Winters Deposition, pp. 151-180
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 6: PP. 151-180 1 have some rights in the matter, too. 2 Q Did you ever run across anyone else that 3 said Father Greeley was crazy? 4 A Sick was the term I heard. 5 Q Sick? 6 A Yes, sir. 7 Q Crazy was Kennedy. Sick, who said he was 8 sick? 9 A Father Hesburgh, Dick Conklin, Father 10 Burtchall, Father Egan used the terminology 11 megalomania, and implied that he was paranoid. 12 Q Monsignor Egan. 13 A He goes by Father. Monsignor is his church 14 title. 15 Q Anybody else? 16 A Not to my recollection. 17 Q Now, this last group of people you named, 18 sir, were mostly connected, as I recall, with Notre 19 Dame University, were they not? 20 A Yes, several. 21 Q And you would not print such comments in 22 the Notre Dame Magazine, would you, attributing to 23 Father Hesburgh the statement you just attributed to 24 him, or any of the others, you wouldn't write that up 151 1 in the Notre Dame Magazine, would you? 2 A Father Hesburgh was speaking to me in a 3 private conversation. 4 He was not speaking to me on the record, 5 or off the record. It was a private conversation. 6 It was a business conversation. 7 Q That is not my question. Would you print 8 that sort of thing in the Notre Dame Magazine? 9 MR. LANE: I don't think you gave him a chance 10 to answer. 11 MR. O'BRIEN: Q The answer is no, and explain it. 12 MR. LANE: He could explain it and then answer 13 yes or no, It doesn't have to be in the order you 14 prefer. 15 THE WITNESS: You are asking a hypothetical 16 question about sorts of things. We print all sorts 17 of things. We print many articles a year. 18 MR. O'BRIEN: Q When did you talk to Father 19 Hesburgh where he expressed that opinion you just said 20 he did? 21 A on August 4, 1980. 22 Q Where did that take place? 23 A In Father Hesburgh's office. 24 Q And who was present? 152 1 A I was and he was. 2 Q How did the meeting come about? 3 A His secretary called me that morning and 4 asked that I come and see Father Hesburgh at 3:15 that 5 afternoon. 6 Q 3:15 on August 4, 1980? 7 A That's correct. 8 Q Had you ever had a private conversation with 9 Father Hesburgh prior to August 4, 1980? 10 A I had met him. 11 Q I mean, yeah, you sat down with him and had 12 a talk with him about any subject? 13 A I interviewed him, just the two of us once. 14 Q For the Magazine, the Notre Dame Magazine? 15 A Yes, sir. 16 Q Apart from that? 17 A No, sir. 18 Q Okay. How long were you at Father Hesburgh's 19 A An hour and a half. 20 Q Was anyone else present? 21 A No. 22 Q Did you transcribe that conversation? 23 A Did I transcribe it? 24 Q Did you record it? 153 1 A No, sir. 2 Q Did he? 3 A Not to my knowledge. 4 Q All right. Could you give us, sir, the 5 substance of what Father Hesburgh said and what you 6 said on August 4, 1980 in Hesburgh's office? 7 A Okay. Can we take a break here? 8 (Whereupon, a short 9 recess was taken.) 10 MR. O'BRIEN: Q I believe we were, sir, at your 11 meeting with Father Hesburgh, on August 4 and in. 12 Father Hesburgh's office at approximately 3:15 p.m., 13 involving just yourself and Father Hesburgh. 14 Would you give us the substance of what 15 Father Hesburgh said on that occasion and what you 16 said? 17 A It actually began at 3:30. It was is scheduled for 3:15, but it was pushed back to 3:30. 19 I mean he just didn't see me until 20 3:30. 21 He mentioned that he had been out of 22 the country and had been in Cambodia and that he had 23 a cold. And he said he had been in a lot of time 24 zones and things. 154 1 Then he told me that he had received 2 this letter from Father Greeley. "As you know," -- 3 he said -- "I have gotten this letter from Greeley." 4 Q Excuse me just a minute. He showed you a 5 letter? 6 A He just picked it up, or he referred to a 7 letter from Greeley. And he said, "I have been talking 8 to Greeley about this. I have talked to Bernardin 9 and I have talked to Greeley, and I am expecting a 10 call, and I just thought I have talked to everybody 11 about this but you, and I wanted to hear what you had 12 to say about this." 13 Q When he said "this," what is the "this," 14 can you describe the "this,-" what is the subject 15 matter of the conversation? 16 A I assume it was the letter that he had 17 received from Greeley, which I assume was a copy of 18 the letter Greeley had sent to Ron Parent, since he 19 had copied in Father Hesburgh on that letter. 