicate that we produced 6 everything covered in your request for production. 7 MR. O'BRIEN: Q Sir, now, we have covered 8 events of the 24th. Do you recall anything else that 9 occurred that night before we leave it? 10 A No, sir. 11 I remember random things like my 12 luggage was lost and things like that. 13 MR. LANE: Before we move on to another date how 14 about a two-minute recess. 15 Whereupon, a short 16 recess was taken.) 17 MR. O'BRIEN: Q Mr. Winters, how often does the 18 Notre Dame Magazine come out per year? 19 A Nowadays it comes out four times a year. 20 Q That is to say corresponding with the 21 seasons as in winter, spring, summer, and fall? 22 A That's right. 23 Q And how long has that been going on? 24 A That is just this year. 78 1 Q By "this year" you mean 1985? 2 A That's right. 3 Q I am looking at the issue of the Notre 4 Dame Magazine labeled "Summer 1984." 5 A We changed the names last year. 6 Q So in 1984 what was the actual number of 7 volumes or issues published per year? 8 A We go by volume rather than year. 9 The volumes roughly correspond with the year, but 10 since we are changing the frequency, that is not 11 exactly correct. 12 The last couple of years in 19 -- 13 between 1974 and 1984 the Magazine was published five 14 times a year. 15 Q And how did you label each, just by number, 16 or give them a season? 17 A For the most part in those years we gave 18 them a month. 19 Q All right. So you switched from five per 20 year to four per year? 21 A That's right. 22 Q And the switch to four to year is effective 23 for the first time in 1985, is that correct? 24 A That's right. 79 1 Q Was there any discussion at El Chero 2 restaurant on the subject matter of where, if anywhere, 3 Greeley's notes, articles, books, manuscripts were 4 maintained and kept? 5 A No, sir. 6 Q You did not bring the subject up and he did 7 not bring the subject up? 8 A That's correct. 9 Q Did you ask him any questions about 10 "The making of the Popes 1978"? 11 A No, sir. 12 Q Did you seek verification of anything about 13 Greeley found in the book and the materials that you 14 previously described that you had with you on the trip 15 to Tucson? 16 A No, sir. 17 Q Did you ask him any questions that night 18 About his dates of graduation from here and there and 19 degrees; did that subject come up? 20 A No, sir. 21 Q Did his relationship with Cardinal Meyer 22 come up; how he ended up at the University of 23 Chicago, et cetera? 24 A This was not an interview. He may have 80 1 brought it up in passing. occasionally he would say 2 things and get that down because he thought I might 3 want to use it, but it wasn't off the record, so 4 I suppose everything he said was usable, but it was 5 not an interview. I wasn't there to ask him a lot 6 of questions about his background. 7 Q Did you discuss the Universal Press 8 Syndicate with him, his publisher, or people he deals 9 with? 10 A Yes. 11 Q How did that come up? 12 A He asked me if they had tried to hire me. 13 Q In what connection? 14 A I don't know. 15 Q And you said no? 16 A "No." 17 Q And did the names of any reporters come up 18 in that conversation that night? 19 A Not to my recollection. 20 Q Did the subject matter of any events 21 whatsoever occurring within the Archdiocese of 22 Chicago come up that night? 23 A Given any time frame? 24 Q Yes. 81 1 A Yes. I remember how he began the 2 conversation. He talked about Cardinal Mundelein. 3 Q What did he say about Cardinal Mundelein? 4 A He said he may have been a homosexual and 5 he may have been murdered. 6 Q Did any other Cardinals come up for 7 discussion that night? 8 A I believe Cardinal Cody was discussed. 9 Q Did you ask any questions about Cardinal 10 Cody? What I am trying to get is if I can hear 11 everything that was said and just the substance of 12 this occasion. That is the point of this exercise. 13 A I am trying to give that. 14 Q Okay. So the subject matter of Cardinal 15 Cody came up that night at the El Chero? 16 A Well, I recall that Cardinal Cody came up 17 because he told me I might want to see Cody, but 18 didn't think he would want to see me about Greeley. 19 That was one reference to Cardinal Cody. 20 Q Did you ask -- were there any other 21 references that you recall? 22 A Not that I recall, no. 23 Q Did you discuss what works, if any, Greeley 24 had in progress, writings, that is, that night? 82 1 A He may have brought up a study he was doing 2 on young Catholics. I am not sure he did that night. 3 He did early in our meetings. 4 Actually I am sure he did now that I 5 recollect. He discussed that. 6 Q And was that a sociological kind of study? 7 A It was a study for the Knights of Columbus. 8 I believe it was a sociological study about the 9 attitudes of young Roman Catholics. 10 Q Did he discuss, or did the two of you 11 discuss anything pertaining to the National Opinion 12 Research Center? 13 A Not to my recollection, although he did 14 direct me to see Mr. McCreaddy [sic], who was associated 15 with that. 16 Q Did the subject matter of the Church 17 International come up; that is, to say how to elect 18 Popes, that sort of thing? 19 A Not to my recollection. 20 Q Did the subject of Father Hesburgh come up 21 in any way whatsoever? 22 A Yes. He gave me his name again as someone 23 I might use as a source. He calls him Ted. 24 Q What do you call him? 83 1 A Father Hesburgh. 2 Q And Father Hesburgh, for the record, was 3 then and had been for some years President of Notre 4 Dame, or perhaps was he still President, or had he 5 stepped down? 6 A He was President then and still is. 7 Q Didn't they have an attempt to get the 8 laity more involved? 9 A There is now a lay board of trustees, a 10 lay-dominated board of trustees. 