Winters Deposition, pp. 121-150
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 5: PP. 121-150 1 Q But you had lunch alone, or with Father 2 Greeley that day? 3 A I had it alone. 4 Q On Thursday, the 27th? 5 A That's correct. 6 Q Now, sir, at any time from the evening of 7 March 24 through roughly the middle of the day, the 8 27th, when you departed the campus, did you haven a 9 discussion about the subject matter of any research 10 Andrew Greeley had participated in involving different 11 kinds of magazines? 12 A Not to my recollection. 13 Q Do you recall, sir, that Andrew Greeley 14 testified -- and I cannot quote his direct words and 15 that is not important -- but he did testify in a 16 general way that his -- he had done a survey of some 17 kind or another about the different kind of 18 publications, do you recall that? 19 A His testimony in this case? 20 Q Yes. 21 A No, sir. 22 Q You don't recall that? 23 A No. 24 Q You don't recall any particular subject 121 1 matter, any discussion of that subject matter while 2 you were at Tucson visiting the University of 3 Arizona and interviewing him? 4 A I don't recall anything like that, sir. 5 Q Now, you have not laid eyes on or be.en in 6 the presence of Andrew Greeley, have you, since 7 March 27, 1980? 8 A I laid eyes on him once. 9 Q You laid eyes on him, but not to speak to, 10 or have any conversation? 11 A Well, I had a conversation with him on the 12 phone. 13 Q We will get to that. 14 Now, Ms. Reporter, I would ask you to 15 mark a collection of documents that have been page 16 numbered in this firm from 0786 through 0902, and 17 the front page says, "Erasure: Page 84, Cody: 18 Pages 41-42, 54-60, 69-70." 19 Just so we are clear, is the front 20 page materials prepared by our law firm, or is that 21 part of the exhibit? 22 MS. NIGHTINGALE: I think it is as we got it. 23 That was produced by your law firm. 24 MR. O'BRIEN: And that document that I just 122 1 described, Ms. Reporter, would you mark as Winters' 2 Exhibit No. 2. 3 (Whereupon, Winters' 4 Exhibit No. 2 was marked 5 for identification as of 6 this date.) 7 MR. O'BRIEN: Q Now, sir, you have in your 8 hand the collection of documents previously marked 9 Winters' Deposition Exhibit No. 2, do you not? 10 A Yes, sir. 11 Q And I gave you these pages of paper shortly 12 before we opened this afternoon's session and I asked 13 you to take a look at it and see if you can generally 14 state what it is and I ask you the question, what is 15 Winters' Deposition Exhibit No. 2? 16 A These are transcriptions of my interviews 17 with Father Greeley in Tucson. 18 Q I am going to ask you, sir, before the 19 conclusion of your deposition if that is the complete- 20 if this is all of the transcripts of the tapes that 21 you made while talking to Andrew Greeley; the 22 recordings you made on March 25, 26, and 27, but I am 23 not going to ask it to you now. 24 I represent to you, sir, that Winters' 123 1 Deposition Exhibit No. 2 was supplied to us by your 2 counsel in the course of discovery and exchange of 3 documents in this proceeding. 4 When were your notes transcribed, sir? 5 A They were transcribed in the months 6 following my trip to Tucson. 7 Q When were they completed, if you know? 8 A I don't recall exactly when they were 9 completed. 10 Q Were they typed up by one, or several 11 people? 12 A One. 13 Q Now, sir? it is true, is it not, that 14 certain portions of the transcript had to be 15 reconstructed from your memory? 16 I recall there were some pages, and 17 I think it appears on the face of that. 18 A Yes. 19 Q Did you have any conversation with Greeley 20 at Tucson on the subject of the skill -- and we will 21 keep this secret from your secretary if you wish; 22 I won't tell her -- the skill of your transcribers? 23 A I did, a particular transcriber, yes. 24 Q What was the subject matter of that 104 1 conversation with Greeley? 