Winters Deposition, pp. 91-120
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 4: PP. 91-120 1 seminar which, I take it, took an hour? 2 A About that. 3 Q And there was a class in the afternoon 4 which took up -- 5 A Actually that was about a two-hour class, 6 but I didn't stay for the first hour. That was the 7 end of the day. 8 Q What time did that afternoon class begin, 9 if you recall? 10 A About 4:00, something like that. 11 Q What was the subject matter of the seminar? 12 A Sociology, religion. 13 Q and you sat through that? 14 A I did. 15 Q Did you record that? 16 A I think I did. 17 Q How about the class in the afternoon, did 18 you record that? You said it was a two-hour class 19 and you stayed about an hour. 20 A I recorded the part I was there for. 21 Q All right. And did the recoding that 22 you made include comments by students as well as 23 what Father Greeley said? 24 A It recorded whatever happened. 91 1 Q But that included certainly the seminar 2 comments by students? 3 A Yes, I believe so. 4 Q I mean, yes, the seminar, they just did 5 not sit there like lumps on the log? 6 A Yes. 7 Q They did say something and you recorded 8 whatever was said? 9 A I believe I did not record the seminar in 10 retrospect. I did record the first half of that 11 course, but for some of the reasons you are getting at 12 here, I don't think I bothered to report the seminar. 13 Q The seminar was on sociology of religion. 14 What was the class subject matter? 15 A Sociology of religion. 16 Q That was around the table? 17 A I believe it was not. I believe it was 18 more like a conventional classroom. 19 Q What was the setting for the two-hour 20 class in the afternoon of which you attended one hour? 21 A It was a large lecture hall. 22 Q About how many students were there, if you 23 recall? 24 A Maybe 100. 92 1 Q of the hour you were there, Father Greeley 2 did most of the talking? 3 A That's right. 4 Q All of which you recorded? 5 A As I recall, I recorded most of it in any 6 event. I may have turned it off after a while. 7 Q We are now at the end of the day after 8 late afternoon of March 25th. 9 During the day of March 25th, as you 10 have described it, did the subject matter of where, 11 if anywhere, Father Greeley kept his files, records, 12 et cetera; did that come up that day? 13 A No, sir. 14 Q Nothing on that subject whatsoever? 15 A No, sir. 16 Q Were you with Father Greeley the evening 17 of the 25th, 18 A No, sir. 19 Q Did you have any phone conversation with 20 him after you left campus that day? 21 A No, sir. 22 Q Where were you staying, incidentally? 23 A Plaza International Hotel. 24 Q That was off campus? 93 1 A I believe it was off campus. 2 Q All right. Now, that night did you listen 3 to your tapes that you had made that day? 4 A I believe I prepared the next day's 5 interviews. I don't know -- I know I didn't listen 6 to the tapes. 7 Q When you say you prepapred [sic] the next day's 8 interviews, we are talking about March 26, what did 9 you do to prepare? 10 A Wrote out questions on a piece of paper. 11 Q Do you recall the subject matter that 12 you intended to address on the 26th? 13 A We addressed a number of subject matters in 14 the afternoon of the 25th and then it moved into the 15 26th. I don't recall specifically what we were going 16 to get into on that day. 17 Q As of the 25th you had not finished the 18 basic biographical data as to Father Greeley, had you? 19 A I don't believe so, no. 20 Q And these notes that you made for further 21 interviewing on March 26th, did you keep them? 22 A I may have. 23 Q Do you remember one way or the other whether 24 you did or didn't? 94 1 A I believe I did. 2 Q Did you turn them over to your attorneys? 3 A I did. 4 Q About when in connection with this lawsuit? 5 A Yes, I believe I did. These were not notes 6 of what Father Greeley was saying. These were just 7 notes of my questions, so I may have discarded those; 8 but I believe, to the best of my recollection, that 9 Ikept them. 10 Q What was your plan for the interview, if 11 you recall, for the 26th since we don't have the 12 documents you referred to? 13 A The-plan was, as it was executed, whatever 14 we talked about was what we planned to talk about. 15 Idon't off the top of my head recall what we talked 16 about on the 26th but we were moving chronologically 17 through his life covering his various activities. 18 Q So in 1980 Father Greeley would have been 19 52 or three, would he not? 20 A He was born in 1928, so he would have been 21 52. 