ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 1 1 IN THE CIRCUIT COURT, CITY OF ST. LOUIS TWENTY-SECOND JUDICIAL CIRCUIT 2 3 STATE OF MISSOURI DOE 1, ) ) 4 Plaintiff, ) ) 5 vs. ) ) 6 7 Archdiocese of St. Paul and ) Minneapolis, Diocese of ) Winona and Thomas Adamson, ) ) 8 Defendants. ) 9 10 11 VIDEOTAPED DEPOSITION OF ARCHBISHOP ROBERT CARLSON 12 Taken on behalf of Plaintiff 13 May 23, 2014 14 (Starting time of the deposition: 15 10:11 a.m.) **CONFIDENTIAL** 16 17 18 19 20 21 22 23 24 25 www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 I N D E X O F E X A M I N A T I O N Page Questions by Mr. Anderson ........................ 8 Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit Exhibit I No. No. No. No. No. No. No. No. No. No. No. No. No. No. No. No. No. No. No. No. No. No. No. No. N D E X O F E X H I B I T S 296 (Letter) ......................... 297 (Meeting Minutes) ................ 239 (Deposition Transcript) .......... 299 (Letter of Assignment) ........... 301 (Memo) ........................... 302 (Memo) ........................... 303 (Memo) ........................... 319 (Letter) ......................... 304 (Memo) ........................... 101 (Newspaper Article) .............. 305 (Memo) ........................... 275 (Memo) ........................... 276 (Letter) ......................... 282 (Memo) ........................... 245 (Memo) ........................... 250 (Memo) ........................... 246 (Letter) ......................... 247 (Memo) ........................... 33 (Memo) ............................ 251 (Letter) ......................... 252 (Memo) ........................... 293 (Memo) ........................... 133 ( Memo) .......................... 260 (Memo) ........................... 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 19 20 21 (The original exhibits were retained by the court reporter, to be attached to Mr. Anderson's transcript.) 22 23 24 25 www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 3 1 IN THE CIRCUIT COURT, CITY OF ST. LOUIS TWENTY-SECOND JUDICIAL CIRCUIT 2 3 STATE OF MISSOURI DOE 1, ) ) 4 Plaintiff, ) ) 5 vs. ) ) 6 7 Archdiocese of St. Paul and ) Minneapolis, Diocese of ) Winona and Thomas Adamson, ) ) 8 Defendants. ) 9 10 VIDEOTAPED DEPOSITION OF WITNESS, ARCHBISHOP 11 ROBERT CARLSON, produced, sworn, and examined on the 12 23rd day of May, 2014, between the hours of nine 13 o'clock in the forenoon and six o'clock in the evening 14 of that day, at the offices of Chackes Carlson, LLP, 15 906 Olive Street, Suite 200, St. Louis, Missouri 16 63101, before BRENDA ORSBORN, a Certified Court 17 Reporter within and for the State of Missouri, in a 18 certain cause now pending before the Circuit Court of 19 the City of St. Louis, Missouri, Twenty-Second 20 Judicial Circuit, State of Missouri, wherein Doe 1 is 21 the Plaintiff and Archdiocese of St. Paul and 22 Minneapolis, Diocese of Winona and Thomas Adamson are 23 the Defendants. 24 25 www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 4 1 A P P E A R A N C E S 2 For the Plaintiff: 3 Mr. Jeff Anderson Ms. Trusha Patel 4 Jeff Anderson & Associates P.A. 366 Jackson Street, Suite 100 5 St. Paul, Minnesota 55101 (651) 227-9990 6 Jeff@AndersonAdvocates.com Trusha@AndersonAdvocates.com 7 8 For the Defendant Archdiocese of St. Paul and Minneapolis: 9 10 Mr. Thomas B. Wieser Meier, Kennedy & Quinn Bremer Tower, Suite 2200 11 445 Minnesota Street St. Paul, Minnesota 55101 12 twieser@mkqlaw.com 13 14 For the Defendant Archdiocese of Winona: 15 Mr. Thomas R. Braun Restovich Braun 16 117 E. Center Street Rochester, Minnesota 55904 17 (507) 2289-4840 thomas@restovichlaw.com 18 19 Also Present: 20 Mr. Tom Buckley Mr. Scott Browning 21 Mr. Patrick Wall Ms. Christa Robertson 22 23 24 25 www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 5 1 APPEARANCES CONTINUED: 2 The Court Reporter: 3 Ms. Brenda Orsborn, RPR/CSR/CCR Missouri CCR No. 914 4 Illinois CSR No. 084-003460 Midwest Litigation Services 5 711 North Eleventh Street St. Louis, Missouri 6 63101 (314) 644-2191 7 8 The Videographer: 9 MR. David Doell Midwest Litigation Services 10 711 North Eleventh Street St. Louis, Missouri 11 63101 (314) 644-2191 12 13 14 15 16 17 18 19 20 21 22 23 24 25 www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 6 1 IT IS HEREBY STIPULATED AND AGREED, by and 2 between counsel for Plaintiff and counsel for 3 Defendants, that the VIDEOTAPED DEPOSITION OF 4 ARCHBISHOP ROBERT CARLSON may be taken in shorthand by 5 Brenda Orsborn, a Certified Court Reporter, and 6 afterwards transcribed into typewriting; and the 7 signature of the witness is expressly not waived. 8 * * * * * 9 [Exhibit Nos. 33, 101, 133, 239, 245, 246, 10 247, 250, 251, 252, 260, 275, 276, 282, 293, 296, 297, 11 299, 301, 302, 303, 304, 305, 319 were marked prior to 12 the deposition.] 13 VIDEOGRAPHER: We are now on the record. 14 Today's date is May the 23rd, 2014. 15 approximately 10:11 a.m. 16 deposition of Archbishop Robert Carlson in the matter 17 of Doe 1 versus Archdiocese of St. Paul, et al., in 18 the Circuit Court of the City of St. Louis. 19 deposition is being held at the law offices of Chackes 20 Carlson. 21 name is David Doell, and I'm a legal videographer, and 22 we are here with Midwest Litigation Services. 23 Will the attorneys present please introduce yourselves 24 and the parties you represent? 25 The time is This is the videotaped This The reporter's name is Brenda Orsborn. MR. ANDERSON: www.midwestlitigation.com My For Doe 1, Jeff Anderson. MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 7 1 Also appearing with me is Trusha Patel, and observing 2 is Patrick Wall. 3 MR. GOLDBERG: Good morning. My name is 4 Charles Goldberg, and I'm appearing here today 5 strictly for the witness, Archbishop Carlson, whose 6 deposition has been noticed in the Doe 1 case. 7 should also note that we have agreed to -- at Mr. 8 Anderson's request, we have agreed to have Archbishop 9 Carlson present for not only this deposition, but for I 10 a related -- for a different case in St. Louis. 11 have agreed informally on breaking up the time so that 12 each of depositions are fully completed today. 13 the Archbishop, as you know, has to leave by 5:00 p.m. 14 We And I should also note for the record that 15 Mr. Anderson has deposed Archbishop Carlson before in 16 different cases, and the Archbishop has testified in 17 1985 in a case, the Riedle case and in another case on 18 three other occasions that his depositions were taken 19 and then, of course, at trial in 1990. 20 we don't have to go over that ground again, but we're 21 prepared to take it a question at a time. 22 23 24 25 MR. WIESER: So hopefully Thank you. Tom Wieser representing the Archdiocese of St. Paul/Minneapolis. MR. BRAUN: Thomas Braun on behalf of the Archdiocese of Winona. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 8 1 2 MS. ROBERTSON: And Christa Robertson on behalf of the Archdiocese of St. Paul/Minneapolis. 3 MR. ANDERSON: Also present is? 4 MR. BROWNING: Scott Browning. 5 MR. BUCKLEY: 6 VIDEOGRAPHER: 7 10 If the reporter would please swear in the witness, you may proceed. 8 9 Tom Buckley. ARCHBISHOP ROBERT CARLSON, of lawful age, being produced, sworn and examined on behalf of the Plaintiff, deposes and says: 11 12 13 14 EXAMINATION QUESTIONS BY MR. ANDERSON: Q. Archbishop, good morning. Would you please state your full name for the record? 15 A. My full name is Robert James Carlson. 16 Q. You have been through this process before. 17 You understand that you are under oath? 18 A. I do. 19 Q. And the answers you give today are being 20 recorded both by transcription and by a videotape? 21 A. I do. 22 Q. By my review of the records, it appears you 23 have now been a priest for 44 years? 24 A. That's correct. 25 Q. And ordained in 1970 by then Archbishop www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 9 1 Binz? 2 A. Correct. 3 Q. It also appears that when you look at your 4 years as an Auxiliary Bishop, as Bishop in two 5 different dioceses and now as Archdiocese of St. Paul 6 -- of St. Louis, it appears that you have been in some 7 capacity as an Auxiliary Bishop or Archbishop for 30 8 years. Does that sound right? 9 A. That's correct. 10 Q. In preparation for today, have you reviewed 11 any materials, documents or depositions or testimony 12 either given by you or others? 13 A. I have not. 14 Q. Archbishop, you have been installed as the 15 Archbishop here in St. Louis since what date? 16 A. June of 2009. 17 Q. I'd like to go back to the period of time 18 when you were in the Archdiocese of St. Paul/ 19 Minneapolis and you were appointed by then the 20 Archbishop Roach to be on the Personnel Board of the 21 Archdiocese. 22 that board? Do you recall what years you were on 23 A. I do not. 24 Q. The records seem to reflect that you were on 25 that board in 1973 and at least through 1977. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Do you Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 10 1 have any reason to dispute that? 2 A. I don't remember, but I really can't say. 3 Q. You were assigned in various capacities in 4 the Archdiocese of St. Paul/Minneapolis as an 5 Associate Pastor, as Vice Chancellor, Chancellor, 6 Auxiliary Bishop and in other official capacities by 7 the then Archbishop Roach, correct? 8 9 10 A. Correct. I had a number of responsibilities. Q. Okay. When, as a priest of the Archdiocese 11 of St. Paul/Minneapolis, did you first receive any 12 information from any source that a priest had been 13 accused or suspected of having abused a child? 14 15 16 A. I -- it would have been more than 30 years ago, and I really can't remember with any accuracy. Q. Do you have any estimates of the time that 17 you were in the Archdiocese of St. Paul/Minneapolis 18 how many different reports concerning different 19 clerics suspected of having abused were made to you? 20 A. I don't remember. 21 Q. When is the first time a priest by the name 22 23 of Tom Adamson came onto your radar? A. I don't remember with any accuracy when that 24 would have been. 25 indicate that. www.midwestlitigation.com There may be a document that would MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 11 1 Q. What do you remember about how he came onto 2 your radar while you were in the Archdiocese of St. 3 Paul/Minneapolis? 4 5 6 7 8 9 10 A. People can come in many different ways. I don't remember what the first contact was. Q. You did realize at that time that he was a priest that had come from the Diocese of Winona? A. As I remember, no information came to me about him that I could say with any accuracy. Q. In the mid-1970s, it is correct to say that 11 the arch -- the Personnel Board was constituted by the 12 then Archbishop to help the Archbishop make 13 assignments and advise the Archbishop of making 14 assignments of priests, among other things? 15 16 17 18 19 A. The Personnel Board never made assignments. It was only recommendations to the Archbishop. Q. Ultimately, it was the Archbishop's decision as to who to assign and when and where? A. As the chief pastor of the diocese, the 20 Archbishop would always have the responsibility who to 21 assign when and where. 22 23 Q. And the Personnel Board was simply advisory, could make recommendations, in other words, correct? 24 A. Correct. 25 Q. And at some point in time, is it correct www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 12 1 also to say that you became the person the Archbishop 2 looked to for handling and investigating reports of 3 sexual abuse by priests in the Archdiocese? 4 A. I was not the only one. 5 Q. And who else was charged with that? 6 A. In some cases, the Personnel Director could 7 have been charged. 8 Vice Chancellor, whoever. 9 Q. I was one of them. Other cases, the Vicar General, Your role was then to be among -- and 10 perhaps in conjunction with others, first is to get 11 the reports and to investigate them and advise the 12 Archbishop about what could or should be done? 13 MR. GOLDBERG: 14 form of the question. 15 to the word "then." 16 Q. I'm going to object to the You need to put a time frame as (By Mr. Anderson) When you were first 17 assigned to be the investigator for the Archdiocese 18 and the Archbishop in connection with reports made of 19 sexual abuse. 20 21 22 23 24 25 A. I was never formally appointed to be an investigator. Q. But when you took on that role or were asked to take on that role, when was that? A. I'm confused, because you're mentioning several different dates. www.midwestlitigation.com You mentioned 1973. MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 What Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 13 1 date are you talking about? 2 Q. Well, I guess I want to know when you took 3 on the role of having to investigate these matters of 4 sexual abuse or complaints of sexual abuse by priests? 5 A. If I had taken on that responsibility, there 6 would be a document, which I would be glad to look at, 7 but I don't remember with any accuracy any particular 8 date. 9 Q. You did investigate complaints, correct? 10 A. There were times when I investigated 11 complaints, as did others. 12 Q. And how many did you investigate? 13 A. I have no memory of how many. 14 Q. What priest did you investigate? 15 A. The one that comes to mind is Thomas 16 Adamson. 17 Q. Any others? 18 A. Not that I remember. I may have, but there 19 would be a document, because I took notes on 20 everything. 21 22 Q. And what did you do pertaining to Thomas Adamson? 23 A. I don't remember exactly what I did, but, 24 again, there would be a document that would spell that 25 out. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 14 1 Q. Tell me what you do remember having done. 2 A. It was 30 years ago, and I don't remember 3 4 with any accuracy. Q. Could you tell us today, remember anything 5 that you did pertaining to a report or complaint or 6 investigation concerning Adamson or any action taken 7 by you? 8 A. 9 10 Again, there would be a document that could refresh my memory. Q. Well, I want to know what you remember about 11 what you did. 12 tell me what you do remember. 13 A. So my question for you at the moment is You're asking me to tell you under oath what 14 I did 32 or 30 years ago, and it would be impossible 15 for me to do that with any accuracy, especially when 16 you have documents that would spell that out. 17 Q. Well, there are matters that aren't 18 documented, so my question is first tell me what you 19 remember. 20 A. Do you remember reporting to the police? I have very little memory, but anything I 21 did would be in the documents you possess and for 22 which I have taken depositions on three or four 23 occasions. 24 25 Q. Did you ever, while in the Archdiocese of St. Paul/Minneapolis ever report any cleric accused of www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 15 1 2 sexual abuse to law enforcement? A. On several occasions, again, as you would 3 see in the documents, I encouraged the people, if they 4 wanted to, to report it to the police. 5 Q. Who did you encourage? 6 A. I could tell you with some accuracy if you 7 show me the documents, but at least in one case it was 8 the parents of a young man whose name I can't remember 9 who came to see me. 10 Q. Did you ever personally make such a report? 11 A. I did not personally make such a report. 12 Q. Did you ever personally order any of the 13 14 officials of the Archdiocese to make such a report? A. Again, it would be in the documents that 15 would show exactly what I did. 16 course, I made many suggestions. 17 Q. Over the years, of I don't remember. You were assigned so be the Bishop of -- 18 appointed to be the Bishop of Sioux Falls in 1984, 19 correct? 20 A. 1994. 21 Q. Excuse me, 1994. And you worked 22 continuously in the Archdiocese of 23 St. Paul/Minneapolis except in the time you were in 24 Rome studying canon law? 25 A. I studied canon law at Catholic University www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 16 1 of America. 2 Q. Excuse me. 3 A. Correct. 4 Q. Okay. In Washington, D.C.? You mentioned that you did encourage 5 some people or persons to report to law enforcement. 6 What do you remember about the person or persons you 7 encouraged to report abuse by priests to law 8 enforcement? 9 A. The one incident that I remember, and, 10 again, there's a document in the file, where parents 11 who came concerned about their child. 12 Q. And what was your title and/or role then? 13 A. I would have to have my memory refreshed as 14 15 to what year you're speaking about. Q. And tell me what you remember having been 16 told by the parents that caused you to advise them to 17 go to police? 