11 Q Now, his report -- if you would mark 12 this document, which appears to be a Xerox copy of 13 "Summer 1984" issue, at least portions of the 14 Notre Dame magazine as Winters' Exhibit No. 1, 15 please. 16 (Whereupon, Winters' 17 Exhibit No. 1 was marked 18 for identification as of 19 this date.) 20 MR. O'BRIEN: Q Now, sir, I show you the 21 document previously described, marked Winters' 22 Exhibit No. 1, and you recall that, do you not, as 23 a Xerox copy of the front page of the Notre Dame 24 Magazine and the index and an article on "And Young 84 1 Shall See Visions," on Andrew Young. 2 You remember that issue, do you not? 3 A Yes. 4 Q Now, is this article about Andrew Young a 5 typical -- and I don't mean to suggest anything -- 6 that that is a profile, is it not, of Andrew Young? 7 A It is a profile of Andrew Young. 8 Q Okay. 9 A I suppose, yes, I would agree with that. 10 Q Okay. Did any particular future plans 11 of Father Greeley come up for discussion that night 12 at the El Chero restaurant, such as the writing of 13 fiction novels? 14 A I think he did mention that, yeah. 15 Q What did he say, if you recall? 16 A I think he said he had switched to writing 17 fiction lately and he was finding it fun. 18 Q Did he discuss the nature of any of the 19 current fiction that he had underway? 20 A I don't know that he did that night. 21 Q Did he discuss any of his work and trips 22 to Rome in connection with his book, "The Making of 23 the Popes 1978"? 24 A No. 85 1 Q All right. Sir, we now turn to March 25, 2 1980. 3 Did you get together with Greeley on 4 March 25, 1980? 5 A I did. 6 Q About what time? 7 A About 9:30 in the morning as I recall. 8 Maybe earlier. 9 Q Where did you meet with him? 10 A In his office. 11 Q At the University? 12 A That's correct. 13 Q Just the two of you? 14 A That's correct. 15 Q And it is now interview time, is it not, 16 between yourself and Greeley? 17 A We began our formal interviews which were 18 tape recorded. 19 Q Now, how long did you spend with Greeley on 20 March 25, 1980? 21 A Just about the whole day. I started in the 22 early morning and I was with him until the late 23 afternoon. 24 Q You said "early morning," you mean 9:30? 86 1 A Well, it may have been earlier than 9:30. 2 actually I think it may have been 8:00 o'clock in the 3 morning, but in any event it was the first thing in 4 the morning. 5 Q How long were you with him? 6 A All day until about 4:30 in the afternoon, 7 maybe 5:00. 8 Q Did you have a lunch with him? 9 A Yes. 10 Q Where was lunch? 11 A Some outdoor place in Tucson. 12 Q Who paid for it? 13 A I did. 14 Q Did you stay in the office during this 15 period -- except for your lunch break were you in 16 Greeley's office the whole time? 17 A No. 18 Q First describe for me for the record 19 physically where you spent those hours with 20 Andrew Greeley? 21 A I spent them in his office. 22 Q About how long? 23 A A substantial amount of time in the 24 morning and a substantial amount of time in the evening 87 1 And by that I mean more than an hour. 2 Q By "evening," you mean afternoon? 3 A Afternoon, I'm sorry. 4 Q So what are we talking about total hours 5 spent at the University of Tucson? 6 A Four, something like that. 7 Q When did you first disclose, assuming you 8 did, and I assume you did, to Andrew Greeley that 9 you were going to tape record the interview sessions? 10 A I certainly did that morning. 11 I asked him if he would mind being 12 tape recorded and he said no. 13 Q Was there any discussion before the 14 interviews began -- any further discussion on the 15 subject of reviewing either the quotes attributed to 16 Greeley in anything you might write? 17 A No, sir. 18 Q Was your tape recorder right on a desk? 19 A Yes, sir. 20 Q And about how long does each tape in your 21 particular tape recorder work? 22 A It would depend on the tape. 23 Q Well, what were your using, if you recall? 24 A I don't recall, but they would go half an 88 1 hour, forty-five minutes, an hour, depending. 2 Q Would you change the tapes, or just turn 3 them over? 4 A You would turn them over initially and then 5 change them when it ran out on both sides. 6 Q So was it half-hour a side? 7 A I don't recall specifically in this 8 interview. 9 Q Can you describe the kind of machine you 10 were using? They come in different sizes, different 11 size tapes? 12 A It was standard type. 13 Q Well, I have seen little ones and I have 14 seen big ones. What kind of a machine is this? 15 A It was a big, wide one. 16 Q Now, sir, could you describe the course 17 of the morning, what were the subjects you were 18 interviewing Father Greeley about? 19 A Essentially I was taking these interviews 20 in an obvious chronological order so I began with 21 his childhood and his father and his mother and his 22 family and his early experiences and his seminary 23 training and so forth. 24 Q About how far did you get in the morning? 89 1 A In the morning we covered most of that 2 material which I have just said to you. 3 Q The youth and education and early training 4 of Father Greeley? 5 A Yes. 6 Q Did you get him through the University of 7 Chicago? 8 A We were getting there in the morning,, yeah. 9 Q Was anything sticking out of matters of 10 particular interest or controversy in connection with 11 the morning session? 12 A No. 13 Q And then you went to lunch. Was anyone 14 else with you at lunch other than yourself and 15 Greeley? 16 A No. 17 Q After lunch you went back to his office? is A Yes, sir. 19 Q And you were there the rest of the 20 afternoon until 4:30, 5:00 o'clock? 21 A No. We went to a class. No, I'm sorry, 22 yeah, we went to a class. We went to two classes that 23 day. One was a seminar and that was in the morning. 24 Q So the morning was interrupted with a 90
previous next
Electronic edition copyright © 1998 Ingrid H. Shafer
Posted 21 August 1998