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Deposition of Cardinal Bernard Law
May 8, 2002, Suffolk County Superior Court

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Q. And is that -- why don't you if you could briefly describe why it's called an archdiocese?

A. An archdiocese would be, if you will, a major diocese historically. For New England the first diocese was the diocese of Boston, and when it was established around 1908, it comprised all of New England. Very, very few priests and very, very few Catholics, a vast, vast territory. And then, in time, it became subdivided so that now there are four dioceses in the State of Massachusetts, one archdiocese, three dioceses, and a diocese each in Vermont, New Hampshire, and Maine. And those dioceses together constitute what's called the Province of Boston. And the rest of New England comes around what was established as the archdiocese of Hartford, and there are several other dioceses in Connecticut and the dioceses of Rhode Island. So it's longevity, if you will, and the importance of the city.

Q. There are provincial meetings of the Bishops of the Province of Boston, isn't there?

A. That's correct.

Q. Are those meetings once a year or twice a year?

A. Twice a year here in the province.

Q. Does the provincial meetings, do they have any jurisdiction over individual dioceses?

A. No, no. Nor does the metropolitan Archbishop.

Q. So are these primarily collegial meetings?

A. They're collegial meetings, that's correct. That would be a good way to describe them.

Q. But there can be no legislation that would affect individual dioceses?

A. No. No. We could decide corporately on a course of action. Rather, we could decide individually on a course of action that we, together, consider.

Q. Now, when you came to Boston in, I believe you said, sometime in March, 1984, in the 20s, you're not sure of which day, when you came, prior to that time, had you ever heard of Father John J. Geoghan?

A. No.

Q. Do you remember when you first met Father Geoghan?

A. No, I do not.

Q. Do you remember when you first heard of Father Geoghan?

A. I do not.

MR. GORDON: Do we have the exhibits?

(Document exhibited to counsel.)

MR. GORDON: Can we have this marked as Exhibit 225?

(Document marked as Exhibit 225 for identification.)

(Document exhibited to witness.)

MR TODD: Do you want to keep that in the middle of the table?

MR. GORDON: Yes.

Q. Cardinal Law, you've been --

A. Yes.

Q. -- given what's marked as Exhibit 225 which appears to consist of two letters, the first of which is a typed letter on the Chancery stationery, apparently dated September 21, 1984 addressed to a Mrs. Marge Gallant, and which has typed as signature Archbishop of Boston and what appears to be, we'll ask if it appears to be your signature. The second of which appears to be a handwritten letter beginning with the salutation Dear Excellency dated September 6, 1984, the second page of which has what appears to be the handwritten signature of Marge Gallant, some handwriting on that last page, and the last page of which appears to be an envelope addressed to you as Archbishop on 2101 Comm. Ave., Brighton, Mass.

Have you seen what's been marked as Exhibit 225 before, any of the documents?

MR. ROGERS: Read it all.

A. Just let me see.

MR TODD: Again, this is seen at any time?

MR. GORDON: Yes.

A. I'm -- first of all, this is my signature (Indicating.)

Q. Okay. On the first page, that is your signature?

A. Yeah. Yeah, that is my signature. I do not recall having received this letter. I do not recall having received the letter. I find the --

MR TODD: The question is actually whether you've ever seen it up to date.

THE WITNESS: Oh, yes, I've seen it before today.

Q. Okay.

A. But I don't recall receiving the letter.

Q. Okay. Do you remember when you first saw this letter?

MR TODD: This letter?

MR. GORDON: Being the letter addressed to the Cardinal beginning with the salutation "Dear Excellency" and the second page of which appears to be a signature of Marge Gallant. The handwritten letter.

A. I saw the letter from, I'm trying to get refreshed on this issue, but I do not recall having received the letter.

Q. Okay.

A. But....

Q. On the last page it looks to be a copy of an envelope, there's some handwriting there. Do you know whose handwriting that is?

A. Yeah. That would be my handwriting. That would be my initial. I --

Q. Okay. And what does that handwriting say?

A. It says, it's addressed to Bishop Daily and it says urgent, please follow through.

Q. And those are your initials right after it?

A. That's correct.

Q. And Bishop Daily had what position in the Archdiocese?

A. Bishop Daily, at that time, he was vicar general and he was chancellor, he was in effect chief operating officer, to use a term that doesn't really apply, but analogously I think it would explain what his role was.

Q. Was he in effect the No. 2 person?

A. That's correct, yeah. The person upon whom I would rely to assist me in the administration of the archdiocese.

Q. You did not get in your first year here a large number of letters informing you that a priest in the archdiocese had been molesting boys; is that correct?

MR TODD: Objection to the form.

A. That's correct, I did not receive a great number of letters.

Q. So a letter like this from Mrs. Gallant would have been more of the exception?

A. It would have been.

Q. Do you recall talking to anybody about this letter about the time it came in?

A. I do not recall.

Q. Do you recall if you were troubled by the information in this letter?

A. I do not recall having seen the letter at the time.

Q. Do you recall writing the note which is on the last page of Exhibit 225 on the envelope?

A. I do not recall writing that note.

Q. But that is your handwriting?

A. But I have no doubt but that that's my writing and signature.

Q. On the --

A. And it would be the normal way in which I would handle cases.

Q. There's a typed letter in the beginning. Did you prepare that letter or did you have somebody on your behalf prepare that letter?