18 A. I don't remember exactly what they said, but 19 I know there's a document that would refresh my 20 memory. 21 Q. Was it a mom and a dad? 22 A. I don't remember. 23 Q. Do you have any memory of -- what else do 24 you remember about that event, other than the fact you 25 advised them to go to law enforcement? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 17 1 A. I remember that there were a parent, two 2 parents -- I don't remember -- who, as I call to mind 3 today, I suggested that they would call the police. 4 Again, I think there's a document that would show 5 that. 6 Q. Any other instance, while a priest from 1970 7 to 1994 of the Archdiocese, where you received 8 information that caused you to advise somebody to go 9 to the police? 10 A. If someone was advised by me, there would be 11 a document which would say so, or the people would 12 tell you. 13 14 15 16 17 Q. That you recall, Archbishop, that you recall having told somebody, "Report this to the police." A. Again, it was 30 years, and I don't remember with any accuracy. Q. Do you remember the parents that did make 18 the report to you, that you did advise who the priest 19 was that was the subject of the complaint? 20 A. It would say so in the document, which I'd 21 have to review, but going back 30 years, I would want 22 to look at it so I'm not making a mistake about 23 anything. 24 25 Q. Well, what do you remember about who the priest was? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 18 1 A. Well, I talk to many people, so I'll make an 2 assumption, but I couldn't do it with any accuracy 3 unless I saw the documents. 4 Q. Well, Archbishop, I mean, it is fair to say 5 that a priest abusing a child and that information 6 coming to you was not a daily occurrence in the two, 7 almost -- I guess it was 1970 to '94 time frame, 8 correct? 9 10 A. Well, first of all, you're talking about a very wide time frame. 11 Q. Yes. 12 A. Many of those years in which I was not in 13 the chancery, so I'm confused as to what particular 14 dates you're talking about. 15 Q. Well, you're telling me that you're not able 16 to remember anything about such an event having 17 happened, other than a report was made to you by 18 parents, and you advised them to go to the police, 19 correct? 20 A. That's not correct. What I'm telling you is 21 that it was 30 years ago, and I know that when reports 22 were made, I prepared a document and sent it to the 23 Archbishop, whatever period of time that was. 24 that I testified in depositions and in court, and I 25 would want to look at the documents so that I can be www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 I know Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 19 1 2 accurate in what I say to you. Q. Can you tell me today that you have no 3 memory of ever having advised anybody to report to the 4 police, other than the mom and dad that you just 5 described? 6 MR. GOLDBERG: Just a minute. I'm going to 7 register an objection to that question. 8 mentioned at the outset, when I was introducing 9 myself, you personally, Mr. Anderson, have deposed 10 Archbishop Carlson on June 21st, 1985; March 30th, 11 1987; April 2nd, 1987; and May 4th, 1987 about each of 12 these matters in some detail of which you had over 30 13 exhibits marked in those depositions, and I think in 14 fairness to the Archbishop, if you want to ask him 15 about these things and get specific answers, he needs 16 to see these documents, because no human being can be 17 expected to remember, regardless of how outrageous 18 some of these matters may have appeared, to explain in 19 detail those things to you without a reference to 20 these depositions 25 to 30 years ago. 21 22 MR. ANDERSON: 25 Mr. Goldberg, just give me a legal objection, please. 23 24 As I MR. GOLDBERG: That's my objection. You MR. ANDERSON: What was the objection? have it. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 20 1 2 3 MR. GOLDBERG: you on the record. Q. I'm not going to argue with You have my statement. (By Mr. Anderson) The question to you, 4 Archbishop, is your memory, first. 5 anything that impedes your ability to remember? 6 illness? 7 way impedes your ability to remember events? 8 9 A. Any disorder? Do you have Any Any condition that in some Obviously, I can't make either a psychological or a physical diagnosis, other than to 10 say I have had seven cancer surgeries. 11 received some kind of chemical to put me out for that. 12 If that's impeded my memory or not, I have no idea. 13 My concern is that what I say to you would be 14 accurate, and I would be happy to respond to your 15 question if you could show me a document, but with 30 16 some years, I would -- I would -- I consider this 17 matter so important, I would not want to respond 18 unless I can see what I said. 19 Q. Each time I And I want you to answer questions first 20 based on what you do remember and have you tell me as 21 accurately as is possible what you do remember. 22 to remember something and say that you don't, you 23 would agree is not truthful, correct? 24 A. What I'm saying is -- 25 Q. Would you agree with that first? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 And Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 21 1 A. What I'm saying and I've said several times, 2 I would like to answer your question with accuracy, 3 and, therefore, I'd like to refresh my memory. 4 Q. I understand what you'd like, but I need you 5 to listen to the questions asked. 6 agree to say that you don't remember something when 7 you do, in fact, have a memory of it is not telling 8 the truth? 9 10 11 12 MR. GOLDBERG: question. Q. I'm going to object to that It's argumentative. (By Mr. Anderson) Would you agree with that, Archbishop? 13 14 First, would you MR. GOLDBERG: The same objection. It's argumentative and inappropriate. 15 A. I don't understand your question. 16 Q. (By Mr. Anderson) Would you agree that the 17 assertion that you don't remember an event, when, in 18 fact, you do remember something about it, is not 19 telling the truth? 20 MR. GOLDBERG: 21 question. 22 that aren't in evidence. 23 some years. 24 25 A. I object to the form of that It's argumentative, and it assumes facts You're talking about some 30 I responded several times, and, in fact, I'll quote you from a previous deposition where you www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 22 1 told me, of course, you can't remember something two 2 or three or four years ago exactly. 3 concern that I would share in this deposition what 4 took place, and, therefore, if I could review a 5 document, I could tell you with great accuracy, 6 because I know what is in the documents I wrote. 7 Q. And it's my (By Mr. Anderson) So what I'm going to -- I 8 asked you first is the things you do remember and the 9 truth of the things that you do remember, okay, and 10 pertinent to this case, and have you tell me the truth 11 about what you do remember. 12 13 Is that a statement or a MR. ANDERSON: No. question? 14 15 MR. GOLDBERG: Q. (By Mr. Anderson) I'm going to just ask you 16 to tell me what you do remember, and then we'll have 17 an opportunity to review documents when necessary to 18 help you refresh recollection to the extent they 19 exist. 20 documents, so we need to know what you remember about 21 these events. There's some of these things that there are no Okay? 22 A. As I shared before, there was a parent or 23 couple. 24 don't remember their child's name, but I do remember 25 inviting them, if they wanted to, to call the police. I don't remember whether it was one or two, I www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 23 1 There may have been others. 2 Q. And did you report that to the Archbishop? 3 A. I reported everything to the Archbishop that 4 ever crossed my desk, and it would have been in a memo 5 form, so you would have that. 6 Q. And there were instances where you had 7 verbal conversations with the Archbishop where you did 8 not put it in memo form, correct? 9 A. 10 wasn't. 11 Q. I don't remember whether there was or Beyond the incident in which the mom and/or 12 dad made the report to you and you advised them to go 13 to the police, are there any other times in which you 14 received information where you advised another to go 15 to the police with the information pertaining to 16 sexual abuse? 17 A. I assume that there was. 18 Q. And when or what happened? 19 A. Again, I told you I don't remember with any 20 21 accuracy any particular dates. Q. And do you have any memory of any other 22 instances in which -- other than what you have 23 described in that one? 24 25 A. I don't, but there may be something in the memos. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 24 1 Q. Do you have any -- any times in which you 2 advised any of the officials or your colleagues in the 3 Archdiocese to make a report of suspicions of sexual 4 abuse by a cleric to police? 5 6 A. Again, there are several memos that tell you what I did. 7 Q. 8 that at all? 9 A. 10 11 I don't remember with any accuracy. So do you have any memory of having done With any accuracy, I can't say I remember something that happened 30 years ago. Q. Is a report of abuse by a priest to you as 12 another priest and an official in the Archdiocese the 13 kind of thing that's out of the ordinary that you 14 would think you'd have some memory of today? 15 A. Over the course of the years, I've handled 16 many things in four different dioceses, and, again, I 17 want to be as accurate as possible, so I really can't 18 comment unless I can see what I said, and I know there 19 are many documents in which I quoted what I said. 20 Q. Beyond Tom Adamson, can you give me the name 21 of any priest who was reported to you while in the 22 Archdiocese of St. Paul/Minneapolis as having 23 offended? 24 25 A. The reports on people could come to many different people, and I don't remember which ones were www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 25 1 reported to me or may have been reported to somebody 2 else. 3 Q. Did you, at any time between 1970 and your 4 appointment as Bishop of Sioux Falls in '94 and 5 particularly during the time you were an official of 6 the Archdiocese, ever meet with any priest who had 7 been accused of offending in the course of your 8 investigation of it? 9 A. Well, first of all, I wasn't in the Chancery 10 between 1970 and 1976 when I became Vocation Director, 11 so certainly during that period of time, I wouldn't 12 have met with anyone. 13 Q. So let's limit the question from '76 to 94. 14 A. In 1976, I was Vocation Director, 15 technically, in the Chancery, but I was at the 16 seminary, and then from '77 to '79, I was at the 17 Catholic University of America. 18 19 20 21 Q. Well, you appeared to be on the Priest Personnel Board in 1973? A. I was representing the junior clergy of the diocese at that time. 22 Q. So -- 23 A. I would talk to them, and we were involved 24 25 in moves. Q. So in 1973 to '76, what was -- what was your www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 26 1 2 3 assignment? A. In 1973, I think I was still at St. Margaret Mary's in Golden Valley. 4 Q. 5 Archdiocese? 6 A. So you were in the geographical area of the Since the time I was ordained, I was in 7 geographical area of the Archdiocese until late 1993, 8 when I moved, or early 1994. 9 10 Q. Didn't you live in D.C. when you studied canon law? 11 A. Correct. 12 Q. So you were in the geographical limits of 13 the Archdiocese except for when you were studying 14 canon law in D.C.? 15 16 17 A. Or went on vacation. It all kind of depends on other things. Q. Okay. So between '73, when you were at 18 St. Margaret Mary in Golden Valley, and during the 19 time that you were on the Priest Personnel Board and 20 then Vice Chancellor and then later became Chancellor 21 and then Auxiliary Bishop, during that time frame, did 22 you meet with any priest accused of sexual abuse and 23 interview him as a part of your responsibilities to 24 investigate? 25 A. And the time frame, again, is? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 27 1 Q. 1973 to 1994. 2 A. I've already mentioned to you that I did 3 note somebody, Thomas Adamson, who I met with, and I 4 think there may be other documents. 5 others, but I don't remember with any accuracy. 6 7 Q. There may be And how many times did you meet with Thomas Adamson? 8 A. I don't remember. 9 Q. And why did you meet with Thomas Adamson? 10 A. I met with him either at the request of the 11 Archbishop or the Vicar General. 12 memo that would explain to you exactly what I -- why I 13 met with him. 14 which I testified that he was involved in sexual 15 abuse, but what that particular case was, I don't 16 remember. 17 Q. There would be a But I would say no from the trial in And my question to you is, directing your 18 attention to the meeting or meetings you personally 19 had with him, what can you tell us about the 20 circumstances of that meeting and what was said? 21 A. I cannot tell you with any accuracy what was 22 said or not said. 23 issue of sexual abuse, since that's what I testified 24 in the trial. 25 Q. It's my assumption it was over the And can you tell us today if you met with www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 28 1 Adamson concerning the sexual abuse allegations more 2 than once? 3 A. As I remember, I'm sure it was more than 4 once, but, again, there would be documents that would 5 tell you. 6 7 Q. And how many times do you believe you met with him? 8 A. I don't remember. 9 Q. Where did you meet with him? 10 A. I assume the meetings were at the Chancery 11 Office. 12 Q. Your office? 13 A. Or boardroom. 14 15 16 I'm not sure. I don't remember. Q. Was anybody else present in the meeting or meetings with Tom Adamson that you do remember? 17 A. I don't remember who was or wasn't present. 18 Q. Can you tell me what action, if any, you 19 took responsive to the meeting or meetings you had 20 with Tom Adamson? 21 22 23 24 25 A. The one thing I can say clearly is whatever action I took, I always reported it to the Archbishop. Q. And when you did, what was the Archbishop's response to you? A. I don't remember. www.midwestlitigation.com Of course, if I presented MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 29 1 many different times, it could have been different 2 responses, but I don't remember, but there would be 3 something in a memo, I would think. 4 Q. Do you have any memory of any occasion in 5 which you brought the information obtained in a 6 meeting with Tom Adamson to the Archbishop and what 7 you said to the Archbishop about that meeting? 8 9 10 A. I don't remember, but I would put it in a Q. Do you have any memory of what the memo. 11 Archbishop said to you responsive to the information 12 you gave him? 13 14 15 A. Again, I assume that's in a memo. I don't remember. Q. How many meetings would you estimate you had 16 with the Archbishop where the issue was sexual abuse 17 by Tom Adamson or another priest and the question was 18 how to handle it? 19 20 A. I don't remember how many meetings I had with the Archbishop on this topic or any others. 21 Q. Can you give any estimate at all? 22 A. I don't remember. 23 24 25 Any estimate would be a simple guess of a number I would pull out of the air. Q. Did you discuss the topic of sexual abuse by either Tom Adamson or by any other priest who had been www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 30 1 accused or had offended with any other official 2 besides -- other than the Archbishop? 3 4 5 A. I don't remember with any accuracy, but there would be a memo if I did. Q. And do you have any memory of having met 6 with any other official on how to handle either 7 Adamson or any other priest accused of abuse? 8 A. I'm sure that if I did meet with somebody, 9 it would have been somebody on the Chancery staff, but 10 I don't remember who I met with or didn't meet with 32 11 years ago. 12 Q. You made reference to one time there may 13 have been a meeting with the Vicar General present. 14 Who do you think that would have been? 15 16 17 A. It would depend what year you're talking about. Q. Do you have a memory of who the Vicar 18 General was that was involved in some way either with 19 Adamson or another priest accused? 20 A. During the time -- what would be the years? 21 Because there were a couple of different Vicar 22 Generals. 23 Q. Well, you're the one that made reference to 24 the Vicar General, so I'm trying to determine who 25 you're referring to when you said the Vicar General www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 31 1 may have been there. 2 A. 3 a year. 4 Q. I could answer your question if you give me My question is what Vicar Generals, if any, 5 were involved with you in investigating or handling 6 allegations of sexual abuse? 