2 A it is here. Should I read it from here? 3 Q Yes, if you can find it. 4 A All right. Greeley says, "Since this is 5 now becoming a record, I'm wondering if you could 6 send transcripts of our interviews to my archives 7 at Rosary College, when you are done with them." 8 I said, "I guess I could do that, but 9 they'll be very rough." 10 Greeley: "Do you have a secretary 11 who does that?" 12 Winters; "Yes, but she isn't very 13 good at it." 14 Greeley: "It's a terrible job. They 15 really should invent something that does it 16 mechanically. I guess, technically, it's possible, 17 but they haven't got it so that it's cheap enough to 18 be practical." 19 Winters: "I'd like to visit those 20 archives." 21 Greeley: "Okay." 22 Winters: "Shit! I said the 23 secretary wasn't any good at transcribing tapes, and 24 she's going to hear that when she transcribes the tape!" 125 1 (Laughter.) 2 Greeley: "Do you want to erase that 3 now?" 4 Winters: "No, I'll get it later." 5 Greeley: (Inaudible.) (Laughter.) 6 Winters: "Ah, jeez, I got myself in 7 big trouble there." 8 Q This appears at page 0787, our page 0787, 9 of Winters' No. 2, does it not, sir? 10 A Yes, sir. 11 Q What you just read was that reconstructed 12 by you? 13 A Yes, sir. 14 Q Because it is noted on here that "Erased," 15 is that in your writing, I mean, look at the left 16 hand column of page 0787? 17 A No, sir, that is not my writing. 18 Q whose writing is it, do you know? 19 A I don't know. 20 Q The fact is that what you just read was 21 something that you put into the transcript from 22 reconstruction because you didn't want the official 23 transcriber to hear that exchange? 24 A I didn't want my secretary, Joan Riggs, 126 1 to hear that exchange. 2 Q So what you just read is your reconstruc- 3 tion -- 4 A Yes. 5 Q -- of the conversation? 6 A Yes. 7 Q And this was done, however, reasonably soon, 8 or at least in 1980, wasn't it? 9 A It was done in 1980. 10 Q Before you reconstructed it you actually 11 knew what it said in there because before you erased 12 it, you did it for your secretary, did you not? 13 A Yes. 14 Q So actually you did not reconstruct from 15 memory of the conversation; you reconstructed from 16 memory of the actual tape before you erased it? 17 A No, I reconstructed it from my memory of 18 what happened while I was there. 19 Q When you left Rosary, did you have this 20 conversation on the tape, or did you erase it at 21 Tucson? 22 A I erased this -- are you talking about 23 Rosary, or Tucson? 24 Q Tucson now. I am trying to figure out when 127 1 you left Tucson. 2 A This was still on the tape. 3 Q And before you erased it so your secretary 4 couldn't see it, did you listen to it again and 5 refresh your recollection? 6 A Yes, sir. 7 Q And she typed it up and then you had this 8 inserted in some way or another? 9 A I typed this up. 10 Q The whole thing, or just that page? 11 A Just that page. My secretary did not 12 transcribe these tapes. I thought she was going to 13 and my secretary was who I was referring to here. 14 Q Do you think, sir, by tomorrow morning you 15 can tell us whether Winters' Exhibit No. 2 16 constitutes all of the transcriptions of the tapes that 17 were made in Tucson on March 25, 26 and 27 of 1980? 18 A Yes, sir. 19 Q I will remember to ask you that in the 20 morning. 21 Now, sir, so you got back to Rosary? 22 A Notre Dame. 23 Q Notre Dame. So you were back at work, you 24 worked the following Monday? 128 1 A I believe so. 2 0 Now, in connection with Greeley's notes, 3 tapes, articles, et cetera, what was the next thing 4 that occurred? 5 A I planned to spend a week working on the 6 story, at the end of April and the beginning of May, 7 so I prepared for that. 8 Q What did you do? 9 A I called some of the people whom I wanted 10 to speak to that we asked, set up appointments. 