22 Q So you had quite a ways to go yet, didn't 23 you? 24 A I only testified as to what we talked about 95 1 in the morning and I said we had gotten up to the 2 seminary. You didn't ask me about the afternoon. 3 Q How far did you get in the afternoon of the 4 25th? 5 A we had an interview. We talked throughout 6 lunch on tape, and then we talked back in his office. 7 So we got pretty far. We got into his priesthood and 8 into the 1960s at least. 9 Q So you got him at Christ the King Parish? 10 A We talked about that, yeah. 11 Q On the 25th? 12 A That's right. 13 Q You had not been at the University of 14 Chicago yet that day? 15 A Yes. 16 Q So now on the 26th of March when did you get 17 together with Father Greeley? is A Early in the morning. 19 Q By early, what time approximately? 20 A Sometime between 8:00 and 8:30. 21 Q And you got together again with him at his 22 office? 23 A That's correct. 24 Q Would you describe the time that you spent 96 1 with Greeley on March 26th, 1980? 2 A This is Wednesday? 3 Q I don't know what day it was. Is Wednesday 4 the 26th? 5 My colleague informs me the 26th was 6 a Wednesday. 7 So what happened -- first, how long 8 were you with Greeley and where did you go with him 9 that day before we get to the subject? 10 A I had a long interview with him that 11 morning. 12 Q In his office? 13 A In his office and we reconvened in the 14 afternoon. 15 Q So you did not have lunch with him on the 16 26th? 17 A I don't believe so. It is conceivable that 18 we did, but I don't believe so. 19 Q What time did you reconvene? 20 A Sometime in the afternoon, maybe around 21 2:00. 22 Q And Father Greeley had no class on Wednesday 23 morning, March 26th? 24 A That's correct. 97 1 Q And so-you were at his office on the 2 morning until lunch time? 3 A That's correct. 4 Q And then you separated? 5 A That's correct. 6 Q And then you came back to Greeley's office 7 around 2:00 p.m.? 8 A That's right. 9 Q How long were you with him that afternoon of 10 Wednesday, March 26th? 11 A Something like two hours. 12 Q Two hours. And this session in the 13 afternoon was not interrupted by Greeley's giving a 14 lecture, or talking to a class? 15 A No, Sir. 16 Q Would you describe the substance of the 17 interviewing on Wednesday, March 26th, in the 18 morning, or if it is easier, the whole day, whatever 19 comes easiest to you? 20 A We talked about Cardinal Cody. 21 Q Was this in the morning, or afternoon - 22 let's not worry about morning and afternoon. 23 Just your best recollection of 24 March 26th, the substance of what was said by you and 98 1 by Greeley on the 26th; you talking in his office 2 on the subject matter as you just mentioned of 3 Cardinal Cody. What did you say and what did 4 Greeley say? 5 A He had addressed Cody at some length the 6 previous day, and I think I only had a few questions 7 to clarify what he had said. 8 I asked him several questions. 9 Q What were those? 10 A I don't recall exactly, but I believe they 11 had to do with, for example, well, if Cody really 12 wanted to get you, couldn't he, and he said, yes, he 13 does have the power to do that, but Cody is like 14 running water; he follows the path of least resistance. 15 He said things like that. 16 Q Now, this is on Wednesday the 26th? 17 A That's right. 18 Q What had he said on Tuesday, the 25th, you 19 just said he had brought up the subject of Cody, or 20 had discussed Cody at least on the 25th, Who said 21 what, please? 22 A I asked him something like what about him. 23 He said that he is a psychopathic monster with 24 paranoid delusions; he lies, cheats, steals, breaks all 99 1 all the--rules; he is the only truly evil person I 2 have ever met. 3 That was the thrust of what he said. 4 Q And you recorded all of that? 5 A That's right. 6 Q You still have those transcripts, do you 7 not? 8 A I do. 9 Q And did you review -- you did review those 10 before coming here, did you not? 11 A I did. 12 Q And what did you say, or what further 13 questions did you ask? 14 A I said, "Oh." And he went into it again. 15 He said some more about that and he said, "I will not 16 go into his relationship with the woman who has made 17 hundreds of thousands of dollars off the church. 18 There are some reporters hunting that up now. They 19 may print a story. I don't know. But it is that 20 level of insanity." 21 Q Anything else? 22 A I wasn't eager to pursue the Cody.-subject 23 at that point. 