7 A. I don't remember if any of the Vicar 8 Generals were involved. 9 During the time I was in the Chancery, there were two, 10 Monsignor Ambrose Hayden and Father Michael O'Connell. 11 Q. I may have made a report. And any other officials besides Ambrose 12 Hayden and Michael O'Connell and, of course, the 13 Archbishop, to whom you all answered, that had 14 responsibility for investigating and handling 15 allegations of sexual abuse? 16 A. If there was, I assume that there's a memo 17 that talks about it. 18 been involved. The personnel director may have 19 Q. And who are you referring to there? 20 A. It depends on the year. 21 Q. Do you remember what personnel directors 22 were involved in the sexual abuse allegation 23 investigations? 24 25 A. I don't remember with any accuracy if they were involved in sexual abuse allegations. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 I do Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 32 1 remember who the various personnel directors were. 2 Q. Who were they? 3 A. In 1973, it was Father Bill Kinney. I 4 believe, but could be mistaken, when I came back from 5 studying canon law, that at some point Michael 6 Kennedy. He was replaced by Michael Korf. 7 Q. Any others? 8 A. There may be others. 9 Those are the ones I remember. 10 11 I don't remember. Q. What were the dates that Kennedy would have been a personnel director? 12 A. I don't know. 13 Q. Dates on Korf? 14 A. I don't know, but he replaced Kennedy, I 15 think, or vice-versa. 16 MR. GOLDBERG: Those are the people. Just so we're clear, all of 17 your questions up to this point are strictly 18 St. Paul/Minneapolis? 19 MR. ANDERSON: Yes. 20 MR. GOLDBERG: Okay. Since he's been other 21 places, I just wanted to make sure we were all sure on 22 that. 23 Q. (By Mr. Anderson) Archbishop, because you 24 have some memories of having been involved with 25 Adamson, then I am going to ask you to tell me what www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 33 1 you do remember about information coming to you 2 concerning him and what involvement you had and/or 3 what action you took responsive to that information. 4 MR. GOLDBERG: I'm going to object to the 5 form of the question. 6 understand it, you can answer it. 7 A. Okay. It's compound. If you As I shared with you before, I very 8 carefully documented everything. 9 different dioceses. I've been in four I don't remember with any 10 accuracy, but as I shared with you just a few minutes 11 ago, I do remember Thomas Adamson. 12 sexual abuse because I testified in a trial. 13 Q. I know it involved (By Mr. Anderson) So then tell me what you 14 do remember today about what interactions you had or 15 actions you took or anything you did or were involved 16 in concerning Tom Adamson, what you can remember 17 today. 18 A. I don't remember with any accuracy what I 19 did or didn't do, but there are memos that would 20 explain that. 21 22 23 Q. Is your memory completely blank concerning Adamson and what your involvement was in that? A. My memory is not blank. You're asking to 24 remember with accuracy what I said or didn't say 30 25 years ago. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 34 1 2 3 4 5 6 7 Q. No. I'm asking you to tell me what you do remember. A. Well, then, I don't understand your question. Q. What do you remember about Tom Adamson and what your involvement with him was? A. I remember he was accused of sexual abuse. 8 That's the trial I participated in. I remember at one 9 point in the trial, you highlighted the fact that 10 Archbishop Roach and I disagreed over how it should be 11 handled, but I don't remember how that -- you know, 12 how that was exactly. 13 things that come to mind. 14 I do remember that I asked one couple that I remember 15 that they should go to the police, and I may have 16 asked others. 17 Q. Those are probably the two And as I've already shared, You do have some memory of the trial, and 18 that trial happened in 1990. 19 other than having met with the parents or something 20 having to do with Adamson and the parents between that 21 meeting and the trial in 1990? 22 about that time frame? 23 1990 and anything that you did or any interactions you 24 had or any action you took, anything you remember 25 about Adamson and what was done and your involvement www.midwestlitigation.com What do you remember, What do you remember We're talking about '73 to MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 35 1 in it. 2 A. Well, first of all, there would have been 3 nothing between 1973 and 1976, because when I was on 4 the Personnel Board, I was representing younger 5 priests, as I remember. 6 Vocation Director and Vice Chancellor, I took care of 7 marriage papers, and that was pretty much the extent 8 of what I did. 9 Office, which was located at the St. Paul Seminary. 10 After that time, while I And other than that, I was at Vocation Following that, I went to Catholic 11 University, so to about 1979, August of '79, when I 12 came back. 13 date. 14 said or who it was that the trial was about, I don't 15 remember. 16 And at some point, I don't remember the I met with Thomas Adamson. Q. What exactly was And is there anything else that you do 17 remember that you did, said or were involved with 18 concerning Adamson between '73 and '90? 19 A. Again, I would say it would have to have 20 been after 1979, because I don't think there was 21 anything before that that I can remember. 22 Q. I'm going to refer to an exhibit, and 23 perhaps that will help. 24 what we marked for purposes of identification an 25 exhibit, Archbishop. www.midwestlitigation.com I'm going to place before you We marked it 297. And this is MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 36 1 an exhibit that came from the file of Tom Adamson, and 2 at the top of it, you can see it is "Personnel Board 3 Meeting, Friday, February 6, 1976." 4 this as the kind of thing that the Personnel Board 5 kept, then, as a part of their minutes? 6 A. Do you recognize I'm not sure there were ever minutes kept, 7 but maybe there were. 8 report because of what's at the top of the page from 9 Father Kennedy. 10 Q. It looks to me like it's a And there's a number of the part after 11 Father Kennedy that has been blacked out or whited 12 out, but at the bottom, what has not been pertains to 13 Father Thomas Adamson. 14 you a question about that. 15 to read along, you can, but I'll read it. 16 says, "Father Thomas Adamson, priest from Winona 17 Diocese." 18 the Personnel Board, that Tom Adamson had come from 19 the dioceses of Winona and was a priest at the Diocese 20 of Winona? 21 22 23 A. Let me read it and then ask Okay? And if you'd like And it First, do you remember in 1976, while on I have no memory, and, in fact, I am surprised at the date. Q. It goes on to state, "Archbishop Roach 24 referred a letter to the Board from Bishop Watters of 25 Winona in which he asked if Father Adamson could be www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 37 1 assigned here one year or possibly two years." 2 remember receiving that information, either as a 3 member of the Personnel Board or from other sources? 4 A. 5 Do you I do not. MR. WIESER: I'm going to register a 6 continuing objection, lack of foundation, objection as 7 to form with regard to this exhibit. 8 9 MR. BRAUN: Q. I concur. (By Mr. Anderson) It goes on to state, "He 10 is a very good priest, has been a pastor, is engaged 11 in marriage encounter work and is ready for assignment 12 March 1st." Do you have memory of that Archbishop? 13 A. I don't. 14 Q. You'll see that this exhibit is dated 15 February 6, 1976? 16 A. I see the date, yes. 17 Q. And you also see that Archbishop Roach, it's 18 being recorded that he's referring to a letter. 19 now direct you to what's been marked as Exhibit 296, 20 and we will put that before you. 21 dated February 5th, 1976, the day before the note I 22 just read you in Exhibit 297, correct? I'll And Exhibit 296 is 23 A. Correct. 24 Q. And it's addressed to the Most Reverend John 25 R. Roach, then the Archbishop, correct? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 38 1 A. Correct, that's what it states. 2 Q. And it's on the stationery of the Diocese of 3 Winona, correct? 4 A. Correct. 5 Q. And you then knew the Bishop of the Diocese 6 of Winona to be Loras Watters? 7 A. I assume I did. 8 Q. And you will see it's signed. 9 10 It's not a very clear signature, but it is signed by Watters, identified as the Bishop of Winona? 11 A. Correct. 12 Q. And you'll see in the lower left-hand 13 corner, it's copied to the Personnel Board. 14 see that? Do you 15 A. I see that. 16 Q. The letter states, "Dear Archbishop Roach, 17 As you recall from our telephone conversation of two 18 weeks ago, Reverend Thomas Adamson completed his work 19 at the University of Minnesota and is now available 20 for full-time pastoral work." 21 copied to the Personnel Board refresh your 22 recollection about the status of Adamson at that time? 23 A. Does that information First of all, I have no memory of ever 24 seeing this letter, and it would not be the policy of 25 the personnel director to get copies of all those www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 39 1 letters. He may have seen it, but I don't think we 2 ever saw it. 3 Q. Well, the Personnel Board note says that at 4 Exhibit 297, it says, "Archbishop Roach referred a 5 letter to the Board from Watters." 6 7 MR. WIESER: MR. ANDERSON: Q. MR. ANDERSON: 11 MR. WIESER: 13 Q. Yes. (By Mr. Anderson) So do you have -- 10 12 Are you done with your question? 8 9 Before -- excuse me. No, I'm not done. Okay. (By Mr. Anderson) Do you have memory of this letter being referred to the Board at that time? 14 MR. WIESER: Excuse me. Before you answer, 15 Archbishop, I'm just going to again interpose an 16 objection. 17 Archbishop's testimony; a continuing objection on the 18 basis of form as well. 19 20 MR. ANDERSON: objection on form. 21 22 necessary. 25 You can have a continuing Just don't keep making -- MR. WIESER: 23 24 Again, lack of foundation based upon the I'll make my objections as Thank you. MR. ANDERSON: Well, do you want to continue or not? MR. WIESER: www.midwestlitigation.com Again, I'm just going to do MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 40 1 this based upon the exhibit that you're introducing at 2 this point, so -- 3 Q. (By Mr. Anderson) At the second paragraph, 4 it says -- excuse me, at the second sentence of the 5 first paragraph, it says, "I and Father Adamson are 6 both grateful to you for your willingness to have 7 Father Pierre and Father Kinney discuss possible 8 assignments with him." 9 10 Archbishop, do you remember learning that Adamson was seeing Father Ken Pierre? 11 A. I do not remember that. 12 Q. Do you remember meeting with Ken Pierre 13 14 15 16 concerning Adamson? A. I may have, but I have no memory of a meeting. Q. You knew Ken Pierre then to be a priest at 17 the Archdiocese of St. Paul/Minneapolis and also a 18 psychologist at the Consultation Services Center? 19 A. Yes. 20 Q. The second paragraph -- I'll read it and 21 then ask you a question. 22 Personnel Board and I have been in close contact with 23 Father Adamson, and all of us agree that for at least 24 a year or two, he needs to be engaged in pastoral work 25 outside the Diocese of Winona." www.midwestlitigation.com It states "Our Priests' MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 41 1 My having read that to you, Archbishop, does 2 that refresh your recollection of the circumstances 3 that the Personnel Board agreed that Adamson needed to 4 be outside the Diocese of Winona for at least a year 5 or two? 6 A. Again, I don't ever remember ever seeing 7 this letter, and I don't remember the discussion at 8 the Personnel Board, and I don't know what was 9 presented to the Personnel Board. 10 Q. The letter concludes at the second to the 11 last paragraph in the second sentence by Watters, 12 stating to Roach, "Our brother priests do need help 13 from time to time. 14 understanding in the case of Father Adamson." 15 I am grateful to you for your My question to you is do you remember you 16 and the Archbishop and the Personnel Board trying to 17 help Adamson and any of those circumstances? 18 A. Again, if assignments were suggested, we 19 didn't see this letter, so I don't know what 20 information we did have. 21 22 23 Q. When you say "We didn't see this letter," who's the "we" who didn't see this letter? A. Usually those things would go to the 24 personnel director, but at least, as I remember, and 25 as I've shared with you, it was a long time ago. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 I Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 42 1 don't remember letters like this being shared with the 2 members of the Board. 3 Q. Are you denying that as a member of the 4 Personnel Board in 1973, that as the note reflects, 5 that this letter was shared with the Board, or are you 6 saying you just don't remember having -- 7 A. I don't remember the letter. I have no 8 reason to doubt this statement in Exhibit 297. 9 don't remember. 10 Q. Okay. I just And so my question, then, is today 11 you don't remember having seen the letter, but you 12 don't dispute that -- if the notes reflect that it was 13 shared with the Board, you don't dispute that? 14 15 A. meeting. 16 Q. I don't remember. Maybe I wasn't at the I just don't remember. Does this refresh your recollection about 17 the fact that Adamson had come from Winona, and the 18 Bishop of Winona was urging him to stay in the 19 Archdiocese of St. Paul/Minneapolis and continue to 20 see a psychologist? 21 you? 22 A. Does that have any resonance with My first memory, and this does refresh that 23 somewhat, is that he was there taking some course at 24 the University of Minnesota, but that's all I 25 remember. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 43 1 2 3 4 5 Q. And why was he at the University of Minnesota? A. I think if he was studying family life or something. Q. And at the time that you learned that he was 6 at the University of Minnesota in coursework, did you 7 also receive information that he had problems in the 8 Diocese of Winona preceding his attendance at the U? 9 A. No. 10 Q. Why did you think he was at the University 11 of Minnesota and in the Archdiocese in 12 St. Paul/Minneapolis, having been a priest at the 13 Diocese of Winona? 14 A. It was not uncommon for dioceses to send 15 priests from many different places to study at the 16 University of Minnesota, so I actually didn't think 17 much of it. 18 19 20 21 Q. And so at any time, were you informed that Adamson could not go back to the Diocese of Winona? A. I may have been, but if I was, there'd be a document that would say. 22 Q. Do you remember that? 23 A. No. 24 Q. At any time, were you informed that Adamson 25 was seeing Ken Pierre for problems? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 44 1 A. I may have been, but I don't remember when. 2 Q. And do you have any memory of having been 3 4 5 6 informed of the fact that he was seeing Ken Pierre? A. I don't have any memory. There might be a document. Q. Do you have any memory of ever having asked 7 Adamson why he was in the Archdiocese of St. Paul/ 8 Minneapolis and/or couldn't go back to Winona? 9 A. As I sit here today, I don't remember asking 10 that question. 11 that would say so. 12 Q. 13 abused kids? 14 A. 15 16 17 18 If I did, there would be a document Did you ever ask Adamson if he had sexually I assume I did, but if I did, there'd be a document that would state that. Q. Do you have any memory of having asked him the question? A. Again, I assume I did. I don't remember 19 what I said or what he said, but there would be a 20 document that would say so. 21 Q. So I don't want you to assume. I just want 22 you to tell me what your best recollection is today 23 and answer it this way. 24 recollection today of having asked Adamson if he had 25 sexually abused any kids? www.midwestlitigation.com What is your best MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 45 1 2 3 4 A. Again, if I did, there would be a document that would say so. Q. But I'm talking about what you remember today. 5 A. I don't remember asking him the question. 6 Q. Is it fair to say that you were kind of the 7 point guy for handling sex abuse claims on behalf of 8 the Archdiocese and the Archbishop in the 1980s? 9 A. That would not be accurate. 10 several, I believe. 11 Father McDonough. 12 13 14 15 Q. I, certainly, and I believe And at some point Father Korf and O'Connell became involved in that as well? A. I don't remember with any accuracy, but I -- as I -- I vaguely remember that they did. 16 17 There were MR. GOLDBERG: Do you mind if we take a break for a minute or two? 18 MR. ANDERSON: Do you want to take a break? 