11 Q Who did you call? 12 A I called Dan Heir (phonetic). 13 He said he did not want to be interviewed. 14 I called Bill McCreaddy [sic] Nancy McCreaddy [sic], John Shea. 15 Q And John Shea is the priest who is a 16 theologian at the seminary? 17 A That's right. 18 Q What did they say? 19 A Well, in each of these cases we arranged to 20 have an interview during that week in which I would be 21 spending in Chicago. 22 Q So the next thing that happened was three 23 interviews? 24 A No. I was not finished with the list. 129 1 Q I'm sorry, carry on. 2 A Nancy McCreaddy [sic], Andy Bird, and I believe 3 it was Mary Bird whom I spoke to. Andy is her husband. 4 A couple of people at the University of Chicago. I 5 think it was Norman Nye (phonetic) and David 6 Greenstone. And I talked to Sister Mary Field. 7 Q Anybody else? 8 A There may have been. I don't recall. 9 Q Which of those that you talked to did you 10 actually interview? 11 A of that list all but Dan Heir. 12 Q And did you transcript -- did you tape 13 record those interviews? 14 A I did not tape record the interview with 15 Greenstone, and I actually did not interview Nye 16 because he didn't show up for the interview. 17 Q But you did interview John Shea, McCreaddy [sic], 18 and Andy Bird and Mary? 19 A The McCreaddy's [sic] were interviewed separately. 20 And those interviews were taped. 21 Q Did you have those taped interviews 22 transcribed? 23 A I did. 24 Q Did you provide copies of those interviews 130 1 to your attorneys? 2 A I did. 3 Q What is it -- I don't recall that we were 4 provided copies with any of that, but leave that for 5 the moment. 6 With respect to John Shea, as you 7 sit there, did you review any of-these transcripts 8 that you just described before this occasion? 9 A I gave them a cursory glance. 10 Q What was the gist of what you learned from 11 Mr. Shea? 12 A Father Shea. 13 Q Father Shea. 14 A We talked about a number of things. We 15 talked about what he thought of Father Greeley as a 16 theologian, how he thought Father Greeley was 17 perceived in the Archdiocese. 18 We talked about Father Greeley's 19 relationship with Cardinal Cody, Cardinal Meyer, as he 20 perceived it. 21 Q Were the statements by Father Shea off the 22 record, or on the record? 23 A For the most part they were on the record. 24 He went off the record -- he didn't go off the record, 131 1 excuse me. He asked to be identified only as a 2 Chicago priest when he was discussing Cardinal Cody. 3 Q What about the McCreaddy's [sic] separately, 4 what did they tell you? 5 A I talked to Nancy McCreaddy [sic] at her home and 6 she described her long relationship with Father 7 Greeley, how she knew him as a teenager, how he had 8 been a counselor to her, the adult relationship that 9 she had. She had been a member of something called 10 the "group." 11 Q This was the Youth Group at Christ the. 12 King Parish? 13 A It was a youth group. It was a group of 14 young adults. She discussed how that worked. 15 Q And how about anything else from Mrs. 16 McCreaddy [sic] 17 A There were other things, yes, but I don't is recall them. I don't recall them. 19 Q To find out what else she said and what you 20 said, would you have to look at the transcriptions, 21 wouldn't we? 22 A That would be there. 23 Q That would be the same thing with Father 24 Shea? 132 1 A That's right. 2 Q How about Andy McCreaddy [sic], if that is his 3 name, her husband? 4 A Bill McCreaddy [sic], I interviewed him at the 5 University of Chicago at the Research Center about 6 half an hour and he discussed his professional and 7 Personal relationship with Father Greeley. 8 Q Was that on the record, or off the record? 9 A On the record. 10 Q What about what he said to you recall, as 11 you sit here today? 12 A Nothing. 