20 Q So what did he say? Try not to summarize. 21 Try to give us the substance of what he said. 22 A He told me he wanted to hear what I had to 23 say. So I told him that I had decided to write this 24 article about Father Greeley, as he knew. 155 1 Are you going to listen? 2 Q Yes, I am listening. 3 A I said I had decided to write this article 4 about Father Greeley, which he knew, because I had 5 asked him some questions through a letter. 6 Q Asked who some questions through a letter? 7 A Father Hesburgh. 8 And I said that I have gone out to 9 interview Father Greeley in March, that in the course 10 Of my interviews he had brought up his archives. 11 I said that I would like to visit his archives, and 12 he had said okay, and I said I did go out to visit 13 the archives several months later in July; that I 14 had the full cooperation of the people who were 15 responsible for the papers at Rosary College; that 16 I had gone through the so-called archives. 17 I said they were not archives. There 18 were 18 file boxes and papers very loosely put 19 together. 20 I said I had gone through them carefully 21 and had made several hundred copies of material in 22 those files. 23 And that was the essence of it. 24 Q You said you made several hundred copies, 156 1 you mean you copied several hundred pages? 2 A Altogether there were several hundred copies, 3 I made one copy of each page that I wanted. It had 4 added up to several hundred. 5 Q And you made these copies at Rosary College, 6 did you not? 7 A Yes. 8 Q And did you tell Father Hesburgh that you 9 also took from Rosary College from these boxes some 10 tapes? 11 A No. 12 Q But you did, didn't you? 13 A I did. 14 Q And you took certain tapes in Greeley's 15 boxes, the so-called archives, to the Notre Dame 16 campus? 17 A I did. is Q And there you copied them, did you not? 19 A No. 20 Q What did you do with them, the tapes? 21 A I listened to them and made a partial 22 transcription of them. 23 Q Partial transcription? 24 A That's correct. 157 1 Q Did you tell Father Hesburgh where those 2 tapes that you had removed from Father Greeley's 3 archives at Rosary were on August 4, 1980? 4 A No. 5 Q Where were they on August 4, 1980, the date 6 of the conversation? 7 A In my office. 8 Q So they had been there ever since, when, 9 July sometime? 10 A That's right. 11 Q okay. You did not tell Father Hesburgh 12 that? 13 A I did not. 14 Q Would you please carry on with the 15 conversation? 16 How many tapes did you take, 17 incidentally? 18 A Ten. 19 Q Do you recall the labels of those tapes? 20 A one said "Pope I" and one said "Pope II." 21 Roman Numeral II. That is about it. That is all I 22 remember as far as labels. 23 Q Did you tell the Sister custodian, whatever 24 her name was, that you were removing the tapes from 158 1 the library from the archives? 2 A No. 3 Q So back with Father Ted. 4 A He gave me this opportunity to fill him in 5 on the details so I did. 6 And he said, "Jim, there is only one 7 thing we can do, and that is to send it all back." 8 And he gave three reasons for that. 9 Q What were they? 10 A He said, "It is not for the Magazine. We 11 don't do exposés." 12 Q We don't do what? 13 A Exposés. 14 He said, "At Notre Dame we don't hurt 15 people." And he said, "Father Greeley is a sick man." 16 Q Now, sir. had you told him about -- you had 17 not told him about the ten tapes that you physically 18 removed. 19 Did you tell him about the stuff you 20 copied; you did tell him that? 21 A Yes. 22 Q And when he said "return," you understood 23 him to mean, did you not, return the copies that you 24 had made? 159 1 A I said, "I really cannot return them." 2 One of the things I said in the course of this 3 conversation was, "I really cannot return them to 4 Greeley because Greeley never had these copies." 5 Q What do you mean by that, sir? 6 A Greeley had never had physical possession 7 in any way of the copies that I had made at Rosary 8 College. 9 Q His originals were his, were they not? 10 A They were and his originals were still at 11 Rosary College. I had no immediate access. 12 Q What did Father Hesburgh say about that, 13 your position on the Xerox copies you made of Greeley's 14 work? 15 A I don't recall. 16 Q Since he did not know about the tapes, 17 correct, Father Hesburgh? 18 A To my knowledge, I didn't tell him. 19 Q So the only thing he knew about was what you 20 copied? 21 A The copies. 22 Q And what Father Hesburgh said was, return 23 the material? 