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Q. Have you ever looked at those?

A. I have never gone through those files as a, as a whole.

Q. Have you asked people to go through those files?

A. I have asked that the files -- yes, that the personnel files be checked of all persons against whom allegations have been made.

Q. And when did you first do that?

A. I did that subsequent to the policy that, the written policy for the handling of these cases, which would have been 1993, sometime past.

Q. Sometime in 1993?

A. Yes. It was January of '93 that the, that the policy was committed to writing and elaborated, and then after that it seemed to me that we needed to go back and check all files of persons against whom allegations had been made and test them against the policy.

Q. Did you find out that the priest that this letter was referring to in 1984 was referring to Father John J. Geoghan?

A. Well, as I said, I can't recall seeing the letter in 1984, but -- so I can't answer that.

Q. When you came here in 1984, who had ultimate authority on assigning priests to parishes?

A. When I came, the authority in the interim after Cardinal Medeiros's death, was Bishop Daily.

Q. And when you became Archbishop?

A. Then I would have the authority to assign.

Q. So -- and since then, you have had that authority?

A. I have the authority.

Q. Okay. So that ultimately you've always had the authority for the assignment of every priest in the Archdiocese?

A. That's correct.

MR TODD: Since the installation?

Q. Since the installation; is that correct?

A. That's correct.

Q. And you don't recall now a discussion with Bishop Daily as to what was being done with regard to the assignment of this particular priest that you had received a written complaint that he had molested boys?

A. If you'd rephrase the question, because I find, you know...

MR TODD: Just rephrase the question.

MR. GORDON: Okay. I can rephrase it.

Q. As I understand it, you do not recall a conversation with Bishop Daily regarding the priest at St. Brendan's in Dorchester that this written letter was sent to you about concerning the molestation of boys?

MR. ROGERS: Objection.

THE WITNESS: Excuse me?

MR. ROGERS: Just objection to form. Go ahead.

A. I do not recall seeing this letter as I sit here before you and try to reconstruct what I knew and didn't know in 1984. I do not recall seeing this letter at that time.

Q. What was the practice for reviewing letters that came to your residence in 1984?

A. Well, obviously it's a practice that evolved, and I can't put a, I can't put a firm date on when this policy took place or didn't take place. But the custom is that the mail is reviewed, is opened, and is sorted by my administrative assistant and ideally assisted by a priest secretary. That sometimes is not possible because of other duties, and the mail has to go through. And the mail is sorted and is directed toward persons bearing responsibility for assisting me in that particular area. So, for example, if it is a matter that is dealing with education, it would go to the person, my secretary for education. If it's a matter specifically for schools, it would go to the superintendent of schools. They would be asked to look at this correspondence and to either prepare a response for me or to handle this matter themselves, if that were appropriate.

Q. In 1984, was it the practice that either your administrative assistant or priest secretary would ask you to handwrite a note to Bishop Daily without having you read what it was concerning?

A. No, are you referencing --

Q. The last page.

A. -- the envelope here? I must say -- no. No one would tell me to put that note on. That kind of a note is a note that I would put on. And I would put on, having absorbed the content of whatever the backup, backup letter is. So the only thing I can say that is my signature, I wrote that. I would be lying to you if I say I recall having seen that letter before, but I can't sit here before you and say that I saw it when I don't think I did, when I don't remember seeing it.

Q. Would it be fair to say that when you wrote notes to Bishop Daily, you didn't usually write urgent?

A. That means what it means, you know. That means that I considered this an urgent matter, and that I wanted it followed through, and I expected him to follow through for me, follow through meaning doing whatever it takes to deal with this thing expeditiously and correctly.

Q. So it would be fair to say that you don't have a specific memory of Marge Gallant's letter, but the record seems to indicate you took it seriously at the time and asked the person you had given responsibility to --

A. That's correct.

Q. -- to address it in a serious manner?

A. That's correct.

Q. And address it quickly?

A. That's correct.

Q. Did Bishop Daily tell you at some point that Father Geoghan was being relieved of his duties at St. Brendan's in Dorchester?

A. I do not recall his having done that, but....

Q. It would it have been consistent with what was your practice at the time?

A. It would have been consistent, yes.

Q. Did -- I'm going to show you what was marked as Exhibit 8 at Bishop Daily's deposition on September 13.

MR. GORDON: I'm going to give him the original.

MR TODD: Bill, do we have the marked copy?

MR. GORDON: I have the original.

MR. ROGERS: Okay.

MR TODD: Do you have the original?

MR. GORDON: Yes, yes.

MR. GORDON: I don't have the original on 225, I don't think. I think I have the copy. That was the letter, Mrs. Gallant's letter.

MR TODD: Was it marked?

MR. GORDON: I think it was marked, yes.

MR TODD: Only two exhibits and we've already lost one.