19 VIDEOGRAPHER: The time is 11:12. 20 the record. 21 (Whereupon a break was taken.) 22 VIDEOGRAPHER: 23 now back on the record. 24 25 We're off Q. The time is 11:21. We are (By Mr. Anderson) Archbishop, when it comes to the events concerning Tom Adamson and your www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 46 1 involvement in them, why do you think your memory is 2 so lacking when it comes to what happened and your 3 involvement in it? 4 5 6 MR. GOLDBERG: Objection, argumentative. There's no evidence that his memory is lacking. Q. (By Mr. Anderson) Well, why do you think 7 that you have told me so many times that you don't 8 remember any events concerning Adamson that occurred 9 in the '70s? 10 A. Well, Jeff, accuracy is very important to 11 me, and I know that the memos would accurately reflect 12 what I said or did, and you're asking me to remember 13 something that was 32 years ago, and I can't remember 14 that with any accuracy. 15 important discussion, and I want to make sure we have 16 the facts as they were then. 17 18 Q. I think this is a very You do recall that in 1985, I took your deposition in the matter of Greg Riedle? 19 A. Yes. 20 Q. And asked you questions concerning what you 21 22 23 24 25 knew back then about that matter? A. I didn't remember he was the one, but I do remember Greg Riedle. Q. The record reflects that was there was a deposition taken of you on June 21st, 1985. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 You have Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 47 1 no reason to dispute that; do you? 2 A. I don't. 3 Q. Did Bishop Watters have discussions with you 4 about your testimony and his imminent, upcoming 5 deposition following the deposition you gave in June 6 of 1985? 7 A. That may have happened. 8 with any accuracy. 9 didn't -- it did. 10 11 12 Q. I don't remember I have no reason to doubt it What do you remember about discussions with Bishop Watters? A. At some point, and I don't remember the 13 date, I went to the Archbishop, and I said, "You know, 14 I don't understand what's going on." 15 met with him, or we both met with him. 16 remember. 17 18 19 Q. And he may have And what made you say you didn't understand what was going on? A. As I shared before, I always thought he was 20 studying at the University of Minnesota. 21 that's what I was led to believe. 22 I don't Q. At least And then you received information otherwise 23 that caused you to discuss it with the Archbishop. 24 What was that? 25 A. Well, you had brought to mind the name the www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 48 1 Greg Riedle, and I know I met with him. 2 that he had been abused by Father Adamson. 3 4 Q. And he said Is Greg Riedle now the name of the parents that you advised to go to the police? 5 A. That, I don't remember. 6 been others. 7 Q. There could have In any case, after having given a deposition 8 in June of 1985, there were discussions with yourself 9 and Archbishop Roach about the Adamson matter? 10 11 12 A. I assume there were. I have no reason to say there weren't. Q. There were discussions between yourself and 13 Archbishop Watters, and he called you, did he not, to 14 discuss it? 15 16 17 A. That, I don't remember. The discussion could have been with Archbishop Roach. Q. Do you recall him, Archbishop Watters, 18 calling you in advance of his scheduled deposition to 19 ask you about how it went and what it was like and 20 what to expect? 21 A. I don't remember that. 22 Q. Do you recall advising him how to testify? 23 A. I don't remember the conversation. 24 Q. I'm going to show you an exhibit that we 25 have marked as Exhibit 239. www.midwestlitigation.com And this is the MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 49 1 deposition taken in the matter of the Riedle vs. 2 Adamson, Archdiocese, et al. 3 February 12, 1987. 4 it is the deposition taken of Loras Watters, 5 examination by me, and I will direct your attention to 6 Page 55 of the deposition, Archbishop. 7 numbers are in the upper right-hand corner? 8 The file date of it is As you can see on the cover sheet, MR. GOLDBERG: Excuse me. And the Before we get 9 into this, may I simply ask you a question? 10 this is not signed, and I notice there's no 11 certification behind it. 12 is an accurate copy of the deposition? Can you represent that this 13 MR. ANDERSON: I do. 14 MR. GOLDBERG: All right. 15 I notice But there is an original signed somewhere? 16 MR. ANDERSON: There is. 17 MR. GOLDBERG: Did he make any edits or 18 19 corrections to this? MR. ANDERSON: I can't -- I can't address 20 that at the moment. 21 deposition that has been signed, certified, filed with 22 the court and speaks for itself. 23 I can only say that this is a MR. GOLDBERG: Well, but it's not signed, is 24 my point, but you're saying there is another one 25 that's been signed. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 50 1 MR. ANDERSON: It is, correct. 2 MR. GOLDBERG: But you don't know whether 3 it's been amended or not by errata sheets? 4 5 6 MR. ANDERSON: Well, I can't answer that question to you today. Q. (By Mr. Anderson) I direct your attention to 7 Page 55, Archbishop, and go to Page 54. 8 25, the question is, "Other than Mr. Blahnik, your 9 attorney, co-counsel, when did you discuss it with 10 11 Father Adamson?" Answer: "Well, we have been in contact, oh, 12 perhaps every two weeks. 13 ten days ago." 14 And at Line Question: The last time was probably "Okay. I will get back and ask 15 you about that a little later. 16 with anybody else in preparation for this deposition 17 today, knowing that you were going to be asked 18 questions about it?" 19 Answer: "I guess Bishop Carlson, after I 20 received his deposition. 21 it looks like, you know?'" I said, 'Is that as tough as 22 Question: 23 Answer: 24 say is 'I don't remember.'" 25 Have you discussed it "Is it?" "He said, the best thing you can Is that what you told Bishop Watters to do www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 51 1 2 3 4 in his deposition? A. I have no knowledge of the discussion. I would simply say I don't think I ever said that. Q. So do you say it's a coincidence that he 5 testified that you told him to -- that the best thing 6 he could say is to not remember and that today you 7 don't remember? 8 A. 9 I never -MR. GOLDBERG: Just a minute. 10 object to the form of that question. 11 argumentative. 12 hearsay, obviously. 13 14 15 16 A. I'm going to It's There's no foundation, and it's I don't remember having this discussion. I don't think I ever said that. Q. (By Mr. Anderson) What discussion did you have with him? 17 A. Again, I don't remember with any accuracy. 18 Q. Well, how can you deny having that 19 discussion if you can't testify to what discussion you 20 did have? 21 22 23 24 25 A. Because I don't think he would have ever called me. Q. Is it your testimony you never had a conversation with Watters? A. I don't remember at this time ever having www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 52 1 any conversation with Watters. 2 document that said so, and if I had this conversation, 3 there would be a document that would say so. 4 Q. If I did, there's a You would document that you had advised him 5 to testify under oath that he didn't remember, and 6 that's the best thing for him to do? 7 A. I don't think we ever had that discussion. 8 Q. Would you agree, Archbishop, that if you had 9 advised him to testify that he didn't remember things 10 that he did remember would be advising him to be less 11 than truthful and not tell the truth under oath? 12 13 14 A. The only advice I would have given -- would give anybody is to talk to your attorney. Q. I'm going to direct your attention to 15 Exhibit 299, and this is for a time reference for your 16 use now. 17 Tom Adamson by then Archbishop Roach. 18 first paragraph. 19 the recommendation of the Personnel Board, I am 20 pleased to offer you an assignment in the Archdiocese 21 of St. Paul/Minneapolis as an associate pastor of the 22 Church of St. Thomas Aquinas at St. Paul Park." 23 That's what it says, correct? And you'll see that 299 is the assignment of I'll read the It says, "Dear Father Adamson. Upon 24 A. Yes. 25 Q. And so this would be the official letter of www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 53 1 assignment by the Archbishop to Adamson at that 2 parish, correct? 3 A. Correct. 4 Q. You were on the Personnel Board then; were 5 you not? 6 A. I believe I was. 7 Q. The second sentence -- the first -- the 8 second paragraph, the first sentence says, "This 9 appointment will become effective on Tuesday, June 15, 10 1976 at noon. 11 pastor, Father Keller, before noon." 12 I would ask that you report to the Do you have a recollection of Keller having 13 been at that parish and as a member of the Personnel 14 Board, Adamson being assigned there? 15 A. I don't remember him being assigned there. 16 Q. I'm going to direct your attention to 17 another exhibit. 18 301 is dated November 25th, 1980. 19 file of Father Thomas Adamson, and it's from you, 20 correct? It's 301, Archbishop. And Exhibit It's a memo to the 21 A. Correct. 22 Q. I'm going to read a portion of it and then 23 ask you a question about it. 24 November 24th, 1980 Father Korf and I met with Father 25 Adamson to discuss the report that Father Wajda www.midwestlitigation.com You write, "On Monday, MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 54 1 brought to the Chancery." 2 that meeting with Father Adamson concerning the 3 report? 4 A. What can you tell me about I don't remember the meeting. It took place 5 a long time ago, but I have no reason to doubt that 6 what I said here was accurate. 7 8 9 Q. So you have no independent recollection of having met with Adamson at the time of this document? A. I believe what I wrote at that time to be 10 true, but I don't remember the meeting at this time by 11 memory. 12 Q. It goes on to state, "He admitted the sexual 13 contact with Blank." 14 blacked out. 15 Adamson admitting to you and Father Korf that he had 16 abused this kid when you met with him? 17 18 19 20 A. That is the name of the kid is My question to you is, do you remember I don't remember it, but if it's here, I believe it to be true. Q. Well, a priest admitting to you that he had abused a kid is a pretty shocking thing; isn't it? 21 A. Correct. 22 Q. It's not an ordinary event in the course of 23 your official duties in the Archdiocese as a priest, 24 right? 25 A. Right. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 55 1 Q. And it's also correct to say that you have 2 no memory of the meeting itself. 3 telling me? 4 A. Is that what you're I have no memory of the meeting, but as it's 5 stated here, it would have been truthful at the time I 6 wrote it. 7 Q. After the name of the kid that he had 8 admitted the sexual contact with, it states, "And I 9 pointed out that this activity reflects a pattern 10 which is both a gross case of mismanagement on his 11 part, and it destroys his long-term effectiveness in 12 the Archdiocese." 13 correct? 14 Those were your words as recorded, MR. WIESER: Actually, you've misstated one 15 of the terms in that sentence you just got done 16 reading. 17 18 MR. ANDERSON: Q. I'll reread it, then. (By Mr. Anderson) After the name of the 19 victim is blacked out on this document, I'll read it 20 again and then ask the question. 21 pointed out that this activity reflects a pattern 22 which is both a gross case of misjudgment on his part 23 and it destroys his long-term effectiveness in the 24 Archdiocese." 25 correct? www.midwestlitigation.com It states, "And I Those were your words recorded then, MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 56 1 2 A. These are my words, which by the typing, you can tell I also typed it. 3 Q. Yeah. 4 A. Correct. 5 Q. So when you use the term "his admission" to So you did your own memos back then? 6 you and Father Korf that he had sexually abused the 7 kid, and you point out that this activity, sexual 8 abuse, reflects a pattern, what was the pattern that 9 was known to you that you recorded to be the case on 10 11 12 13 14 November 25th, 1980? A. Again, I don't remember why I put that word down, but if I put it here, this is what I said. Q. You wouldn't put down there was a pattern unless there was a pattern, right? 15 A. I believe that would be true. 16 Q. And you're talking about sexual abuse here, 17 so there was a pattern of sexual abuse you're now 18 making a record of for the benefit of the file and the 19 Archbishop, I trust, correct? 20 A. Correct. 21 Q. And as you testify here today, you're not 22 able to tell us, or at least remember what the pattern 23 was that you recorded in this document? 24 25 A. I don't remember why I used that word, but I have no reason to doubt that if I used it, there was www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 57 1 something. 2 3 Q. And something would be a pattern of sexual abuse by Adamson, correct -- 4 A. I believe that to be true. 5 Q. -- of kids -- 6 A. Well, of people. 7 Q. You went on to state, "This behavior cannot 8 be tolerated," correct? 9 A. Correct. 10 Q. It then -- you then wrote, "I told him that 11 the Archbishop had asked me to accept his resignation, 12 or if he did not give it, to suspend him." 13 write that? Did you 14 A. I believe the memo to be accurate, yes. 15 Q. Do you remember that? 16 A. I don't remember it, no. 17 Q. Do you remember having ever taken action 18 like this or recommending action like this to the 19 Archbishop before the date of this memo, November of 20 1980? 21 A. No, I don't. 22 Q. You go on to write, "He asked if another 23 course of action was possible, and I spoke with the 24 Archbishop." 25 the Archbishop? www.midwestlitigation.com Tell me, do you remember speaking with MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 58 1 A. I do not. 2 Q. Do you remember Adamson asking you to 3 consider options, other than a resignation? 4 A. I don't. 5 Q. You then write, "It was agreed that we would 6 meet again on Tuesday in the Archbishop's office at 7 10:30 a.m." 8 9 10 A. Do you remember that? I don't remember the meeting, but I have no reason to doubt it didn't take place. Q. Okay. And then I think you record, "At this 11 meeting, the Archbishop spoke with Father, and it was 12 agreed that." 13 recorded there, correct? So there are six items that you 14 A. That's correct. 15 Q. And as you read this memo that you prepared, 16 is it fair to say that you attended that meeting, and 17 then you made this recording of what was done or said 18 at that meeting? 19 A. That's correct. 20 Q. Okay. And so when you write, "At this 21 meeting, the Archbishop spoke with Father," that means 22 with Adamson in your presence, correct? 23 24 25 A. I'm not sure I was present. I just don't know, but obviously spoke with Adamson. Q. Well, how else would you know that these six www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 59 1 points were put down unless you were there? 2 A. He could have told me. I don't -- I just 3 don't remember, but I have no reason to doubt that 4 these are not the points. 5 Q. And you don't dispute that you were -- you, 6 along with Korf, at this time were in charge. 7 your responsibility to basically investigate and 8 handle this and report to the Archbishop? 9 10 A. I don't think there was anything that formal, but, obviously, I was involved in this case. 11 Q. So as you read this memo, you don't dispute 12 that you were at the meeting. 13 don't remember it? 14 15 It was A. Are you just saying you I don't remember being there, but whatever I wrote there would be truthful. 16 Q. Okay. So when you write Point No. 1, "It 17 was agreed that, number one, Father Adamson would 18 begin an immediate evaluation with Father Pierre as to 19 the final treatment." 20 remember it? 21 A. No, but I have no reason to doubt it wasn't Q. Two, you write, "This report will be given 22 23 24 25 You recorded that. Do you said. to the Archdiocese ASAP." A. Did you write that? I have no reason to doubt I didn't. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 60 1 Q. 2 does it not? 3 A. As it's printed there, I believe it does. 4 Q. Item 3. This connotes a -- some sense of urgency; You wrote, "Father would see his 5 Bishop in Winona when the evaluation is finished." 6 you remember that? 7 8 A. I don't, but, again, I have no reason to doubt that was what was said. 9 10 Q. No. 4, you wrote, "Father Carlson would meet with Father Adamson and Wajda." 11 A. 12 typewriting. 