24 Q Were you aware of a relationship, if any, 100 1 between Monsignor Egan on the one hand and Cardinal 2 Cody on the other? 3 A Yes. 4 Q What were you aware of? 5 A Well, Cardinal Cody was Monsignor Egan's 6 boss. 7 Q Not while he was at Notre Dame? 8 A In a sense he still was because he still 9 was a priest of the Archdiocese of Chicago. 10 Q What was your understanding about why 11 Monsignor Egan went to Notre Dame from Chicago? 12 A As I understand it, he met Father Hesburgh 13 in an airport in 1970 and Father Hesburgh said, 14 "Gee, you look terrible, why don't you come out to 15 Notre Dame for a year's sabbatical." 16 Monsignor Egan asked for permission to 17 do that and received it. 18 Q From Cardinal Cody? 19 A From Cody. 20 Q How long was Monsignor Egan at Notre Dame? 21 A 12 years. 22 Q And it is a fact, is it not, that after 23 Cardinal Cody died, Monsignor Egan returned to the 24 Archdiocese of Chicago? 101 1 A That's correct. 2 Q And he resumed duties at Notre Dame after 3 his year sabbatical, did he not, didn't he have a job 4 at Notre Dame? 5 A He got an appointment at Notre Dame. 6 Q So most of the time he spent at Notre Dame 7 he was working at Notre Dame? 8 A That 's correct. 9 Q What was his job at Notre Dame? 10 A He had various positions. Finally his 11 position was an assistant to the president. 12 Q Anything else on the subject matter that 13 you have been referring to a conversation between 14 yourself and Greeley on Tuesday, March 25? 15 A We covered a broad range of topics. We 16 covered the Archdiocese. We covered his relationship 17 with Cardinal Meyer. 18 Q That was very pleasant, was it not? 19 A As he recounted it, yes. And that is how 20 we led into the relationship with Cardinal Cody. 21 That obviously came next. And we got out of that 22 and talked about other subjects. 23 Q What other subjects? 24 A I don't recall right at the moment, but 102 1 we talked about his work. 2 Q Why did you not as you indicated want to 3 pursue the subject of Cardinal Cody with Father 4 Greeley on March 25 or March 26, 1980? 5 A I had asked him two very mild questions and 6 it got him in a state of high agitation, extremely 7 high agitation. 8 Q That is newsworthy stuff, isn't it? 9 A Yes. 10 Q Then why were you unwilling or reluctant 11 to pursue it? 12 A I didn't want to agitate him further. 13 Q And didn't you know, sir, at the time that 14 the Notre Dame Magazine would never print that kind 15 of stuff anyway; you knew that? 16 A I did not know that. 17 Q Have you ever heard of the Magazine 18 publishing such comments about a leading churchman 19 by a fellow churchman? 20 A It seemed to me that was legitimate. 21 It was on the record. It was newsworthy. 22 Q That is not my question. Can you think of 23 any time where any kind of such criticism was leveled 24 against the Prince of the Church by a clergyman? 103 1 MR. LANE: I object to the characterization of 2 Prince of the Church. 3 MR. OBRIEN: That is what a Cardinal is. Take 4 my word for it. 5 A Sir, we have never had an occasion to 6 print an article in which this sort of language was 7 used by a Cardinal other than this occasion, which we 8 didn't subsequently do for other reasons. 9 Q I suggest you are still not answering the 10 question. 11 Sir, isn't it a fact that the Notre 12 Dame Alumni Magazine would not print that kind of 13 statement? 14 A No, sir. 15 MR. LANE: objection, asked and answered. 16 THE WITNESS: No, sir, that is not a fact, sir. 17 MR. O'BRIEN: Q Can you recall any such harsh 18 remarks ever delivered of a Cardinal about the church 19 which was printed in the Magazine where the Cardinal 20 was living 21 A No, sir. 22 MR. LANE: I object to that and move it be 23 stricken. 24 MR. O'BRIEN: Q Anything else that you can 104 1 recall that you have not touched upon, on March 25, 2 before we leave it, hopefully, forever? 3 MR. LANE: You mean in the time he was with 4 Greeley. 5 MR. O'BRIEN: Q Yes. 6 A No. 7 Q On the evening of March 25 after you left 8 strike that. 9 At any time during the day of March 10 25, that is a Tuesday, while you were out at Tucson, 11 did you call anybody connected with the Notre Dame 12 Magazine? 13 A No, sir. 14 Q Did anyone connected with the Notre Dame 15 Magazine call you? 16 A No, sir. 17 Q Did you report at any time on March 25 to 18 anyone at all on the subject matter of your 19 discussions, your interview with Greeley? 20 A No, sir. 21 Q All right. So the evening on March 25 you 22 were preparing for March 26th? 23 A That's correct. 