24 A He said to return the material. 160 1 Q And he meant it. He couldn't have meant 2 anything other than the copies, could he, that is 3 all he was talking about? 4 A That's right. 5 Q Did you return the copies? 6 A Yes. 7 Q And did you tell Father Hesburgh that you 8 would return the copies? 9 A No. 10 Q Did you make copies of the copies before you 11 returned the copies? 12 A Yes. 13 Q So, when you returned the Copy 1, you 14 retained Copy Set 1 -- you retained Copy Set 2? 15 A That is correct. 16 Q which was identical in every respect to 17 Copy Set 1? 18 A That's correct. 19 Q And, therefore, when you told Father 20 Hesburgh that you -- you didn't tell him you 21 returned anything? 22 A That's correct. 23 Q Would it be a fair characterization by 24 returning Copy 1 and retaining Copy 2 that by that 161 1 act you disregarded Father Hesburgh's suggestion? 2 A No, sir. 3 Q Why not? 4 A I followed Father Hesburgh's suggestion. 5 Q By returning the copy, but making a copy 6 of the copy before you returned the copy? 7 A All he said was to return the material I had 8 gotten at Rosary College. 9 That is all he said for me to do, and 10 I did that. 11 Q But making a copy. You have it right now 12 today? 13 A My attorney has it. 14 Q And you felt you were complying with what 15 Father Hesburgh said by doing what you have just 16 described you did? 17 A Yes. 18 Q Up to this date did you ever tell anybody 19 that? 20 A Yes. 21 Q Who? 22 A I have told any number of people that. 23 Q Other than your attorneys? 24 A Yes. 162 1 Q Who ? 2 A Ron Parent. 3 Q When did you tell Ron Parent that you had 4 made a copy of the copies before you returned the 5 copies? 6 A On the morning of August 5, 1980. 7 Q What did he say? 8 A He said that it was all right with him. 9 Q Whom else did you tell it to? 10 A Dr. James W. Frick. 11 Q Who is Dr. Frick? 12 A He was the Vice President for Public 13 Relations, Alumni Affairs, and Development at the 14 University. 15 Q When did you tell Dr. Frick this? 16 A On January 8, 1981. 17 Q What did Dr. Frick say? 18 A He said it was all right with him. 19 Q Did you tell both Parent and Frick what 20 Hesburgh had told you to do? 21 A I did. 22 Q Anybody else? 23 A Any number of people knew. It was in the 24 newspapers. 163 1 Q Before the stuff had hit the fan? 2 A Sure. 3 Q And by "stuff hitting the fan," I mean the 4 events of September '81? 5 A Yes. 6 Q Okay. Now, Sir, going back, you mentioned 7 that in your discussion with Father Hesburgh, you had 8 mentioned various things, including Bernardin. 9 Now, isn't it a fact that sometime 10 after you left Rosary College you had a conversation 11 let's see the dates of your visit to Rosary College, 12 Sir, date or dates, what was it? 13 A July 7, July 18 -- excuse me -- July 7, 14 July 8, and July 17, I believe, 1980. 15 Q Now, Sir, you were asked in interrogatory 16 NO. 101, "To identify and describe in detail any and 17 all communications between plaintiff and any member is of the written newspaper or magazine or broadcast, 19 or radio media relating or referring to the Greeley 20 papers." 21 And you said, "Portions of the 22 documents were discussed with Roy Larsen, Chicago 23 Sun-Times on July 16,1980." 24 Now, was he the first person, Roy 164 1 Larsen, that you discussed what you thought you had 2 found in the Greeley-papers that you either copied or 3 removed from the Rosary archives? 4 A I believe I discussed it with Ron Parent. 5 I know I discussed it with Monsignor Egan on the day 6 before I met with Roy Larsen. 7 Q Let's start with Parent. This is a 8 conversation you had with Parent following your visit 9 to the archives on the subject matter what you think 10 you found there, what you believed you found there. 11 What did you tell Mr. Parent? 12 A I told him that I have found information 13 that Father Greeley had been having lots of conversa 14 tions about Cardinal-Cody with various people; that 15 he had planned to rig a Papal election; and that the 16 material made the story more interesting than we had 17 thought it was going to be; and it probably was going 18 to be a cover story. 19 Q And what did Mr. Parent say? 20 A He agreed. 21 Q Any more in that conversation? 22 A That was about it. 23 Q Any discussion about what Father Hesburgh 24 might think of such an article about rigging a Papal 165 1 election and so forth? 2 A No, sir. 3 Q Did you discuss the date of some of this 4 material that you had copied? 