13 Q So to find out what was said by McCreaddy [sic], 14 we would have to look at the transcription of your 15 tape recording? 16 A Yes. 17 Q Was any part of the discussion with Bill 18 McCreaddy [sic], off the record? 19 A No. 20 Q What did you tell these people that you 21 described you interviewed as to what you were up to? 22 A I told them I was writing an article about 23 Father Greeley for Notre Dame Magazine. 24 Q Now, what about Sister Mary Field, who 133 1 is she? 2 A She is, as I understand it, a librarian, 3 or at that time was a librarian at Rosary College. 4 Q And you called her on the telephone? 5 A I did not call her. I called the library 6 of Rosary College. I called the College. 7 Q And we are into April now? 8 A This is April of 1980. 9 Q So what was the substance of what you said 10 to Sister Mary Field and what she said to you? 11 A I called her. I told her my name is Jim 12 Winters. First of all, I called the library and I 13 asked to speak to whoever could help me with regard 14 to Father Greeley's archives. 15 Sister Mary Field came on the line. 16 I told her I was Jim Winters, that I was from Notre 17 Dame Magazine, and I was researching an article about 18 Father Greeley for the Magazine. 19 And I said I would like to come out and 20 examine the material in the archives that he keeps at 21 Rosary College. She said she would have to check with 22 someone about that. She left the phone and she came 23 back a short time later and said, "Okay, that will be 24 fine. when do you want to come?" 134 1 And I said, "Saturday, May 3rd." 2 And then I asked her for directions to 3 Rosary and she gave them to me. 4 Q And did you go to Rosary College on 5 Saturday, May 3rd? 6 A No, sir. 7 Q Did you call her to tell her you were not 8 going to come on May 3rd? 9 A No. 10 Q You just did not show? 11 A That's right. 12 Q You described the interviews; you told 13 everybody, including Sister Mary Field, that you were 14 Jim Winters, Managing Editor of the Notre Dame 15 Magazine, and you were doing a piece on Father 16 Greeley? 17 A She said she liked the Magazine. 18 Q Okay. And what was the next thing that 19 happened, if anything, in connection with Father 20 Greeley, your article, et cetera? 21 A Well, let's see. In June I discussed 22 Father Greeley with Dr. Eugene Kennedy. 23 Q Who is Dr. Eugene Kennedy? 24 A He is a Professor of Psychology at Loyola 135 1 University at Chicago. 2 Q And he is also a novelist, is he not? 3 A Yes, 4 Q He wrote "Father's Day" about Notre Dame, 5 did he not? 6 A That's right. 7 Q And I am reading right now a book he wrote. 8 It is a novel about a woman who becomes a big political 9 person in Chicago, probably someone based on Jane 10 Byrne. 11 And I read in the paper the other day 12 he is coming out with a new novel, something about 13 doctors, called "Defendant." 14 A I believe that is nonfiction.. 15 Q That is nonfiction. So it had something to 16 do with medical malpractice cases. 17 A Right. 18 Q And had you known -- Dr. Eugene Kennedy 19 is a former priest, is he not? 20 A Yes. 21 Q So you saw him? 22 A I did. 23 Q How did you get to him; did Father Greeley 24 suggest you go see Dr. Kennedy? 136 1 A No, sir. 2 Q Where did you get his name? 3 A From Monsignor Egan. 4 Q And this was in a conversation you had with 5 Monsignor Egan face to face, or on the telephone? 6 A Face to face. 7 Q And this was on the Notre Dame campus? 8 A Yes. 9 Q Do you recall the conversation between 10 yourself and Monsignor Egan on the subject matter of 11 you seeing Dr. Kennedy? 12 A I do. 13 Q What did Monsignor Egan say in substance and 14 what did you say on that occasion? 15 A He was giving me a list of people to see 16 about Father Greeley. 17 Q Did he say anything about Dr. Kennedy? 18 A He said he has known him for a very long 19 time. 20 Q Monsignor Egan had known Kennedy for a long 21 time, or Greeley had known? 