24 Q And any other activity was irrelevant, 105 1 anything connected with this lawsuit? 2 A That's correct. 3 Q Now, on March 26, you had some follow-up 4 questions you said with respect to Cardinal Cody. 5 I think we covered that. 6 Have we covered that? Do you have 7 anything further to add on the subject of follow-up 8 questions on Cody? 9 A I don't. 10 Q So what was the time you spent with Greeley 11 on March 26th devoted to; what were the subject 12 matters? 13 A I don't recall specifically what we would 14 have gotten into on that day, but we did get into 15 Cody, I know that. We did get into other aspects of 16 his career. 17 Q Such as? 18 A I believe we talked about his novel writing. 19 I think we talked about his sociology. We talked 20 about a range of things. 21 Q Well, what ranges -- when you say "a range," 22 that does not give me any information at all. 23 A I cannot be specific right off the top of 24 my head about what we talked about on that day. 106 1 There are records. 2 Q That is to say the tapes? 3 A And the transcripts of them. 4 Q Did you have the transcript -- they are 5 dated, are they not? 6 A Yeah. 7 Q And you turned all those over to your 8 lawyers, did you not? 9 A I did. 10 Q All right. Sir, on the subject of novels 11 on March 26, what do you recall was said by Father 12 Greeley? 13 A I do know that he talked about his novel, 14 "Death in April," and he said he would have a person 15 from his publishing company send me a copy of it, 16 which didn't happen. 17 He talked about the "Cardinal Sins." 18 He said it was not about Cody. I believe that was 19 the first thing he said about it. 20 Q That had not been published yet? 21 A It had not been published. I believe he had 22 written it and was working on a second draft. 23 He said it was not about Cody. He 24 said it was about two churchmen, one a priest, the 107 1 other a Cardinal, one who could keep the vow of 2 celibacy, the other who couldn't. The priest who 3 could keep the vow of celibacy was the non-Cardinal. 4 The Cardinal was the one who could not keep it, and 5 the priest kept bailing out the Cardinal until there 6 was a confrontation. 7 Q Did he give you a manuscript of the book? 8 A No, sir. 9 Q Okay. Sociology, what was said about 10 Sociology? 11 A I don't recall. 12 Q Although I hesitate to ask, but I want to 13 make sure we get as much as of this that you remember 14 between that period, between yourself and Greeley on 15 March 26th, Wednesday, what was said on the subject 16 of Cody other than what you have already described? 17 A I don't recall. 18 Q Nothing dramatic like you recalled from 19 March 25? 20 A It was not quite as dramatic as that, no. 21 Q Anything else you recall that was done on 22 March 26th? 23 A. Yes. He told me there was another reporter 24 in town who had gotten sick. He was supposed to meet 108 1 with him but he had gotten sick. 2 Q Who was that? 3 A He didn't mention the name. He said he was 4 from Washington. 5 Q And what was the other reporter -- did he 6 tell you anything more than there was another reporter 7 in town apparently to talk to Greeley about something. 8 Did he tell you what this other 9 reporter was going to talk to him, Greeley, about? 10 A No, sir. 11 Q Did you ask? 12 A No, sir. 13 Q Did he tell you apart from being from 14 Washington, what publication this reporter represented? 15 A No, sir. 16 Q And he did not tell you what kind of thing 17 this reporter was investigating, if anything? 18 A No, sir. 19 Q And you did not ask? 20 A No, sir. 21 Q Is that complete, what you recall, about the 22 substance of Wednesday, March 26? 23 A Yes, sir. 24 Q To go back to March 26, did the subject 109 1 matter come up on that day at all about any records 2 of Andrew Greeley? 3 A No, sir. 4 Q Nothing about where I store my stuff, 5 nothing came up? 6 A Nothing like that. 7 Q And all of the tapes you made on the 26th 8 like those of the 25th were transcribed? 9 A That's correct. 10 Q And then later the transcriptions, or 11 copies, were turned over to your attorneys? 12 A Yes, sir. 13 Q And each transcript bore the date of the 14 transcription, did they not? 15 A I believe so. 16 Q And you have copies, do you not? 17 A I do not I don't believe. 18 Q You did not retain copies? 19 A I gave what I had to my attorneys. 20 Q All right. Now, we are up to Thursday, 21 March 27. Did you get together with Greeley that 22 day? 23 A I did. 24 Q About what time did you first get together 110 1 with him on Thursday, March 27? 