13 Q. Did you write that? I -- obviously, I wrote it. Okay. It's my Do you remember Father Wajda had 14 brought the report of Adamson having abused a kid to 15 you that precipitated this meeting? 16 17 18 Do A. That's what it says at the top of the memo, Q. And when it says and you record that you yes. 19 would meet with Adamson and Wajda, did you meet with 20 Adamson and Wajda? 21 A. I assume I did. 22 Q. And if you did do as is recorded here, would 23 I don't remember. you have made notes of that meeting? 24 A. I think I would have. 25 Q. Was your practice then to make handwritten www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 61 1 notes during a meeting and then type them up later? 2 A. Yes, usually. 3 Q. You wouldn't type during meetings with the 4 5 6 7 8 9 10 11 12 13 14 15 Archbishop, I trust? A. No, I wouldn't. I type like this, so I wouldn't. Q. I kind of figured. Well, what would you do with the handwritten notes? A. I would have transcribed them to a typed memo, because nobody can read my writing. Q. notes? A. And then what happened to the handwritten Were they destroyed? They would have been shredded or thrown out, or I don't know. Q. Have any of those notes pertaining to this 16 matter at that time or any others like it been 17 retained by you, the handwritten notes? 18 19 20 A. I have no handwritten notes at all, nor would I have ever retained them. Q. So your practice was to write down the notes 21 in the meeting, type it out, or peck it out, as you 22 say, and then destroy the handwritten note and keep 23 the typewritten copy for the file? 24 25 A. The handwritten notes would have been of no use to nobody. www.midwestlitigation.com Sometimes it wasn't even of any use to MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 62 1 2 me. Q. Item No. 5 is "Father Adamson," it looks 3 like "would" -- maybe it's misspelled -- "cease all 4 youth involvement." Did I read that correctly? 5 A. I believe that's true. 6 Q. Do you remember that he was to cease all 7 8 9 10 Yes. youth involvement? A. If it's there, obviously that's what the Archbishop told me. Q. In your experience, is it really possible 11 for a priest to be in a parish and not have some 12 involvement with youth? 13 A. I don't know. Some do and some don't. 14 Q. Have you ever seen a priest, or have you 15 ever known a priest to be able to be in a parish where 16 they could not have some involvement with youth? 17 18 A. There may be some. I think it would be very difficult. 19 Q. Is it even possible? 20 A. Oh, sure. 21 Q. How could it be possible? 22 A. We have senior priests in parishes that have 23 24 25 It's possible. no contact with youth, other than if they're at Mass. Q. What could you tell us about the reason No. 5 is being imposed, that he was to cease all youth www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 63 1 involvement? 2 A. Well, this is what -- obviously what the 3 Archbishop said. 4 Father Wajda gave at the top of the page, so I assume 5 it has to do with that report. 6 7 Q. 10 11 12 13 14 And -- but other than what is written, again, no memory of it? 8 9 We're talking about a report that A. I have no memory of what Father Wajda said with any accuracy, but if he did tell me, I wrote it down. Q. Item No. 6, you write, "If it gets out any further, Father would have to leave." A. That's correct? I have no reason to doubt it, that that's what the Archbishop said. 15 Q. And is the concern there about scandal? 16 A. Obviously, I'm sure the Archbishop would be 17 concerned about scandal, but what his thinking was, 18 other than this statement, I don't know. 19 Q. When you recorded it, under the circumstance 20 at the time, why would the -- why would the 21 information about him having abused getting out any 22 further have to cause him to have to leave? 23 24 25 A. I don't remember. It's what the Archbishop would have said, because that's what I wrote. Q. There was a concern about the scandal; www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 64 1 2 3 4 wasn't there? A. Was there not by the Archbishop? Again, I don't know what his thinking was. I assume that's what it was. Q. I'm going to direct your attention to 5 Exhibit 302, Archbishop, and it is dated a little 6 over, I guess, nine days after this Exhibit 301. 7 the date of this is December 4, 1980. 8 the file of Father Adamson from yourself, Robert J. 9 Carlson. And It's a memo to The subject is Father Adamson/ 10 Do you remember him to have been the kid who Adamson 11 admitted having abused? 12 13 A. what it says. 14 15 I would like to read the memo just to see MR. GOLDBERG: Q. Take a minute. (By Mr. Anderson) Let me just ask you. I 16 put it before you to see if it refreshes your memory, 17 and I guess I just want to have you listen to that 18 question first. Do you actually remember that? 19 MR. GOLDBERG: 20 out if he remembers it. 21 Q. He's got to read it to find (By Mr. Anderson) Well, no, I'm asking what 22 you remember, and I'll ask you some questions about 23 it, but I'm not going to keep you from reading it, but 24 I need you to ask [sic] what you remember first. 25 A. I know I met with Joe Wajda. www.midwestlitigation.com I couldn't MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 65 1 tell you with any accuracy the name of the person, 2 but, again, I'll read the memo. 3 Q. I think the memo, you know, does reflect 4 that there's a report from a Father here, and this is 5 your memo prepared by you, and I presume you made some 6 handwritten notes and then typewrote this, correct? 7 A. I assume that's what I did. 8 Q. Okay. 9 There's also a -- the December 1, '80 notes that you record here concerning and 10 Wajda, and then there's the December 4th, '80, a 11 Sister Patrice Neuberger. 12 with her concerning Adamson and all -- and who is she? 13 14 A. Do you remember engaging Well, Sister Patrice Neuberger was my kindergarten teacher. 15 Q. Okay. 16 A. And she's now deceased, but we -- I saw her 17 18 often. Q. And so what you wrote was accurate, then. 19 The question is do you remember anything about the 20 events here? 21 A. No, but I would be glad to read it. 22 Q. Well, if -- if you think you need it and it 23 will refresh your recollection or something, it's 24 worth it to have you read it, but -- if you choose to. 25 A. I'd like to read it. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 66 1 Q. Sure. 2 A. Okay. I read it. 3 Q. Okay. Is it correct that you recorded that 4 -- does your reading it refresh your recollection 5 about the events? 6 7 8 9 A. It doesn't, but as written, it would have been what happened. Q. Okay. And so what happened, then, is that after the restriction of no youth contact was imposed 10 on him by the Archbishop, as recorded by you on 11 November 25th, 1980, he's continued to have youth 12 contact in violation of that restriction and as is 13 reflected in your memo of December 4th, 1980, correct? 14 A. My confusion is it says there's a report 15 from Father Wajda. 16 and so -- 17 18 Q. That's not here and on this one, There's an earlier report in the document from Wajda. 19 A. Well, this is what it is. 20 Q. Okay. Do you remember what action you took 21 or advice given to the Archbishop pertaining to the 22 information in Exhibit 302? 23 A. I don't. 24 Q. Yeah. 25 I assume I sent this to him. When you prepared it for the file, you also prepared it for the Archbishop's eyes. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 That Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 67 1 was your practice? 2 A. Correct. 3 Q. The records reflect that at some point in 4 time -- let's go to Exhibit 303. 5 December 9, a few days after 302. 6 and this is a memo to Archbishop Roach from you 7 regarding Thomas Adamson. 8 write, "I have concluded the investigation concerning 9 Father Thomas Adamson." This one is The year is 1980, And it begins by -- you So it's correct to say that 10 you were charged with the investigation of Adamson, 11 correct? 12 13 MR. GOLDBERG: Object to the form of that question. 14 A. Well, I know what I wrote was truthful at 15 the time. 16 was asked to do it, so whether it was formal or not, I 17 don't know, but I was asked to investigate. 18 Q. Whether it was a formal investigation or I (By Mr. Anderson) And you go on to write, 19 "Concerning Father Thomas Adamson and the very serious 20 charges brought against him by Blank." 21 charges? 22 23 A. I don't remember, but I'm sure they were of a sexual nature. 24 25 What are those Q. Criminal sexual conduct to minors; wasn't it? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 68 1 2 3 A. I can't make a decision as to what it is in law, but it was serious sexual abuse. Q. You go on to write, "I have spoken to Father 4 Wajda, the Associate Pastor of Immaculate Conception 5 of Columbia Heights; Sister Patrice, the parish worker 6 at Immaculate Conception; Blank, which would be a 7 victim or father or a parent." 8 "All of these people requested to see me." 9 remember those people requesting to see you? And then you write, Do you 10 A. No, but I have no doubt that they did. 11 Q. You then write "On Friday, December 5th, 12 1980, I met with Father Ken Pierre concerning his 13 evaluation of the session with Father Adamson." 14 correct that you record that you knew that Ken Pierre 15 had been evaluating and seeing Adamson, and you had 16 permission to meet with him, and you did, correct? 17 A. I assume I did. 18 Q. Go to the fourth paragraph. It's It says I did. I'm going to 19 read it and then ask you a question concerning what 20 you wrote. 21 with Blank, and Father Adamson was as truthful as he 22 had to be." 23 24 25 A. You write, "I have discussed the incident What did you mean by that? I think exactly what it says. If he thought I knew something, he said something. Q. And you write -- go on to write, "Father www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 69 1 Pierre also indicated to me that there have been other 2 incidents of this nature." What does that refers to? 3 A. I think it refers back to the sexual abuse. 4 Q. And what do you remember about how many 5 other incidents Father Pierre related to you there had 6 been of sexual abuse by Adamson? 7 A. I don't remember. 8 Q. Do you remember what action was taken at 9 10 11 12 that time responsive to this by the Archbishop? A. Only because I turned the page. It must have been inpatient therapy. Q. But that's reflective of the next 13 document -- excuse me -- the next page. 14 question to you is do you have any memory, independent 15 memory of that? But my 16 A. I don't. 17 Q. You do know that he ultimately was 18 transferred to another parish; do you not, by the 19 Archbishop? 20 A. 21 what parish. 22 Q. 23 I believe that happened. I can't tell you The records reflect it was Risen Savior. Does that refresh anything for you? 24 A. (No response.) 25 Q. Before Adamson was assigned to Risen Savior, www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 70 1 and after he was removed from Immaculate Conception, 2 and during that time, do you have any memory of 3 yourself or any official of the Archdiocese having 4 reported what's reflected in the memos prepared by you 5 and the meetings held being reported to law 6 enforcement? 7 8 MR. GOLDBERG: question. Object to the form of the It's compound. 9 A. No. 10 Q. (By Mr. Anderson) Do you recall being 11 concerned or the Archbishop or any other official 12 involved with Adamson at that time, being concerned 13 about him being criminally prosecuted, that being 14 public and there being scandal concerning it? 15 16 MR. GOLDBERG: question. 17 18 Object to the form of that MR. WIESER: A. Join in the objection. I think anytime you're dealing with 19 something like this, there's always a concern about 20 scandal. 21 remember. 22 Q. I assume it existed in this case. I don't (By Mr. Anderson) There is a former priest 23 from the Diocese of Winona who was then administrator 24 at the Guardian Angels. 25 Do you remember Jim Fitzpatrick? www.midwestlitigation.com His name is Jim Fitzpatrick. MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 71 1 A. The name's familiar. 2 Q. He has reported to us that you placed a call 3 to Ken LaVan at Guardian Angels. 4 LaVan? Do you remember Ken 5 A. I remember Ken LaVan. 6 Q. He's also reported that the call to Ken 7 LaVan was overheard by him, and you were trying to 8 find a parish to place Adamson in and asked LaVan to 9 take Adamson. 10 My question to you is do you recall having made such a call to Ken LaVan? 11 MR. GOLDBERG: I object to the form of the 12 question. 13 you or what you're referring to, but -- 14 15 18 MR. ANDERSON: I'm asking the witness what MR. GOLDBERG: Well, you're referencing a he knows. 16 17 I'm not sure what report has been made to report, sir, that hasn't been produced. A. It would be very unusual for me to be making 19 calls to parishes for placement. Usually that would 20 be the Personnel Board Director. I don't remember 21 making the call. 22 Q. (By Mr. Anderson) And so do you recall 23 making an effort to find another parish where Adamson 24 could be in the Archdiocese? 25 A. No. www.midwestlitigation.com And I think someplace there's a MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 72 1 document where I was removed from the case because I 2 opposed him being moved to another parish. 3 Q. What do you remember about that? 4 A. I remember I was no longer involved, and 5 Father Korf took it over. 6 Q. Who removed you from the case? 7 A. The Archbishop. Q. Why were you opposed to him being moved to a 8 9 10 11 12 13 I believe I testified to that. parish, another parish? A. Very obvious. There's reports of sexual abuse of young people. Q. Fitzpatrick has also indicated that he 14 reported to Ken LaVan and thus to you that if Adamson 15 was placed at that parish, he would resign, because he 16 knew that Adamson had abused kids back in Winona and 17 had reported it to Fitzgerald. 18 of having received that information either from LaVan 19 or Fitzgerald at that time? 20 MR. GOLDBERG: Do you have any memory I object to the form of the 21 question. There's no time frame as to "at that time." 22 There's no foundation that the Archbishop has ever 23 spoken with Mr. Fitzpatrick or has a memory of it. 24 And if you have a document, it should be produced to 25 the witness. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 73 1 2 A. I was never working at the Chancery when Bishop Fitzgerald was alive. 3 Q. (By Mr. Anderson) Okay. But I'm talking 4 about having been told by Ken LaVan, "We can't take 5 him here, because Jim Fitzpatrick will resign and make 6 a stink." 7 A. Again, I -- I don't know whether that 8 conversation took place or not, but I believe it would 9 have been with the personnel director, not me. 10 Q. Sometime later, did you follow up -- did you 11 make a call to Jim Fitzpatrick after the Adamson case 12 became quite public in 1987, '88 and making a call to 13 Jim Fitzpatrick's and having a meeting with him at 14 Jack's Cafe? 15 A. 16 No, but it would be a great place to have lunch. 17 Q. He thought it was. He said you ordered the 18 steak sandwich, the top of the menu. 19 that? 20 A. 21 cholesterol. 22 Q. Do you remember That was before I had to deal with Okay. Do you have any memory at all, 23 Archbishop, of having had a meeting with Jim 24 Fitzpatrick after the Adamson thing became quite 25 public and a discussion with him about his knowledge www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 74 1 of it and what he might do or not do? 2 3 4 MR. GOLDBERG: Object to the form of that question. A. I have no reason to say I did or didn't. I 5 liked Jim Fitzpatrick, as I can kind of remember. 6 I've had no contact with him for 20 or 25 years, but 7 as I think about it, if he had some information, I 8 think I would have told him to go to the police, but I 9 don't remember. 10 Q. 11 Exhibit 319. 12 February 2, 1981. 13 Roach. 14 "I am pleased to appoint you as an Associate Pastor of 15 the Church of the Risen Savior, Apple Valley, 16 effectively immediately." 17 this, correct? (By Mr. Anderson) I'm going to show you And Exhibit 319, Archbishop, is dated It's a letter from Archbishop It's copied to you, to Adamson, and it says, You obviously received 18 A. It says at the bottom that I was copied. 19 Q. And do you remember receiving this? 20 A. I don't remember receiving it, but I have no 21 22 reason to doubt I didn't. Q. Do you remember being ticked off when you 23 saw that he had been assigned to another parish 24 after -- after what you had recorded and learned? 25 A. I don't remember if this was the time. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 I do Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 75 1 remember being very upset and at some point was 2 removed from everything. 