22 A Kennedy had known Greeley for a long time, 23 and that he thinks he is paranoid. 24 Q Who thinks who is paranoid? 137 1 A Dr. Kennedy believes Father Greeley is 2 paranoid. 3 Q Okay. And Dr. Kennedy teaches psychology, 4 is that right? 5 A That's correct. 6 Q Did Monsignor Egan tell you that Father 7 Greeley had ever gone to Dr. Kennedy for help for his 8 paranoia, as you described, or as Egan described it? 9 A No. 10 0 In any event, you knew from Monsignor 11 Egan that Dr. Kennedy, according to Monsignor Egan, 12 believed Father Greeley to be paranoid? 13 A I did. 14 Q And you believed that, all right. 15 So you went to see Dr. Kennedy? 16 A I did. 17 Q Where did you see him? 18 A on what occasion? 19 Q The first occasion you saw him following 20 the conversation with Monsignor Egan. 21 A I first saw Dr. Kennedy at his office at 22 Loyola University on March 12, 1980. 23 Q Apart from arranging for the visit to 24 Dr. Kennedy, perhaps on the telephone, did you have 138 1 any conversation of substance with him prior to 2 March 12? 3 A No. I had talked to him about other things 4 because he is a writer for the Magazine. 5 Q The Notre Dame Magazine? 6 A That's correct. 7 Q And how long did this meeting with Dr. 8 Kennedy last? 9 A It lasted from about 11:30 in the morning 10 until about 2:00 o'clock in the afternoon. 11 Q Did you eat lunch? 12 A Yes. 13 Q Where? 14 A The Red Coach Inn in Park Ridge. 15 Q Did you buy him the lunch? 16 A Yes. 17 Q Okay. How much of this time was lunch? is A only about half an hour. 19 Q And would you tell us what you said to 20 Dr. Kennedy as to why you wanted to see him? 21 A on the phone? 22 Q Yes. 23 A I told him I was writing an article about 24 Father Greeley for the Magazine. 139 1 Q You identified the Notre Dame Magazine? 2 A Yes. 3 Q Okay. What did he say; did he make a joke? 4 A He said -- no, he did not. 5 Q Okay. And Dr. Kennedy is familiar, I 6 believe, you said with the Notre Dame Magazine? 7 A Yes, he is. 8 Q When was he last, to your knowledge, 9 published in the Notre Dame Magazine? 10 A In the winter of 1984-85 issue. 11 Q And what was the subject matter, if you 12 recall? 13 A It was on the church. 14 Q All right. Now, back to the conversation 15 consisting of the time you spent with Dr. Kennedy in 16 his office and at the Red Coach Inn. 17 Did you tape that conversation? 18 A No, sir. 19 Q Why-not? 20 A It was off the record for one thing, and it 21 didn't occur to me to tape. 22 Q Dr. Kennedy told you what he was going to 23 say would be off the record? 24 A Yes. 140 [1] Q Did he suggest to you any way [illegible] [2] him, or to attribute anything he might say that you [3] wished to put in your article, such as "spokesman" [4] or "long,-time observer"? [5] A No, he did not. [6] Q Just strictly off the record? [7] A It was off the record. [8] Q And did you take notes? [9] A While I was with him, no. 10 Q Did you after you left him write up to the 11 best that you could recall while your memory was 12 fresh, what he said and what you said? 13 A I did. 14 Q And that was written up and typed up, was 15 it? 16 A I typed it. 17 Q And that was turned over to your attorney, 18 I take it? 19 A Yes. 20 Q About how long was the typewritten matter 21 you typed up in connection with your interview of 22 Dr. Kennedy? 23 A A few pages. 24 Q Just a couple pages? 141 1 A A few pages. 2 Q We have not seen that so would you give us, 3 to the best of your recollection, what it was that 4 Dr. Kennedy said? 5 A I met him in his office and we walked outside 6 toward my car, and at that point he started discussing 7 Father Greeley. 8 He did say that the assignment I had 9 was a thankless task. He said, "Father Greeley is 10 crazy, and I mean that sincerely. He is seriously 11 disturbed, paranoia in the extreme. You have to. 12 realize you are not dealing with a person with normal 13 reactions." 