2 A About 9:30 a.m. 3 Q In his office? 4 A That's correct. 5 Q How long were you with him in the morning 6 of the 27th? 7 A At least two hours. 8 Q Was any part of that time interrupted by 9 Greeley giving a seminar, or teaching a class? 10 A No, sir. 11 Q So you were with him a straight two-hour 12 shot on Thursday, March 27? 13 A At least two hours. 14 Q And were you with him at lunch? 15 A No, sir. 16 Q And were you with him in the afternoon of 17 Thursday, March 27? 18 A No, sir. 19 Q So it was a two-hour session on Thursday, 20 March 27? 21 A As I have said, at least two hours. 22 Q All in the morning? 23 A All in the morning. 24 Q I may have asked this, but at the 111 1 conclusion of the day of March 26th, or any time 2 prior to March 27, did you discuss with anyone at 3 all about what was happening and what was being said 4 by yourself and Greeley during these interviews on 5 March 25 and March 26? 6 A No, sir. 7 Q You made no reports. So now we are up to 8 the morning of the 27th, and as of that moment when 9 you commenced further interviewing, you had not 10 recorded to anybody at all about your interviews 11 with Greeley in Tucson, Arizona? 12 A No, sir. 13 Q What was the subject matter of the two 14 hour session on Thursday, March 27? 15 A We were wrapping things up. We were talking 16 about odds and ends, getting towards the end of the 17 interviewing obviously. 18 At the end of the interviews I asked 19 him to tell me what he thought about various people; 20 gave me kind of a mini-column is how we said it. 21 Q Just a quick reaction? 22 A Yeah. 23 Q Where you would say a name and he would 24 react to it? 112 1 A A few lines. He would tell me what he 2 thought of this individual. 3 Q Did you have a list prepared of individuals? 4 A Yeah. 5 Q And you were operating from a note that you 6 prepared the night before? 7 A I guess so, yes. 8 Q You read names off and Greeley responded 9 to that one-liner, or two-liner? 10 A Several liner. 11 Q And you recorded all of that and that was 12 transcribed? 13 A That's right. 14 Q What are the names of the people you 15 submitted to Greeley for his quick response? 16 A Father Hesburgh was one, Monsignor Egan, 17 Gary Wills, a number of people in the Catholic 18 community. Pope Paul VI, Pope John Paul I, Pope 19 John Paul II, Phil Donahue. 20 Q Do you recall the substance of Greeley's 21 answer on one or two or possibly even three-liners 22 about any of the above names? 23 A Why don't you list them? 24 Q Hesburgh. 113 1 A A good friend and a very important person 2 in the church. 3 Q Gary Wills? 4 A He said he would not criticize another 5 columnist from universal Press Syndicate. He said 6 some other things I don't recall. 7 Q The various Popes referred to? 8 A He called Paul VI the Lyndon Johnson of 9 the Popes. I don't know if he did that on that 10 particular moment. 11 He thought he was a failure. 12 John Paul I, he was high on, and John 13 Paul II he thought was a complex man and the verdict 14 was out on him. 15 Q How about Phil Donahue? 16 A He said he had been on the show once. 17 He said he was a conflicted man that blamed the 18 church for his problems like his marriage; that 19 he should marry Marlo and get it over with. Something 20 to that effect. 21 Q Donahue went to Notre Dame? 22 A That's correct. 23 Q Anything else that you recall? 24 A No. 114 1 Q I think I have asked you this. We are now 2 on Thursday, March 27, and there is no discussion on 3 Wednesday, March 26. of archives, storage, records, 4 nothing? 5 A None whatsoever. 6 Q Okay. What else happened on the morning of 7 Thursday, March 27? 8 A well, the first thing he said to me is: 9 "Now that this has become a record I am wondering if 10 you would send transcripts of our interviews to my 11 archives in Rosary College." 12 I said; "I guess I could do that, but 13 they will be very rough, Our secretary does not do 14 a very good job at transcribing theories." 15 He actually asked me, "Does somebody 16 do that?" I said, "Yeah, but she is not very good 17 at it." 18 Q Did he discuss his own use of tapes at that 19 occasion, did that prompt the discussion between you, 20 how you use your tape machine one way? 21 A No, sir. He brought it up himself without 22 any prompting. And then I said I would like to visit 23 those archives and he said okay. 24 Q. Was anything else said on the subject of 115 1 of the archives? 