3 Q. Who did you express your upset to? 4 A. Well, if I was removed, I must have 5 expressed it to the Archbishop, but I don't remember 6 doing it. 7 Q. Why were you upset? 8 A. I was upset for a couple of different 9 reasons. One, as I think about it, when he went to a 10 counselor, I thought the counselor would say, you 11 know, he can't continue. 12 opinion, I think counselors did a disservice. 13 think they know what they were dealing with. 14 remember that particularly? 15 have. 16 It's a feeling, and he was obviously reassigned. 17 18 19 Q. I don't Do I No, but it's a feeling I Do you know what I mean? It's not a memory. And you were also upset because you knew the Archbishop was making a choice to put kids at risk? A. I don't remember that, but that was 20 certainly part of it. 21 ministry at one time. 22 But in those days, in my Q. I was involved with the youth This assignment letter, the third paragraph 23 states, "This appointment will not be published in the 24 'Catholic Bulletin' at this time." 25 that it would not be publicly known that he was being www.midwestlitigation.com Now, that means MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 76 1 assigned there. 2 being made by the Archbishop and copied to you that 3 this would not be published? Do you remember why the choice was 4 A. There are two possibilities. 5 Q. But do you remember? 6 speculate. 7 A. No, I don't remember. 8 Q. Okay. 9 I'm not asking you to Would you agree that this document reflects an effort by the Archbishop to keep the 10 assignment under the radar because of the history 11 already known to the Archdiocese? 12 13 MR. WIESER: Object to the form. It calls for speculation. 14 MR. GOLDBERG: I'll join in that objection. 15 Q. (By Mr. Anderson) You can answer. 16 A. Again, there would be two reasons. One, it 17 could be a very temporary assignment, and I don't 18 remember whether it was or wasn't; and secondly, for 19 whatever reason, the Archbishop didn't want it known. 20 21 22 23 24 25 Q. If it's a temporary assignment, he's assigned as an administrator, right? A. No. He's assigned at an associate pastor, and that's often a temporary assignment. Q. Yeah, but it's a temporary assignment that says temporary assignment as associate pastor; doesn't www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 77 1 it? 2 MR. WIESER: Objection, foundation. 3 Q. (By Mr. Anderson) In your experience? 4 A. Sometimes yes and sometimes no. 5 Q. It doesn't say "temporary" here? 6 A. It doesn't have to. 7 Q. It doesn't look like it; does it? 8 A. I don't remember, but it is what it is. 9 Q. Okay. But if it's not a temporary 10 assignment, it's really, then, an effort to make sure 11 the people -- it's an effort to keep this thing under 12 the radar and to avoid scandal; isn't it? 13 14 MR. GOLDBERG: I'm going to object to the form of that question, speculation. 15 A. As I shared, there's two reasons. 16 Q. (By Mr. Anderson) I'm going to refer you to 17 Exhibit 304, Archbishop. 18 June 29th, 1984, and it's a memo to Archbishop John R. 19 Roach from you, then Bishop Carlson, on the subject of 20 Father Tom Adamson. 21 1984, I was contacted by Mr. Paul Ringsmuth, 22 Vocational Rehab Counselor at St. Cloud Reformatory to 23 inform me that one of the inmates, Gregory Riedel, 24 serving 13 months for rape, was the victim of sexual 25 abuse from the age of 14 to 16 ending in 1982 by www.midwestlitigation.com And this one is dated And you write, "On June 28 [sic], MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 78 1 Thomas Adamson." 2 A. You wrote that, correct? Correct. 3 MR. GOLDBERG: 4 you misstated the date. 5 don't get confused. 6 7 MR. ANDERSON: Excuse me. For the record, It's June 29, 1984, so we I stand corrected. Thank you. 8 Q. (By Mr. Anderson) So do you remember this? 9 A. I don't remember the meeting, but I have no 10 11 reason to doubt this. Q. You go on to write, "This began when he was 12 a priest serving in St. Paul Park and continued at IC, 13 Columbia Heights." 14 Conception, correct? IC stands for Immaculate 15 A. Correct. 16 Q. You go on to write, "Some of the incidents 17 took place while he was seeing Father Pierre and while 18 we had him in counseling with Dr. Gendron." 19 what you wrote, correct? That's 20 A. Correct. 21 Q. Does this refresh your recollection that he 22 had not only been required to see Pierre, but he also 23 had seen Dr. Gendron at St. Mary's? 24 25 A. It does refresh my memory. I did send him to Dr. Gendron. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 79 1 Q. And you had some kind of relationship that 2 you knew Gendron from having worked with other 3 priests? 4 A. I'm not sure if it was having worked with 5 other priests. 6 was on the St. Mary's Board for a while. 7 8 Q. We were on the same board, because I Okay. Do you remember why you selected Gendron to send Adamson to? 9 A. No, unless, you know, I knew him. 10 Q. The last -- you'll recall that Adamson was 11 to not have contact with youth in the earlier memos, 12 and this clearly is -- well, let me ask you this. 13 Look at the last paragraph in this memo, and I'll read 14 it and then ask you a question. 15 statute of limitations does not run out for two and a 16 half years." 17 A. I wrote it. 18 Q. Why did you calculate the criminal statute 19 You wrote that, correct? of limitations? 20 MR. GOLDBERG: 21 object to form. 22 question whatsoever. 23 24 25 You write, "The A. Just a moment. I'm going to There's no foundation to that The way I would write these memos, I would write what people told me, so I assume they said that. Q. (By Mr. Anderson) Who told you that criminal www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 80 1 statute of limitations would run out in two and a half 2 years? 3 A. I believe it was the parents. 4 Q. You go on to write, "The mother and father 5 are considering reporting this to the police." 6 makes you think that the parents told you that and not 7 some official or attorney for the Archdiocese? 8 9 10 A. What Because I would have written down what the parents told me. If somebody else told me that, I would have written that down. 11 Q. So you don't know -- did you do the 12 calculation of two and a half years on the statute of 13 limitations? 14 A. No. Q. Why do you believe that? 15 16 17 18 19 20 I believe that's what the parents told me. Do you have a memory of that? A. No, because I write down on things -- what people tell me, and that's what it says. Q. Well, the way this is written, first, the 21 statute of limitations does not run out for two and a 22 half years, which means this guy, if reported, could 23 be prosecuted, right? 24 25 MR. GOLDBERG: Objection. There's no foundation for that. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 81 1 2 Q. (By Mr. Anderson) Isn't that what it means, Archbishop? 3 MR. GOLDBERG: It could be -- there are many 4 statutes of limitations, as you well know, 5 civil/criminal. 6 MR. ANDERSON: This is criminal statute of 7 limitations. 8 A. I'm just stating what the parents told me. 9 Q. (By Mr. Anderson) Let's just talk about what 10 you wrote. 11 limitations does not run out for two and a half 12 years," what that means as you wrote it then was that 13 there were two and a half years in which this guy, 14 Adamson, could be prosecuted for the crime against 15 Riedle as reported above, correct? 16 17 Okay? When you write, "The statute of MR. GOLDBERG: Object to the form, no foundation. 18 A. Again, this is what the parents told me. 19 Q. (By Mr. Anderson) Is that a fair reading of 20 what you wrote, though? 21 A. I don't remember. I just wrote what they 22 said, and I have no reason to doubt that's what they 23 said. 24 25 Q. Well, you do not attribute the first sentence to the parents here; do you? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 82 1 A. I do not. 2 Q. Okay. 3 So you have no memory of what the parents told you; do you? 4 A. Perhaps that's what Paul Ringsmuth said. 5 Q. Okay. So let's get to what you do remember. 6 You don't remember how you had learned that statute of 7 limitations was two and a half years? 8 A. Somebody told me. 9 Q. Okay. 10 11 And you recorded that, but you don't know who told you that, correct? A. Well, in reading the memo, whoever told me, 12 this is what was said. 13 Mr. Ringsmuth or the parents, that I don't remember. 14 Q. Okay. Whether it was this I just want to know if you know -- if 15 you calculated that, and if you didn't, if you can 16 remember who calculated it that led you to record it 17 as it is written here, and your answer to that 18 question is "I don't know who did the calculation that 19 caused me to record it as I did," correct? 20 21 MR. WIESER: witness' testimony. 22 23 24 25 Objection, misstates the MR. GOLDBERG: Join in the objection and object to the form. A. What I wrote is what I was told. As I read through the memo, obviously having not seen it for a www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 83 1 long time, I thought I was recording the parents, but 2 in your redirecting me to the first paragraph, it 3 could have been this Mr. Ringsmuth. 4 Q. (By Mr. Anderson) Okay. 5 A. I don't remember. 6 Q. Yeah, and that's what I'm getting to. You 7 really don't know who told you the statute of 8 limitations of a criminal prosecution was two and a 9 half years? 10 A. Well, I'm assuming it's either Ringsmuth or 11 the parents, and it appears now, as I reread it, it 12 looks like it was Ringsmuth. 13 Q. But you don't have a memory of that? 14 A. I have no memory. 15 Q. Okay. And the information contained in this 16 memo obviously was shared with Archbishop Roach at 17 that time. 18 19 20 A. Who else? I don't remember, other than he's listed, so I assume it went to him. Q. Okay. And he also named Paul Ringsmuth and 21 Janet and John Riedle at the bottom. 22 it was sent to them or you just put that there for 23 contact information? 24 25 A. I don't remember. Do you know if I don't think I sent it, because if I sent it, there would be something up www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 84 1 above. 2 Q. Okay. That's what appeared to me, but I 3 wanted to ask you. 4 and father are considering reporting this to the 5 police." 6 You go on to write, "The mother What led you to write that? A. Either the parents or Mr. Ringsmuth told me 8 Q. And did you report this to the police? 9 A. I did not. 10 Q. Why not? 11 A. It didn't occur to me it was my 7 12 13 14 that. responsibility. Q. This was a counselor from the prison. Did you consider yourself to be a mandatory reporter? 15 A. No. 16 Q. Did you ever consider yourself to be a 17 mandated reporter while in the Archdiocese of 18 St. Paul/Minneapolis? 19 A. 20 No. MR. GOLDBERG: Is this a good time to just 21 check in with you to see how you're doing, what your 22 time is? 23 MR. ANDERSON: Sure. 24 a while. 25 give me some idea as to how -- We've been going quite Why don't we take a lunch break? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Can you Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 85 1 2 MR. ANDERSON: talk about it. 3 4 Well, let's take a break and VIDEOGRAPHER: The time is 12:20. now off the record. 5 (Whereupon a break was taken.) 6 VIDEOGRAPHER: 7 The time is 1:29. We are now back on the record. 8 9 We are Q. (By Mr. Anderson) All right. Archbishop, right before we went on the record, you had -- your 10 counsel had asked the last question be read back, and 11 it was, and then you said you wanted to respond to the 12 last question asked before the break. 13 wanted to respond to and/or say? 14 A. What was it you When you asked the question, I was still 15 thinking of the earlier time period. 16 a date, but there was a time when all priests became 17 mandatory reporters, and the only reason I remember 18 that is because there was a lot of discussion about 19 priests and Bishop relationships and things, but I 20 don't remember when it was, so there was something. 21 Q. I can't tell you So do you know when it was you yourself were 22 considered to be a mandatory reporter under Minnesota 23 law? 24 A. I don't remember the date. 25 Q. Do you know if it was before or after you www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 86 1 prepared the exhibits that we identified earlier as 2 304, 319 and 301 in the 1980s? 3 A. I don't remember. 4 Q. Did you ever get training after you became a 5 mandatory reporter on what constitutes a report, a 6 requirement under law? 7 A. I don't remember any training that I had. 8 The first thing that comes to mind was when the 9 Bishops met in 1996 and talked about sexual abuse. 10 There could have been something before that, but I 11 don't remember. 12 13 Q. Was that the Minnesota Bishops or the Catholic Conference of Bishops? 14 A. Conference of Bishops. 15 Q. And that was at the annual meeting in '96? 16 A. I think it was 1996. 17 Q. You also attended a meeting of the Catholic 18 Conference of Bishops in Collegeville at St. John's, 19 actually, in 1985, because you were then an auxiliary, 20 correct? 21 22 23 24 25 A. went. I don't remember that meeting. Perhaps I I did not go to all the Bishops' meetings. Q. Well, you had been installed as an Auxiliary Bishop in 19 -A. January of '84. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 87 1 Q. -- '84. That meeting was in '85 at 2 Collegeville, St. John's. 3 that meeting at all? 4 5 A. No. Do you have any memory of The one I remember was 1996. I thought there was a meeting. 6 Q. And what do you remember being discussed 7 about sexual abuse, reporting requirements and the 8 like at the '96 meeting? 9 A. What I remember is some discussion about the 10 challenge that therapists had in understanding what, 11 you know, sex abuse was and the recidivism rate, which 12 is what we, of course, took as our advice in those 13 days. 14 there was, but I don't remember. 15 There may have been other things. Q. I'm sure But in 1996, you already knew, however, by 16 reason of your experience and the work you had done 17 with victims, offenders and the like, that sexual 18 abusers and the recidivism rate was very high, and 19 that was a disease or a disorder that really couldn't 20 be cured? 21 A. I did not know that. 22 Q. When -- go ahead. 23 A. I did not know that, but as a pastor, I was 24 25 becoming increasingly concerned. Q. When do you think you first came to the www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 88 1 realization or the knowledge that, you know, sexual 2 abuse, adults abusing kids, be it priests or adults, 3 was a disorder that one couldn't be cured, if you did? 4 A. I don't know if I ever knew it as a disorder 5 that couldn't be cured, but certainly by the '90s 6 there were more and more instances, and, in fact, I 7 remember one therapist who we had used before, in 8 fact, may even have been an expert witness -- I don't 9 know whether he was for us or against us, but he said 10 that therapists themselves didn't know in the early -- 11 the late '70s, early '80s, but I don't have a date on 12 that. 13 Q. All right. I have a date that might help 14 you with that by reason of -- let's look at Exhibit 15 101. 16 as you can see, it's a newspaper article. 17 February 16, 1987, and you're quoted in it, and on the 18 topic of cures and disabilities, the second page. 19 me direct you to a portion of it, and there's some 20 statements attributable to you, and then I'll ask you 21 about it. 22 you remember this article appearing in the news? 23 24 25 I'm putting before you Exhibit 101, and, first, A. It's dated Let First, by way of the background of this, do I don't. MR. GOLDBERG: Counsel, do you have a better copy of Page 1? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 89 1 MR. ANDERSON: No. 2 MR. GOLDBERG: Because it's illegible. 3 MR. ANDERSON: I know. 4 better copy. 5 Q. I don't have a (By Mr. Anderson) The headline of it is "A 6 Cover-up of Priest Sex Misconduct denied." 7 picture of you. 8 been a cover-up of sexual abuse pertaining to Adamson, 9 correct? There's a You denied at that time there had 10 A. Do you know what the date was? 11 Q. Yeah, February '87. 12 A. I don't remember the article, but -- 13 Q. Do you remember issuing a public denial of a 14 cover-up? 15 A. No. 16 Q. Had there been a cover-up? 17 A. Well, I think what we just discussed about 18 Adamson, he was certainly moved, but, again, they were 19 taking the word of counselors that this problem could 20 be cured. 21 cover-up, but I don't think people had the knowledge 22 at the time, and in many ways, we were the victims of 23 those we sent people to for treatment, and I didn't 24 like that, but that's the way it was. 25 Q. So, in essence, I don't think there was a You did have the knowledge in '87, though; www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 90 1 didn't you? 2 3 MR. GOLDBERG: Object to the form of the question. 