14 He said, "You might want to think about 15 not doing the article for that reason, but on the 16 other hand, that doesn't make him any less interesting 17 to write about." 18 Q Apart from these opinions that Dr. Kennedy 19 had about Father Greeley, did he give you any factual 20 material to go with those opinions? 21 A He talked about his experience with 22 Father Greeley on the occasion of their preparation 23 of a study for the Roman Catholic Bishops about 24 priests. 142 1 Q What did he say about him; they couldn't 2 get along, or what? 3 A He did not mention anything about their 4 relationship. 5 Q Did he give you any specifics for this 6 conclusion of his about Father Greeley? 7 A He spoke at some length about things he 8 observed about Father Greeley. 9 Q Such as? 10 A He said he tries to control people. 11 Q What else? 12 A He said the father was important, his 13 father was important in his relationship, and his 14 relationship with his father was important to 15 understand him. 16 Q Anything else that you recall? 17 A He said that Cody had been fairly good to 18 Greeley, but that Greeley had a thing about father 19 figures. 20 Q In what way, if any, did Dr. Kennedy back 21 up his assertion that Cardinal Cody -- the late 22 Cardinal Cody -- had been very good to Greeley? 23 A I think he said fairly good. 24 Q Fairly good. 143 1 A He said basically he had left him alone, 2 that he could have taken action against him, and he 3 never did. 4 Q Did Kennedy suggest that action should have 5 been taken? 6 A No. 7 Q Did Kennedy suggest that Cardinal Cody was 8 derelict in his duty for not taking action against 9 Father Greeley? 10 A No. 11 Q What else did Dr. Kennedy have to say? 12 A I don't recall. 13 Q I don't mean anything sly by this, but was 14 Kennedy out of the priesthood by then? 15 A He was. 16 Q Did you know when Kennedy left the 17 priesthood? 18 A At that time, no. 19 Q Did you learn later? 20 A Yes. 21 Q When was it? 22 A 1977. 23 Q Anything else that Dr. Kennedy had to say 24 about Father Greeley? 144 1 A He said, "He attacks people in public 2 gratuitously. He attacks people who can't defend 3 themselves." 4 Q Did he give any examples? 5 A He mentioned Phil Gleason at Notre Dame. 6 Q Who is Phil Gleason at Notre Dame? 7 A He is a Professor of History. 8 Q Anybody else that fit in the category of 9 people being attacked in public who cannot defend 10 themselves? 11 A He mentioned an organization something 12 like the National Association of Priest Council. 13 Q Any other targets? 14 A Not that I can recall. 15 Q Did he tell you why Professor Gleason could 16 not defend himself if attacked in public? 17 A No. 18 Q Do you know Professor Gleason? 19 A No. 20 Q Ever heard of him before that date? 21 A Yes. 22 Q And what had you heard about him? 23 A I knew he was Professor of History at 24 Notre Dame. 145 1 Q Did Dr. Kennedy tell you where and when 2 Father Greeley had attacked Professor Gleason? 3 A I don't believe so. 4 Q Did he tell you the nature of the attack by 5 Greeley upon Professor Gleason? 6 A I don't believe so. 7 Q Same question as to the National Association 8 of Priests. Are you familiar with that organization? 9 A No. National Association of Priest Councils, 10 or something like that. 11 National Federation of Priests Councils 12 Q And, I take it, this National Association 13 of Priests Councils would be a National Association 14 of such Ardiocese [sic] and Priest Councils 15 A I don't know what it is. 16 Q Do you have any reason to believe that such 17 a National Association of Priest Councils, if that is 18 the correct name, or something like that, would be 19 unable to defend itself if attacked publicly by 20 Father Greeley? 21 A I believe in relation to that Council, he 22 said he attacked it while it was on its last legs, 23 and that was like shooting fish in a barrel. 