A. Ordinarily letters of this kind would be prepared for me, and they would be prepared by the person who was handling the matter for me.

Q. So you would think that Bishop Daily prepared the September 21 letter?

A. I would think either Bishop Daily would have prepared it, and in given the note at the top, I would presume that that's the way it was. The letter could have been done by the personnel office with, under the instruction of Bishop Daily, but in this instance it would appear that it originated with Bishop Daily and then the copies went.

Q. So, in September of 1984 did you have secretaries?

A. I did.

Q. Who were your secretaries then?

A. Father William Helmick was my secretary. I only had one secretary, a priest secretary.

Q. Okay.

A. And then Mrs. Kay Woodward was my secretary, administrative assistant.

Q. Is Mrs. Woodward still --

A. She is.

Q. She's still working for you?

A. She does.

Q. And do you know where Mrs. Woodward lives?

A. She lives in --

MR TODD: No, no. We'll supply that information.

MR. GORDON: No, no.

A. I don't know her address.

Q. No, the city or town she lives in.

A. She lives in Walpole.

Q. Do you know the name of the street?

A. No.

Q. Do you know who her husband is?

A. Yes.

Q. What --

A. Frank Woodward.

Q. Does she have any children?

A. She, she does. She has two living, and she has one deceased.

Q. Are any of the children living with her?

A. I can't answer that, I'm not sure of that.

Q. Okay. All right.

A. Well, not living with her, no. They're adult.

Q. Have you ever been to her house?

A. No.

Q. Did Father Helmick, as your priest secretary, ever draft letters for you in response to letters you had received?

A. Yes.

Q. Do you know if it's -- how -- strike that. How would you know that the first letter in Exhibit 225 addressed to Mrs. Gallant would not have been drafted by Father Helmick?

MR TODD: Objection to the form.

MR. ROGERS: Go ahead.

THE WITNESS: Do I go ahead and answer?

MR. ROGERS: Yes.

THE WITNESS: I have to get this down.

A. Well, first of all, I wouldn't have an absolute -- I can't give you absolute recall on this, but given the substance of the letter, it would not be the kind of a letter that ordinarily my secretary, priest secretary would handle. It would be, the nature of the letter would be such that it would need to go someone who would be responsible for following through, checking out, and that -- in a matter of that kind.

Q. And the matter of that kind, are you referring to the fact that in Mrs. Gallant's letter in the second paragraph she, I believe, there's a reference here, a priest at St. Brendan's in Dorchester who has been known in the past to molest boys; that the matter you mean?

A. Certainly anything that would come to me that was of substance, and a letter of this kind would certainly be a letter of substance, would go to the person who would be responsible for assisting me in this type of matter. And the -- I don't know whether it's -- the way in which I operated --

MR TODD: Why don't you wait for a question?

THE WITNESS: Excuse me, I'll wait for the question.

Q. Let me have a clear understanding. You believe that because of the subject matter here, it probably was drafted by Bishop Daily; is that correct?

A. That's correct.

Q. Okay. As we sit here today, you don't know that Bishop Daily in fact drafted this letter?

A. That's correct.

Q. Okay. And do you know today as a fact that Father Helmick did not?

A. My presumption would be that he would not have drafted this. It would have been out of the ordinary for him to have drafted that letter.

Q. Okay. Where is Father Helmick now?

A. His assignment now?

Q. Yes.

A. He's pastor of St. Theresa of Avila Church in West Roxbury.

Q. Is he -- does he -- was he ever given the title of Monsignor?

A. He was.

Q. So it's Monsignor Helmick?

A. That's correct.

Q. Did you have a conversation with Bishop Daily about Mrs. Gallant?

A. I don't recall having a conversation with Bishop Daily on this matter.

MR TODD: Do you mean to say whether you had one or can't recall?

THE WITNESS: Yeah, I can't recall having had the conversation, having had a conversation with Bishop Daily.

Q. While Bishop Daily was working with you, while you were in Boston, when you had reports that came in such as this, did you have conversations, when you could, with Bishop Daily about these issues?

A. Well, let me say that I don't -- to say when we received reports while Bishop Daily was with me like this, I'm not certain that there were reports like this, that there was -- but anything, anything of substance ordinarily we would have a, we would have a discussion, particularly when it came down to a decision as to what was to be done. I would get his recommendation on what the action should be.

Q. And let me ask you, when you came to Boston, was there something called either locked or secret files?

A. There were confidential files, I presume in the Chancery, but I did not go to those, I did not keep those.

Q. On the first page of Exhibit 225 on the letter under -- is there some language that indicates copy to Father Oates and Father MCC, personal, confidential, do you see that?

A. Yes, I do.

Q. Under that does it say "For the locked file"?

A. I see that.

Q. And do you know what it's referring to when it says the "locked file"?

A. My presumption is that it would be confidential files.

Q. And would those have been confidential files of priests?

A. They would certainly have included that confidential personnel files.

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