2 A No, sir. 3 Q Did you ask where these archives were? 4 A I knew where they were. He said they were 5 in Rosary College. I knew that. 6 Q How? 7 A I knew it from Kotre's book. 8 Q But you had not brought up the subject 9 until -- the subject was not discussed until Thursday, 10 March 27? 11 A That's correct. 12 Q Do you recall anything else now that was 13 said in Greeley's office that was said on the subject 14 of Rosary College archives, other than what you have 15 described? 16 A Not one thing. 17 Q Did you state that you did intend to visit 18 the archives? 19 A I said that I would like to visit those 20 archives and he said okay. 21 Q That was it? 22 A That was it. 23 Q All right. Anything further in the office 24 on the subject of archives? 116 1 A No, sir. 2 Q And did you walk across the campus with 3 Greeley following the discussion in his office? 4 A We went to a court that he was teaching. 5 Actually it was a class that he was being the guest 6 lecturer at. He was lecturing on Irish families. 7 I sat in on that. And from that we took our leave. 8 Q Did the subject of manuscripts come up 9 A Yes. 10 Q -- at any time of the day of Thursday, 11 March 27, in a discussion between yourself and 12 Greeley? 13 A He gave me a manuscript of a book that 14 he was doing on the young Catholics. He gave me 15 that, he didn't give it to me that day. He gave 16 it to me the day before. 17 Q First of all, prior to March 27, had the 18 subject of Greeley's manuscripts for his writings 19 been discussed at all? 20 A Yeah. He mentioned that he gave me that 21 manuscript. 22 Q Apart from that? 23 A He wanted a copy of the "Death in April" 24 sent to me and that may have been in the manuscript. 117 1 Q Was there any subject about manuscripts 2 in connection with the archives at Rosary College? 3 A No, sir. 4 Q At any time had you ever heard the word 5 apart from as you have described? 6 A I don't recall it coming up in connection 7 with the archives, no. 8 Q You have read Father Greeley's deposition, 9 have you not? 10 A No, I haven't. 11 Q Do you recall at the point that you were 12 talking across the campus and he is saying to the 13 effect, you know, my manuscripts are stored at Rosary 14 and if you want to take a look at them, you don't 15 recall that? 16 A No, sir. 17 Q And the only subject matter of a conversa- 18 tion between yourself and Greeley with respect to 19 that manuscript was the manuscript of "Death in 20 April"? 21 A Yeah. 22 Q And a manuscript of which he promised to 23 send you and didn't, and then a manuscript which he 24 did give you of his study on Catholic youth? 118 1 A That's right. The possibility of my 2 looking at the manuscript came up. 3 Q When? 4 A I don't recall. 5 Q So at some point that subject apart from 6 "Death in April" and apart from the study of the 7 Catholic youth, the-subject matter of you looking at 8 Greeley's manuscripts did come up? 9 A I recall that, yes. 10 Q Did you bring that up, or did he? 11 A I don't recall that. 12 MR. O'BRIEN: I think it is a good time to 13 break now. It is four minutes after 1:00. 14 (Whereupon, a lunch break 15 was taken.) 16 MR. O'BRIEN: Q The subject of looking at 17 manuscripts other than the manuscript of the novel 18 and other than the manuscript of the study of Catholic 19 youth came up during the period March 24, 25, 26, 27, 20 while you were at Tucson, Arizona? 21 A Yes, I recall the specifics of it. 22 Q But you don't recall what day it occurred? 23 A I do, yes. 24 Q What day? 119 1 A The 27th, Thursday. 2 Q What were the circumstances? 3 A It was after the interviews were over and 4 we were outside and I was walking. I was preparing 5 to leave the campus, to take my leave. 6 Q He was seeing you off? 7 A So to speak. 8 Q Okay. What happened; who said what? 9 A I mentioned that I might want to review 10 some of his manuscripts to see how he put them 11 together and he said, "Those are in the archives." 12 Q Was anything further said on that? 13 A No, sir. 14 Q That was the end of it? 15 A That was the end of it. 16 Q Now, sir, at any time -- what time did you 17 leave the Tucson campus? 18 A I left the Tucson campus the next day. 19 Q The 28th? 20 A Friday, the 28th. 21 Q And Thursday afternoon what did you do; 22 just write up your notes, or review your notes, or 23 what? 24 A I don't recall. 120
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Electronic edition copyright © 1998 Ingrid H. Shafer
Posted 22 August 1998