4 5 Knowledge of what? A. I don't know if I knew the recidivism rate was that high then, but I found out at some point. 6 Q. (By Mr. Anderson) Let's look at the second 7 page of this article, and in the first column of the 8 second paragraph, let me read it, and you're quoted, 9 and I'll ask you a question. It says, "Acting under 10 the determination that the incident was, quote, 11 'inappropriate behavior,' unquote and not sexual 12 abuse, Carlson said the Archdiocese decided to ask 13 Adamson to sign a written agreement that he would have 14 no contact with young people." 15 do you remember telling the "Pioneer Press" that? 16 A. I don't. 17 Q. Is that true? 18 MR. GOLDBERG: 19 question. 20 told them that? 21 22 Q. Is what true? My first question is Object to the form of the His statement or that he (By Mr. Anderson) Is that statement, as reported, true? 23 A. True that I said it? 24 Q. That you said it or that you did what you 25 said? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 91 1 2 A. I don't remember saying it, so I don't know whether it's true or not. 3 Q. You go on to be quoted as saying, "'If there 4 had been a case of sexual abuse at that time, rather 5 than just inappropriate behavior, I think we would 6 have removed him,' unquote, Carlson said." 7 say that? Did you 8 A. I don't remember saying it. 9 Q. Do you deny saying it? 10 A. I just don't remember. Q. That statement belies the earlier documents 11 I can't confirm or deny. 12 13 we looked at about him having admitted to criminal 14 sexual conduct; doesn't it? 15 MR. GOLDBERG: I'm going to object to the 16 form. It's argumentative, and, secondly, you're 17 building off a Page 1 of the document that's 18 illegible, so -- 19 20 MR. ANDERSON: that's what I'm reading from. 21 22 23 Well, Page 2 isn't, and MR. GOLDBERG: Oh, I understand you're reading from Page 2, but it relates to the article. Q. (By Mr. Anderson) Doesn't this public 24 statement made by you in 1987 contradict the documents 25 we reviewed in 1980 and '84? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 92 1 A. My difficulty is I don't remember what I 2 said, and there's been enough instances in my life 3 where what I was quoted as saying was not what I 4 actually said to the reporter, so I can't say with any 5 accuracy. 6 Q. Let's go to the second column of this Page 7 2, Archbishop, and I will read what is quoted here, 8 and it looks like in quotation marks attributable to 9 you. "'It's our policy today that there really is no 10 cure for someone with the disease of pedophilia, but 11 only a chance for some recovery,' unquote, Carlson 12 said." So is that something you said? 13 A. It's possible. I don't remember saying it. 14 Q. Was that the policy, as represented in this 15 article and made to the people by the Archdiocese 16 through you and others in 1987? 17 A. I don't remember what I said to the 18 reporter, so I don't remember whether I'm quoted 19 accurately or not. 20 I would agree with that statement. But certainly as I sit here today, 21 Q. Okay. 22 A. I don't remember any policy. 23 Q. When do you remember there was first a And was it the policy? 24 policy implemented in the Archdiocese of St. Paul/ 25 Minneapolis that prohibited the Archbishop and his www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 93 1 officials from continuing any priest in ministry that 2 had been credibly accused of abuse? 3 4 A. Again, I thought there was something in 1996, but I don't -- 5 Q. But you're not sure? 6 A. Not sure. 7 Q. If this quotation attributed to you is made 8 in quotes, it would appear -- and this is Clark 9 Morphew, who is a religion reporter. 10 Do you remember him? 11 A. Uh-uh. 12 Q. Well, in any case, you don't deny that there 13 was such a policy if you made this statement. 14 just saying you don't remember having made it today, 15 correct? 16 A. I don't remember having made it. You're I also had 17 enough experiences with being misquoted, I can't 18 attest that that's exactly what I said or not. 19 Q. Did you intend, at the time you were 20 interviewed by Clark Morphew and this article was 21 written, to try to assure the parishioners that you, 22 an official of the Archdiocese, and the Archbishop 23 wanted people to believe that their kids were safe? 24 25 A. I don't remember any intention that I attributed to this. www.midwestlitigation.com I have no memory of that. MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 94 1 Q. Did you make a representation on behalf of 2 the Archdiocese and the Archbishop that there were no 3 priests in ministry who had offended? 4 5 MR. GOLDBERG: Object to the form. What period of time are you talking about? 6 MR. ANDERSON: 1987. 7 A. I don't remember doing so. 8 Q. (By Mr. Anderson) Were there priests in 9 10 ministry who had offended in 1987, that you knew to have offended and continued in ministry? 11 12 A. I don't remember, because I don't remember whether Tom Adamson was still in ministry or not. 13 Q. But other than Adamson, any that you knew 15 A. Nothing comes to mind right now, but -- 16 Q. So you obviously had -- if the statement is 14 of? 17 attributable to you, you did have some information 18 about "It's our policy today that there really is no 19 cure for someone with the disease of pedophilia, but 20 only a chance for some recovery." 21 statement was made by you. 22 quoted by you. 23 that from somebody. 24 that in 1987 there really is no cure for someone with 25 the disease of pedophilia? www.midwestlitigation.com Let's assume that Let's say it's correct and Thus, if it is so, it means you got From whom would you have learned MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 95 1 A. 2 anyone. 3 Q. I don't remember. I can't attribute it to Let's go to Exhibit 305. Exhibit 305, 4 Archbishop, is dated July 9, 1984. 5 Archbishop Roach from you, as Bishop Carlson. 6 subject is Father Thomas Adamson, and this is a memo 7 you've seen before and was prepared by you, correct? It's a memo to The 8 A. Correct, it was prepared by me. 9 Q. And it was prepared in much the same way you 10 had prepared the other memos, where you took some 11 notes and then typed it out yourself or had it typed 12 by somebody else or what? 13 A. I don't remember whether I typed it or 14 somebody else, because it doesn't quite look like the 15 same typewriter. 16 Q. It looks like a little better typing. 17 A. Yeah, probably somebody else. And I would 18 guess that the notes were mine, and if Kevin McDonough 19 was there, he may have made notes, too. 20 remember. 21 Q. I don't At the top, Archbishop, it says "Strictly 22 Confidential," underlined. 23 and for whose eyes was this intended to be used and 24 seen only? 25 A. What did that then mean It would have gone only to the Archbishop. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 96 1 Q. That's what that means? 2 A. That what I would intend it to mean. 3 Q. And then at the second page, there's a 4 little bit of an initial there. Is that yours? 5 A. It is. 6 Q. So you prepared the memo? 7 A. I may have prepared it. 8 9 may have had some input into it. Q. Fair enough. Father McDonough I don't remember. I could probably -- I could 10 ask you about the July '84 thing and what happened, 11 and your answer would be -- 12 13 14 A. As I read it, this would probably be what happened. Q. Okay. Yeah, but first, independent of 15 reading this, your answer would be what happened on 16 that date? 17 18 MR. GOLDBERG: look at it? 19 20 21 MR. ANDERSON: Q. (By Mr. Anderson) First I want to see if you MR. GOLDBERG: Well, he can't tell you unless he reads it. 24 25 Yeah. have an independent memory of the memo. 22 23 Are you asking him not to MR. ANDERSON: Q. No. (By Mr. Anderson) Before you read it, I want www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 97 1 to ask you if you remember what happened at that time 2 and/or what you did about it. 3 don't remember it," then we'll look at the memo. 4 A. I don't remember it. 5 Q. Fair enough. And if you say, "I Let's look at the memo. It 6 states, "On Friday, July 6, 1984, Father Kevin 7 McDonough and I met with the Reverend Thomas Adamson 8 concerning certain charges which had been made by Greg 9 Riedle, which currently is an inmate at the St. Cloud 10 Reformatory." 11 So this reflects in your own hand that you 12 had a meeting on this date with then Kevin McDonough, 13 who is one of the officials helping you advise the 14 Archbishop in how to handle the sexual abuse 15 allegations made against Adamson, correct? 16 17 18 A. Well, it says we were both there, so obviously we were both there. Q. And tell me what you remember about that 19 meeting with yourself, Kevin McDonough and Tom 20 Adamson. 21 22 23 A. Outside of the memo, and I have no reason to believe this isn't inaccurate, I have no other memory. Q. The second paragraph, you write, "In the 24 counseling process at St. Cloud, it has become evident 25 that Gregory was also sexually abused from 1978 to www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 98 1 1982." 2 3 A. It's something I recorded for this memo, Q. And that does not refresh any additional yes. 4 5 That's something you recorded then? recollection of this meeting? 6 A. It does not. 7 Q. You then go on to state, "I asked Father 8 Adamson about this, and he admitted, and, in fact, he 9 had abused the boy during that period of time." 10 Did I read that correctly? 11 A. Correct. 12 Q. So you and McDonough asked Adamson if he had 13 abused Greg Riedle, and he admitted having done the 14 crime against the kid, correct? 15 A. Correct. 16 Q. And you so record that? 17 A. As I record it is how I would have been Q. You write, "I did not go into the sexual 18 19 told. 20 activity, but Father Adamson agreed that it probably 21 would be first degree sexual contact." 22 That's what you wrote? 23 A. That's what I wrote. 24 Q. And you also knew that when first degree 25 criminal sexual conduct is written and recorded, that www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 99 1 is the most serious of the sex crimes against a child. 2 You know that? 3 A. Correct. 4 Q. And he admitted that to you and Kevin 5 McDonough? 6 A. 7 or I did. 8 time. 9 Q. I don't remember if Kevin asked the question If I wrote it, that's what was said at the And when he admitted having done this to 10 this kid, did you ask Adamson about his sexual history 11 and whether he had committed sexual -- criminal sexual 12 conduct against other kids? 13 A. It's -- I don't remember whether I asked 14 that question or not, but it's not recorded here, so I 15 assume I didn't. 16 17 18 19 20 Q. Isn't that something you would have wanted to know? A. I don't remember the conversation, so it's impossible to say what I was thinking at the time. Q. Well, if he's admitting to having abused 21 this kid and it's crim sex, first degree crim sexual 22 conduct, and you did not record that you asked him the 23 question on this admission, did you at any time ever 24 ask Adamson his sexual history and if he had admitted 25 to having abused any other kids since he had been a www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 100 1 priest, ordained in '58, and continued into the 2 Archdiocese until the '80s? 3 A. I don't remember whether I did or didn't. 4 Q. Don't you think that's something some 5 official of the Archdiocese should have asked this 6 priest? 7 A. 8 9 At the time, I don't know whether someone did or didn't, but what's here is what I did. Q. Because it's not in the document, you're 10 saying you didn't ask the question and, therefore, 11 didn't get the answer. 12 by you then, upon his admission that he had committed 13 criminal sex? 14 15 16 17 18 MR. GOLDBERG: question. A. Why wasn't that question asked Object to the form of the It calls for speculation. Well, obviously, this was 30 years ago, so I really don't remember the conversation. Q. (By Mr. Anderson) Oftentimes we don't ask 19 questions we don't want to know answers to, 20 Archbishop. 21 want -- the Archdiocese really didn't want to know how 22 bad it was? 23 24 25 Do you think that's the reason we didn't MR. GOLDBERG: A. Object to the form. I think, given the status of things in '84 with counselors and other people telling us things www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 101 1 were okay, I don't know if it occurred to me. 2 Q. (By Mr. Anderson) You since learned that he 3 had a long trail of victims that predated Greg 4 Riedle's abuse; haven't you? 5 6 A. Certainly at the time of the trial or after Q. The trial revealed that there had been a that. 7 8 long stream of victims going back to the early '60s; 9 didn't it? 10 11 A. I remember there were other victims. 12 13 I don't remember what it revealed. Q. And it also revealed that there was abuse after 1984; wasn't there? 14 A. I don't remember that, but -- 15 Q. When you learned at the trial there had been 16 a long history of abuse by him in '84, did you ever 17 ask yourself the question, "Why didn't I ask when I 18 learned this," and "Why didn't I do more?" 19 A. I think in everything we do, once we've 20 experienced it, we reflect on our actions and we ask 21 what we can do better. 22 Falls and other places, I think we did a pretty good 23 job. 24 25 Q. Certainly as I look at Sioux I'm looking at '84 now. Do you think that there was a practice at that time that there was a www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 102 1 concern about scandal that sometimes made the 2 officials or the Archbishops have a tendency to err on 3 the side of protecting the priests and avoiding 4 scandal? 5 A. Well, in this memo, for instance, it's the 6 counselor that's talking about reporting it. 7 Apparently, he didn't, but he was talking about it. 8 don't know why he didn't either. 9 Q. I The fourth paragraph is, "I asked Father 10 Adamson to see Dr. Gendron and recommended to him that 11 he obtain the criminal history." 12 Mr. Ted Collins or Mr. Andrew Eisenzimmer as lawyers 13 for him; did you not? 14 15 16 17 A. And you recommended Again, if I said I did, I probably did. I don't remember doing it. Q. And the Archdiocese paid for his lawyers; did they not? 18 A. I don't remember that we did or didn't. 19 Q. The fifth paragraph, you write, "Further, I 20 told Father Adamson that I will be in contact with him 21 after I visited with the Archbishop and Bishop 22 Watters." 23 visit with both the Archbishop and Bishop Watters, 24 correct? 25 A. So you recorded here that you intend to That's what it says. www.midwestlitigation.com And I have no reason MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 103 1 to doubt it if it's written here. 2 3 Q. with Bishop Watters? 4 5 So how many meetings did you actually have A. I don't have any remembrance of any meetings, but obviously I did if it's here. 6 Q. When I confronted you with the statement 7 that Bishop Watters made at his deposition that he 8 attributed to you that you advised him that the best 9 thing he could do in a deposition is not remember, you 10 said you never had any conversations with Watters. 11 fact, this reflects that you had not only 12 conversations, but you had meetings with him, correct? 13 A. Based on my memory, I said that I didn't 14 remember having any conversations with him. 15 Obviously, this says that I did. 16 Q. And today, do you remember pertaining to 17 this memo, as you see it, what came in the meeting 18 with Watters and Roach? 19 20 MR. WIESER: 23 Objection, misstates the evidence in the Exhibit 305. 21 22 In Q. have. (By Mr. Anderson) Well, that you intended to Do you recall having such a meeting? A. I do not recall having such a meeting. I 24 assume from the document that I reported what I had 25 been told. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 104 1 Q. The second page under "Recommendation," this 2 is a recommendation you are making as an Auxiliary 3 Bishop to the then presiding Archbishop Roach, 4 correct? 5 A. Correct. 6 Q. And under "Recommendation," you write, "It 7 is my recommendation, given the seriousness of our 8 exposure, that the Archdiocese posture itself in such 9 a way that any publicity will be minimized." 10 First, those are your words; weren't they? 11 A. If they're written here, they're my words. 12 Q. And that was your recommendation? 13 A. Apparently at the time, that was my 14 recommendation. 15 Q. How does that make you feel reading that and 16 the recommendation you made to the Archbishop at that 17 time? 18 MR. GOLDBERG: 19 question. 20 his feelings. 