24 Q Did he say anything else, did he give you 146 1 any reasons why this National Association of Priests 2 councils, even if it is on its last legs, could not 3 defend itself from these attacks by Father Greeley? 4 A No. 5 Q Did Dr. Kennedy suggest in any way by what 6 he said about the instances that you described that 7 what Greeley said about the priests in the National 8 Association was not a reasonably fair opinion to 9 express? 10 A Could you repeat that? 11 (Question read by reporter.) 12 THE WITNESS: By calling it an attack, I think 13 he inferred that it was not a reasonable opinion to 14 express. 15 MR. O'BRIEN: Q Well, sir, as an incident -- 16 you are a journalist, are you not? 17 A I am. 18 Q And is Father Greeley a journalist in your 19 opinion? 20 MR. LANE: At what point in time now? 21 MR. O'BRIEN: Q From 1980 forward. 22 A From 1980 forward he had a column. 23 Q Sir, the question is -- you don't have a 24 column except in the Notre Dame Magazine and you are 147 1 a journalist. I am asking you, sir, if your opinion 2 is that Father Greeley is a journalist? 3 A Yes. 4 Q All right. Now, sir, you believe, do you 5 not, as a journalist in the fact that robust public 6 debate is good for the republic, you believe that, 7 don't you? 8 A Yes. 9 Q And that anything that chills the free 10 exchange of opinion is bad for the republic, you 11 believe that is a bad thing if opinion stating is 12 chilled? 13 A It is a broad statement. 14 Q You are familiar with the expression, aren't 15 you, the "chilling effect"? 16 A I have heard it. 17 Q About journalists? 18 A I have heard it. 19 Q And anything that would inhibit a 20 journalist in expressing his opinion is bad, is it 21 not? 22 A No, sir. 23 Q Why is it not bad to inhibit journalists in 24 context of our republic and our constitution to 148 1 inhibit journalists in expressing their opinions? 2 A You said anything that would - 3 MR. LANE: I object to the second question. it 4 is just with the first. Let's stick with the second 5 question then. 6 (Question read by reporter.) 7 THE WITNESS: I think in general it is bad to 8 inhibit journalists in the expression of their - 9 MR. O'BRIEN: Q You do think it is bad? 10 A In general, yes. 11 Q And you want to give other journalists the 12 same right to express their opinions as you have to 13 express yours, don't you? 14 A Yes. 15 Q Did you in your notes include these opinions 16 of Dr. Kennedy that Father Greeley was crazy? 17 A I did. 18 Q Do you believe that if you had written 19 something for the Notre Dame Magazine they would print, 20 even anonymously, from the shadows -- strike that. 21 Do you believe that the Notre Dame 22 Magazine would print an article authored by you 23 quoting an anonymous psychologist that Father Greeley 24 is crazy? 149 1 Do you think that that would be 2 printed in the Notre Dame Magazine? 3 A No. 4 Q And whatever you write up, did you include 5 that in whatever writings you made ultimately? 6 A No. 7 Q Why not? 8 A It was off the record. 9 Q So the whole conversation with Dr. Kennedy 10 was off the record, in the sense of not to be 11 mentioned even without quoting a source, is that 12 correct? 13 A That's correct. 14 Q From your understanding, sir, could you tell 15 me the difference between total off the record, or 16 in the connection with some other folks -- I think 17 Father Shea you mentioned -- 18 A With Father Shea we agreed to a specific 19 guideline in which I would refer to him only as a 20 Chicago priest, but could quote him directly. 21 With Dr. Kennedy we just said it was 22 off the record. 23 Q He just said -- 24 A He said it and I agreed to it. I mean I 150
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Electronic edition copyright © 1998 Ingrid H. Shafer
Posted 22 August 1998