MR. ROGERS: Are you putting an original of this in front of the Cardinal?

MR. GORDON: Yes, I'm going to give you that.

MR. ROGERS: You need that for counsel.

MR. GORDON: We're going to have to retrieve the marked Exhibit 225 at the break.

MR TODD: Or remark one if you want. Here it is. Okay. Thank you.

MR. GORDON: Thank you, Mr. Todd.

Q. Cardinal, this is the original Exhibit 8 from Bishop Daily's deposition.

(Document exhibited to witness.)

A. Thank you.

MR. ROGERS: Are you asking the Cardinal to read this?

MR. GORDON: I'd like him to.

MR. ROGERS: Mr. Gordon, you want the Cardinal to read just the first page?

MR. GORDON: Just the first page. Bishop Daily represented the first page was a reasonably accurate transcription of his notes that follow.

Q. Cardinal, have you read Exhibit 8?

A. No, this is the first time I've ever seen this.

Q. Okay. Did Bishop Daily ever convey to you what Father Geoghan told him in 1980?

A. No, not that I can recall.

Q. So as of 1984, your memory of September of 1984, you were unaware that Father Geoghan had admitted to Bishop Daily to molesting boys?

A. I do not recall having been informed of this by Father, by Bishop Daily, no.

MR. GORDON: I believe we wanted to take a break to see if we could meet with the judge at 10:30. I have more questions, but why don't we stop now, take a quick break and see if we can meet with the judge?

THE WITNESS: Good.

VIDEO OPERATOR: The time is 10:25, we'll stop the video and go off the record.

(Video off.)

(Brief recess.)

(Video on.)

VIDEO OPERATOR: The time is 10:58. We're back on the record.

MR. GORDON: Could I have the exhibits, please?

(Document exhibited to counsel.)

MR. GORDON: Where is 225 ?

MR TODD: Coming down. Mr. Murphy had it.

MR. MURPHY: That's 224.

MR. GORDON: Where's 225. That was the letter from Mrs. Gallant. It was there a little while ago. Mr. Todd, you had --

MR TODD: Yes, it was in the middle.

MR. ROGERS: That's my copy of it.

MR TODD: They were here when we left.

MR. GORDON: Tom, did you take it?

MR. MURPHY: I did not.

THE WITNESS: Could that be it?

MR TODD: Can we operate with a copy for the time being?

MR. GORDON: All right. From now on, I will hold on to the exhibits. If anybody wants to have them, please ask me. Obviously people are not returning them.

MR TODD: Sorry, here we are Bill, took it right from the middle (Document exhibited to counsel.)

MR. GORDON: All right.

Q. Cardinal, I'm again going to show you Exhibit 8, and I'm again going to show you Exhibit 225. (Document exhibited to witness.)

Q. And my question now is: Did you -- let me ask you this: When letters came into the Cardinal's residence, did you create a log of each letter that came in, or did you have a log created?

MR TODD: Object to the form. It's --

MR. GORDON: Okay.

MR TODD: Personally or --

MR. GORDON: That's fine. But let me also put on the record, we agreed to waive objections, not waive, but to reserve them until the time of trial.

MR TODD: Not form.

MR. GORDON: Okay. All right. Fine.

A. The filing system has evolved, and again, I can't tell you at what point a particular system went into play. The system currently in play, and it's been in play for some time, is that as mail comes in, it is logged in with regard to its substance in the computer so we have a record as to what has come in. I instituted a chron. file on outgoing mail as soon as I came in because I had found in previous work experience that that's always, it's a manual thing, more difficult, but at least it's, you're sure that you have that. But that's on outgoing mail.

Q. Does that -- when you say chron. file, you mean a chronological file?

A. That's right. That each day correspondence that has gone out of the house is, a copy of it is filed so that you, so that you, so that you have a chron. file.

Q. And does the chron. file indicate to whom the letter is sent?

A. It's a copy of the letter.

Q. Oh, it is a copy of the letter?

A. Yeah, it's a copy of the letter that's gone out. It's a hard copy of the letter that's gone out. It's a primitive form of filing.

Q. Sure.

A. But...

Q. There's no handwritten notation of a letter to whom on a particular date?

A. No, no. No.

Q. What happens is just a copy of the letter is filed --

A. That's correct.

Q. -- in your files?

A. And as I say, the incoming mail is filed now, and I can't tell you when that began. It may very well be, and I would presume that when I first got there, the filing system was a more routine filing system where you would keep a file of the incoming letter.

Q. Now, Bishop Daily at some point in 1984 was given another assignment, wasn't he?

A. Yes.

Q. And where was that assignment to?

A. Palm Beach.

Q. Do you remember approximately when that assignment was given?

A. I think he left sometime in September of '84.

Q. So just about the time that you would have sent him the letter from Mrs. Gallant which was also in September of '84; is that correct?

A. I believe so.