5 A I don't believe so. 6 Q Did you discuss with Mr. Parent what 7 particular Papal election you were talking about? 8 A I identified the election as the election 9 of '78, as I recall. 10 Q And this is 1980? 11 A That's correct. 12 Q All right. Anything further with Parent? 13 A No. 14 Q Did he give you his blessing to proceed? 15 A Yes. 16 Q Did you tell him that you had removed 17 physically ten tapes dictated by Father Greeley from 18 the archives and still had them? 19 A Yes. 20 Q What did Mr. Parent say? 21 A He said nothing about it. 22 Q He said nothing? 23 A To my recollection, yes. 24 Q Okay. 166 1 A I told him I had to get them transcribed, 2 or in some way taken care of, transcribed, copied, 3 or something. 4 I told him that we needed to do that 5 within the foreseeable future. So it was a mechanical 6 discussion as such. 7 Q Before you went to the archives on July 7, 8 sir, the Greeley archives, which actually were ten 9 boxes, or whatever it was - 10 A 18. 11 Q You had no contact with Greeley, had you? 12 A Since? 13 Q No, prior to your visit of July 7, since 14 March 27, you had no further communication of any kind 15 whatsoever with Father Greeley? 16 A That's correct. 17 Q And you did not notify him of your find, 18 did you? 19 A No, sir. 20 Q Anything further on Parent? 21 He thought that it was okay? 22 A Yes. 23 Q And is Mr. Parent in your opinion a 24 journalist? 167 1 A Yes, sir. 2 Q Is Mr. Parent a member of the American 3 Society of Professional Journalists, to your knowledge? 4 A Mr. Parent is dead. 5 Q Was he? 6 A No, sir, to my knowledge, no, sir. 7 Q Did Mr. Parent raise with you even the 8 possibility of an ethical question? 9 A No, sir. 10 Q Prior to the time of your discussion of 11 July 1980 with Mr. Parent had you discussed with any 12 lawyer the lawfulness of the conduct you described? 13 A No, sir. 14 Q When did you first discuss --and I don't 15 want to know -- I am not going to go beyond when and 16 who, okay -- I am not going to get into that. 17 MR. LANE: I am sure you will abide by the rules. 18 MR. O'BRIEN: Q When did you first discuss the 19 question of the propriety of your copying and removing 20 material, as you described it, from the Greeley 21 archives with a lawyer? 22 A I discussed with a lawyer on August 3, 1980 23 my rights regarding my use of material and my 24 obtaining material from those files. 168 1 Q In the way you have described? 2 A That's correct. 3 Q And who was the lawyer? 4 A Tom Winters. 5 Q That is your brother? 6 A That's correct. 7 Q Did he do any research before he gave you 8 the opinion that you were okay legally? 9 MR. LANE: If you know. 10 MR. O'BRIEN: Q Do you know if he did any 11 research? Were you out having a beer with him, or 12 having dinner with him, or what? 13 A what is your question? 14 Q Do you know whether he did any legal 15 research before he gave you the answer you say he gave 16 you? 17 A I gave him some material that I had found. 18 Q What kind of material? 19 A Material from a handbook. 20 Q Handbook about what? 21 A Its title is "The Right of Reporters." 22 Q Who wrote it? 23 A Joe Gora. 24 Q And is it a pamphlet, or a book? 169 1 A A book. I believe it is . 2 Q Where did you get the book? 3 A I bought it for a course I had at Notre 4 Dame as an undergraduate. 5 Q So you gave him -- is Joe Gora a scholar of 6 constitutional law, do you know? 7 A I don't know. 8 Q In any event, your brother, after he read 9 the material you gave him, decided you were okay 10 legally, is that correct? 11 MR. LANE: Hold on. I object to any 12 MR. O'BRIEN: I am asking for his opinion. 13 Q You saw no reason to do anything different 14 than you had been doing as a result of the conversa 15 tion with your brother? 16 A That's correct. 17 Q okay. Sir now, the next conversation on 18 the subject of your find at Rosary in the Greeley 19 archives and the removal of same was with Roy Larsen, 20 correct? 21 A No. You have got me confused. 22 MR. LANE: You are jumping all over here. 23 MR. O'BRIEN: Q I am talking July 1980. 24 A You were in August earlier. 170 1 Q Sure. Now we have gone backward in time 2 from the August conversation with Hesburgh and now 3 we are back in July, and you told us that you talked 4 with Parent. I believe you said it was on July 16. 5 A I talked with Monsignor Egan on July 15. 6 Q So you did not list him in the interroga 7 tories. What did you say -- was anybody else present? 8 A No, sir. 9 Q Where did the conversation take place? 10 A Morris Inn. 11 Q This was during a meal? 12 A Breakfast. 13 Q Did you call the breakfast meeting? 14 A I asked to see him and we arranged a break 15 fast meeting. 16 Q How long did that last? 17 A Hour. 18 Q And what did you tell Monsignor Egan? 19 A Well, we discussed my research on Father 20 Greeley since I last discussed it with him. 21 Q What did you say in substance? 22 A I told him how I had been to several of 23 these people's houses and interviewed them and what 24 they had said about him. I told him my impression of 171 1 Father Greeley. 2 Q I would like you, sir, to please try and 3 give us the substance of what you said and don't 4 characterize the topics and heading. I need as much 5 detail as you can remember. 6 A I told him, "I liked him." 7 Q What else did you tell Monsignor Egan? 8 A I told him that I had also gone to the files 9 at Rosary and had gone through them over a three-day 10 period, or actually over a two-day period, and was 11 going to go back, and that I found some startling 12 information. 13 Q Did you describe the startling information? 14 A I had made some copies of the startling 15 information already, and I gave it to him to read. 16 Q What do you recall it was that you gave him? 17 A I believe it was from his transcription of 18 tape recordings he had made in preparation for his book 19 on "The Making of the Pope." 20 Q As you went through that material, the 21 Papal diaries, wasn't that what they were called, 22 something like that? 23 A They were under various names. 24 Q Do you recall they were labeled "top 172 1 secret" on the top cover page? 2 A Yes. 3 Q Did you tell that to Monsignor Egan? 4 A I may have. I don't recall. 5 Q Did Monsignor Egan read any of the material 6 you presented to him, the copies you had made of the 7 materials, did he comment -- did he read and comment 8 on it in your presence? 9 A Yes. 10 Q What did he say? 11 A He said, "The megalomania on those pages." 12 Q So apparently Monsignor Egan did not think 13 that Father Greeley was capable of rigging a Papal 14 election? 15 A He did not -- 16 MR. LANE: I would object to the characteriza- 17 tion of the intent of somebody else other than the 18 deponent here. It calls for the state of mind of 19 somebody other than the witness. 20 MR. O'BRIEN: Q What did Monsignor Egan say? 21 A He said, as I have said, "The megalomania 22 on those pages." 23 Q Did you tell Monsignor Egan on this 24 occasion, sir, that you had not discussed this 173 1 material with Father Greeley? 2 A Yes. 3 Q And what did Monsignor Egan say to that? 4 A I don't know. I guess that was inferred. 5 He knew that I had not. 6 Q Did you discuss the dates of ‘75 and ‘76 on 7 this material with Monsignor Egan? 8 A This particular material was from 1977, 9 and he knew that. 10 Q And was there any discussion of "The 11 Making of the Popes 1978" in connection with your 12 giving Monsignor Egan some of the Greeley material 13 that you had copied? 14 A I showed it to him. 15 Q Showed him what? 16 A The material that you mentioned. 17 Q You just showed it to him; you didn't 18 give -- 19 A I didn't give it to him to take home. 20 Q Was there any discussion on this occasion 21 at Morris Inn with Egan about "The Making of the Popes 22 1978" book by Andrew Greeley? 23 A I believe I identified this material as 24 material he had put together in preparation for that 174 1 book. 2 Q At that point in time, sir, had you read 3 "The Making of the Popes 1978"? 4 A I don't know specifically if I had at that 5 point. 6 Q At any time, sir, did you compare the notes 7 made -- the Roman notes I think is a fair way to 8 characterize them -- labeled as Top Secret, did you 9 compare the content of those notes with any portions 10 of "The Making of the Popes 1978"? 11 A Yes. 12 Q And what was the result of your comparison? 13 A Some of the material from the notes 14 appeared in the book. 15 Q A lot of it did, didn't it? 16 A Yes. 17 Q So is it your testimony, sir, that as far 18 as you can tell, Monsignor Egan took it seriously, 19 even though he believed the megalomania that Andrew 20 Greeley had, or thought he could actually fake a 21 Papal election? 22 A I think he believed as far as I could tell 23 that Father Greeley thought he could rig a Papal 24 election, and he characterized that belief as 175 1 megalomania. 2 Q Therefore not in the real world? 3 A Yep. 4 Q And did you take it seriously, sir, this 5 information was long after the election of the Pope? 6 A I believed that Father Greeley -- that 7 he could rig a Papal election. 8 Q But you did not take that up with your 9 target, Father Greeley, did you, as of the time you 10 had spoken with Monsignor Egan? 11 A He was not my target, sir. 12 Q He was the subject matter of the article? 13 A I will accept that. 14 Q Are you aware, sir, of any particular 15 guide to journalists in the ethics department that 16 before you make an accusation against somebody you 17 give them a chance to refute it? 18 A Before you print one, yes, sir. 19 Q And when -- did you contact Father Greeley 20 to discuss with him your belief that you had 21 documents suggesting to you, at least, that Father 22 Greeley was plotting, or had been plotting to rig 23 the Papal election? 24 A I asked him for another interview when I 176 1 spoke to him on the phone. It was, I believe, 2 August 1, 1980 -- no, it was July 29. 3 Q He wrote you a letter on July 297 4 A That's right. 5 Q Did you call him, or did he call you? 6 A He called me. I called him back. He called 7 me at several places and I called him back. 8 Q I show you a document marked Greeley 9 Deposition Exhibit No. 16, and ask you if that is a 10 copy of a letter you received from Father Greeley on 11 or about the date it bears? 12 A Yep. 13 Q Sir, so we fix the conversation with 14 Greeley as of July 29, correct, or it has to - 15 A It was July 29 and August 1st. 16 Q Well, this letter is dated -- you only had 17 one conversation with him, or did you have several? 18 A One. 19 Q All right. And this letter is dated July 20 29, and refers to a conversation between yourself and 21 Father Greeley as of the morning of that date. 22 A I see, yeah. That would have been the date. 23 I was confused. That would have been the date. 24 Q So he called you and you called him back and 177 1 now would you give us the substance of the conversa- 2 tion on July 29, 1980 between yourself and Father 3 Greeley? 4 A He said -- I believe that he had heard I 5 had been to Rosary and he was appalled by what would 6 come out. He said he wasn't afraid about himself, 7 but he was terrified. He said he was afraid of what 8 would come out about other people. 9 He had not taken money, or had any 10 affairs, but was afraid of what would come out for 11 other people. 12 And I said, "I told you I was going 13 there in Tucson." 14 And he said, "I know that." 15 Q Anything else? 16 A He said he had cooperated with the article 17 up to now. He thought honorably. I said,I acted 18 honorably, too." 19 That is the gist of it. 20 Q Did you tell Father Greeley on occasion 21 after this July 29, 1980 call, sir, that you had 22 removed from the library ten tapes dictated by 23 Andrew Greeley? 24 A No, sir. 178 1 Q Why not? 2 A Didn't occur to me to. 3 Q Didn't occur to you? 4 A No, sir. 5 Q Did you tell him you copied about 200 pages 6 of the Rome Diaries? 7 A No, sir. 8 Q Did you charge him with trying to rig a 9 Papal election? 10 A No, sir. 11 Q Did you tell him you were going to write a 12 story using the material you copied from his 13 archives and the tapes that you had removed from his 14 archives? 15 A No, sir. 16 Q Why not? 17 A Obviously I was going to write a story and 18 obviously I was going to use the material that I had 19 gathered in preparation to write that story. 20 Q Did you tell him that you were aware of 21 the fact that the cover to the material - - the 22 covers to the material on the Roman Diaries were 23 labeled "Top Secret"? 24 A No, sir. 179 1 Q But you knew that then, did you not? 2 A I did. 3 Q Did you tell him you had been into his 4 personal correspondence files? 5 A What do you mean by personal correspondence 6 files? 7 Q Letters from Andrew Greeley to Cardinal 8 somebody or the other, the Papal delegate, letters 9 to Father Hesburgh, for example? 10 A That is his personal files? 11 Q Yes. 12 A No, I didn't tell him that. 13 Q Did you tell him that you had made copies 14 of correspondence marked "personal and confidential"? 15 A No, sir. 16 Q But you had, had you not? 17 A I had. 18 Q Now, sir, I note that in his letter to you 19 of July 29 he says, "Any copies you may have made 20 from these files ought to be returned to me." 21 Did that subject come up in the 22 telephone conversation with Greeley; the subject 23 matter of copies you may have made from Greeley's 24 files? 180
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Posted 23 August 1998