21 answer if you wish. 22 23 24 25 A. Object to the form of the We're not here to ascertain his opinion, We're here to get the facts. You can Obviously, based on some 25 years later, I would do it differently. Q. (By Mr. Anderson) Don't you think you should have done it differently then? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 105 1 A. I did what I did. 2 Q. Don't you think the Archdiocese made a 3 grievous mistake in trying to minimize publicity and 4 posture itself in the way it did? 5 A. I think counselors made mistakes. 6 people in general made mistakes. 7 Archdiocese made mistakes. 8 9 10 11 Q. I think I think the Don't you think that the Archdiocese has to take responsibility for its mistakes, because if it doesn't, it's destined to repeat them? A. I know that several times people -- I, as a 12 Bishop, have been told in many different places, you 13 know, if you call it best practices, and I think it's 14 in our best interest to do that. 15 Q. This recommendation about given the 16 seriousness of our exposure, when you use the term the 17 seriousness of our exposure, that means yours and the 18 Archdiocese's, correct? 19 A. I don't remember what I was thinking, but as 20 I read it now, I think I'm focusing on the Archbishop 21 and the Archdiocese. 22 Q. Is that exposure to go to jail? Were you 23 concerned about being sent to jail for you -- for 24 yours and the Archdiocese's failures at that time? 25 A. I never remember being concerned about going www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 106 1 to jail. 2 Q. Well, when somebody says given the 3 seriousness of our exposure, they're referring to 4 something. 5 climate change. 6 Is the consequence jail or publicity or scandal or 7 what? 8 9 It's not exposure to It's exposure to some consequence. MR. GOLDBERG: Object to the form of that question. 10 11 Exposure to what? A. Well, obviously, it would be scandal and also publicity. 12 Q. (By Mr. Anderson) Did you have concerns back 13 then, Archbishop, that as you wrote this, that 14 Archdiocesan officials could face some criminal 15 liability for their role in being complicit in 16 covering up or concealing the crimes by Adamson? 17 A. No, I don't remember I ever did that. 18 Q. Did you or any of the Archdiocesan officials 19 consult criminal lawyers about your exposure at this 20 time? 21 22 23 24 25 MR. WIESER: Object to the form of the question to the extent that it's a compound question. Q. (By Mr. Anderson) Did you seek legal counsel on whether -A. I did not seek any. www.midwestlitigation.com I'm not aware of MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 107 1 2 anybody who did. Q. Ted Collins, the lawyer you referred Adams 3 to -- Adamson to did end up representing Adamson. 4 you recall that? 5 A. I don't. 6 Q. Okay. Do The next sentence is, you write, "I 7 would recommend that in cooperation with Bishop 8 Watters, that Father Adamson be sent to the Paracletes 9 in Albuquerque or to the House of Affirmation." 10 Those are both treatment centers you knew to exist? 11 A. At the time, they were both. 12 Q. And they were often -- they were treatment 13 centers used to send up clerics with problems, not 14 just sexual abuse, but problems dealing with celibacy, 15 chemical dependency and other things; is that correct? 16 A. I think and also emotional issues. 17 Q. And were these both treatment centers that 18 had an affiliate with the Catholic Treatment Centers, 19 funded by Bishops? 20 21 A. I don't believe they were funded by Bishops, but they were Catholic Treatment Centers. 22 Q. Did you also utilize St. Luke's back then? 23 A. I don't remember if we did or didn't. 24 Q. You had earlier said that you felt that the 25 Archdiocese made mistakes in the handling of this www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 108 1 priest and others, but you seem to attribute more 2 responsibility on the therapist. 3 the therapist, upon which you relied, either at the 4 Service of Paracletes, Ken Pierre, Gendron or others 5 that appear in this record, bear as much or more 6 responsibility than the Archdiocesan officials who 7 made the choices they did? 8 9 A. Do you think that I think if you go back in history, I think the whole culture did not know what they were dealing 10 with. 11 fully understood. 12 administrators understood it. 13 realized it was the serious problem it is. 14 15 I think therapists didn't. Q. I don't think public school I don't think we Well, mandatory reporting laws went into effect across the nation in 1973, Archbishop. 16 17 I don't think we MR. GOLDBERG: I'm going to object to the form of that question. 18 MR. ANDERSON: Let me finish the question. 19 MR. GOLDBERG: Go ahead. 20 Q. I'm sorry. (By Mr. Anderson) And you knew at all times, 21 while a priest, having been ordained in 1970, it was a 22 crime for an adult to engage in sex with a kid. 23 knew that, right? 24 25 MR. GOLDBERG: I'm going to object to the form of that question now. www.midwestlitigation.com You You're talking about MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 109 1 mandatory reporting. 2 3 MR. ANDERSON: MR. GOLDBERG: conjunctive question. 6 7 10 another question. One doesn't -- Q. Objection heard. I'll ask Okay? MR. GOLDBERG: Go ahead. (By Mr. Anderson) Archbishop, you knew it was a crime for an adult to engage in sex with a kid? 11 A. 12 or not. 13 Q. 14 Well, you've asked a MR. ANDERSON: 8 9 I'll -- if you don't like the question, I'll ask another question. 4 5 Okay. I'm not sure whether I knew it was a crime I understand today it's a crime. When did you first discern that it was a crime for an adult to engage in sex with a kid? 15 A. I don't remember. 16 Q. When did you first discern that it was a 17 crime for a priest to engage in sex with a kid who he 18 had under his control? 19 A. I don't remember that either. 20 Q. Do you have any doubt in your mind that you 21 knew that in the '70s? 22 A. I don't remember if I did or didn't. 23 Q. In 1984, you are a Bishop in the -- an 24 Auxiliary Bishop in the Archdiocese of St. Paul/ 25 Minneapolis. www.midwestlitigation.com You knew it was a crime then, right? MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 110 1 A. I'm not sure if I did or didn't. 2 Q. Well, you're talking about criminal sexual 3 conduct in 1980, and you're talking about it again in 4 1984, so you knew that to be correct, right? 5 6 A. What I said, I said, and if I -- if I wrote it, I said it. 7 Q. Do you know what other treatment centers 8 were utilize by the Archdiocese besides the House of 9 Affirmation, Dr. Gendron, Ken Pierre Consultation 10 Services Center or the Service of Paracletes, to treat 11 priests who had offended against kids? 12 13 A. remember. 14 15 Q. That funding was done by the Archdiocese as a part of a substantive evaluation; is that correct? 16 17 There may have been others, but I don't MR. WIESER: Object, foundation, if you know. 18 MR. GOLDBERG: Let me just ask you for 19 clarification. I'm not sure. Are you talking about 20 the cost of treatment that was paid by the diocese? 21 MR. ANDERSON: Yes. 22 MR. GOLDBERG: Are you talking about 23 supporting the institution that was providing the 24 treatment? 25 MR. ANDERSON: www.midwestlitigation.com The cost of treatment. MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 111 1 2 MR. GOLDBERG: question that way? 3 4 THE WITNESS: No. I thought we were supporting the -- 5 6 Did you understand the MR. ANDERSON: Okay. Let me clarify the question. 7 Q. (By Mr. Anderson) The funding for the 8 treatment of the priests that was sent, in this case, 9 to House of Affirmation, the Service of Paracletes, 10 St. Luke's or any of the institutions where priests 11 who had offended or abused kids and they were sent for 12 treatment, is it correct to say the Archdiocese paid 13 for that treatment? 14 MR. WIESER: And before you answer, 15 Archbishop, it would be helpful just to have a time 16 frame on this question as well. 17 18 19 MR. ANDERSON: We're in the 1984 time frame now. A. I don't remember whether we did or didn't. 20 I was never involved with the financial aspects of 21 things. 22 Q. (By Mr. Anderson) You did get involved in 23 meeting with the counselors, however, to help to 24 determine whether or not an offender such as Adamson 25 could be returned to ministry, and you understood that www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 112 1 Adamson had given a waiver of his privilege for you 2 and other officials to consult with them? 3 MR. WIESER: 4 MR. ANDERSON: 5 6 Is that a question? No. It was a bad question, so I'm going to ask a good question. Q. (By Mr. Anderson) Did you understand that 7 you had access, as an official of the Archdiocese, to 8 his medical care providers, such as Gendron, Pierre, 9 Service of Paracletes? 10 11 12 13 14 A. I would talk to them, but usually if there was something written, it was sent to the Archbishop. Q. And did you ever meet with them personally concerning Adamson? A. I remember meeting with Dr. Gendron, and the 15 reason I remember meeting with him is it was in a 16 parking garage, and he died like that week later, so 17 it was just -- that kind of thing sticks in your 18 memory. 19 Q. Sure. So now that we've reviewed some 20 documents and explored some issues pertaining to 21 sexual abuse, what you knew and how you viewed it, let 22 me see if there's anything that has come to you in the 23 time we spent together that changes your answer to 24 this question. 25 At any time, Archbishop, while you were a www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 113 1 priest, a chancellor, an Auxiliary Bishop or an 2 official to the Archdiocese from 1970 to '94, did you 3 ever report any suspicions of sexual abuse by a priest 4 to any law enforcement agency directly? 5 A. 6 Dakota. 7 Q. The first report I remember is in South And so the answer to that question I just 8 gave you pertaining to your tenure in the Archdiocese 9 would have been, "No, I never reported it," correct? 10 A. I don't remember. 11 Q. And did you, during your tenure in the 12 Archdiocese of St. Paul/Minneapolis from '70 to '94, 13 ever order or advise any of your colleagues or 14 subordinates or other officials to report suspicions 15 of sexual abuse to law enforcement agencies? 16 A. 17 others. 18 but I don't know. 19 information, firsthand information, I'm pretty sure I 20 would tell them to report if they wanted to. 21 Q. I know I told parents. I may have told There may be examples that you're aware of, But if someone came to me and had But your answer to the question today is you 22 have no memory of having ever told anybody to report 23 to law enforcement or advised them to do so, correct? 24 25 MR. GOLDBERG: I'm going to object. I think that mischaracterizes his testimony given earlier this www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 114 1 morning. 2 3 MR. ANDERSON: Well, let me ask the question so that there's no ambiguity about it. 4 Q. (By Mr. Anderson) Did you, from 1970 to 5 1994, ever advise or order any of your colleagues or 6 other officials to make a report to law enforcement of 7 suspicions of sexual abuse by one of the clerics? 8 9 A. Q. MR. GOLDBERG: Well, that's a different MR. ANDERSON: No, it's not. question. 14 15 I'm talking about colleagues and officials. Now, priests and officials. 12 13 I think there's some memos we didn't see. 10 11 I know I told parents. I asked colleagues and officials. 16 MR. GOLDBERG: Well, I thought you -- 17 MR. ANDERSON: If you didn't understand the 18 question, I'm going to get him to understand it, and 19 then you listen to the question, too. 20 21 MR. GOLDBERG: You were talking about "or MR. ANDERSON: No, I said -- listen. anyone." 22 23 get on the same page. 24 it. 25 Okay? MR. GOLDBERG: www.midwestlitigation.com It happens. Let's Don't worry about I'm not worried about it. MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 115 1 Q. (By Mr. Anderson) Okay. The question is 2 from 1970 to 1994, did you ever order or advise any of 3 the Archdiocesan officials or priests to report 4 suspicions of sexual abuse? 5 A. I don't remember if I did or didn't. I 6 think I would have advised people that had firsthand 7 information to call the police if they wanted to or to 8 get the facts. 9 10 Q. done it? 11 A. 12 didn't. 13 Q. My question is, do you remember ever having Yes or no? As I said, I don't remember whether I did or Well, if you did, isn't that the kind of 14 thing you would remember, just like you remembered 15 Gendron's death -- 16 17 18 MR. GOLDBERG: A. 21 22 23 -- and the conversation you had with him about a week before? 19 20 Objection. MR. GOLDBERG: question. A. Object to the form of the It's argumentative. I think there may have been people I did. I can't call to mind a name right now. Q. (By Mr. Anderson) Have you discussed -- have 24 you discussed the current litigation or the handling 25 of -- other than with your lawyers, the handling of www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 116 1 the whole matter of the sexual abuse in the 2 Archdiocese with any of your former colleagues for the 3 Archdiocese? 4 Chancellor Eisenzimmer or anybody else? 5 6 That would be Kevin McDonough, now MR. WIESER: Misstates the facts with regard to your representation about Chancellor Eisenzimmer. 7 MR. ANDERSON: 8 Eisenzimmer. 9 Q. Oh, former Chancellor Sorry. (By Mr. Anderson) My question is have you 10 discussed the whole matter of this litigation and the 11 controversy surrounding that with anybody? 12 A. With the people you just mentioned, no. 13 Q. Who have you discussed it with besides the 14 15 16 lawyers? A. My sisters called me when it was in the paper. 17 Q. And anybody from the Archdiocese -- 18 A. No. 19 Q. -- or affiliated with them? 20 A. No. 21 Q. Nobody other than family, correct? 22 A. (Witness nodding head.) 23 Q. Correct? 24 A. Correct, family. 25 Q. No conversation -- what about Harry Flynn? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 117 1 Ever have a conversation with him about how sexual 2 abuse was to be handled or had been handled? 3 A. The only communication I've had with Harry 4 Flynn was inviting him to be on a committee three 5 years ago, and he never came. 6 Q. Okay. What about Kevin McDonough? Any 7 conversations following your departure from the 8 Archdiocese in '94, on the topic? 9 10 A. We may have had conversations. Nothing particular comes to mind. 11 Q. Anything recent? 12 A. No. 13 MR. GOLDBERG: Counsel, just for 14 clarification purposes, when was this case filed? 15 not sure he knows. 16 around this case, and I am not sure when this case was 17 filed. You keep referring to controversy 18 MR. WIESER: 19 MR. GOLDBERG: May of what year? 20 MR. ANDERSON: 2013. 21 MR. GOLDBERG: Oh, okay. 22 I'm May. So his questions are relating since May of 2013. 23 A. Only my sisters. 24 Q. (By Mr. Anderson) When you take a memo like 25 that marked "strictly confidential," and you said it www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 118 1 was for the Archbishop's eyes only, where would that 2 memo go once you prepared it for the Archbishop's eyes 3 only, having marked it "strictly confidential"? 4 5 A. Since you have it, I assume he sent it to the file. 6 Q. Okay. 7 A. Not necessarily. 8 Q. Was there a separate secret file maintained 9 10 11 12 13 And it would be sealed in the file? for confidential and scandalous material? A. At one time, there was. I -- I don't know when that stopped. Q. That was my next question. When did that practice stop? 14 A. I don't know. 15 Q. It was in place while you were a Chancellor; 16 was it not? 17 A. It was. 18 Q. And was it still in place while you were 19 20 auxiliary? A. I wouldn't have known, because I wasn't 21 Chancellor anymore. 22 to replace me. 23 Q. I think Kevin McDonough came in As Chancellor, what was the protocol for 24 scandalous material, and in what file was scandalous 25 material kept? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 119 1 A. Depending on what it was, in the old days, 2 years ago, I think anything that was considered 3 scandalous would be sent to the secret archives. 4 my time, other than memos marked strictly 5 confidential, it would go to the normal file. 6 Q. Under seal? 7 A. No, just -- 8 Q. Just like that? 9 A. Yeah. 10 Q. Okay. In So when you say a secret archive, 11 where was the secret archive, and who had access to 12 it? 13 A. It was in the same file room, I think. 14 Q. In the vault? 15 A. In the vault on the main floor. 16 Q. Of the Chancery? 17 A. Yes. 18 Q. And that secret archive, who had access to A. The Archbishop had a key, and the Chancellor 19 20 21 22 23 that? had a key. Q. And so the Archbishop Roach and you, as Chancellor, would have access to that -- 24 A. Or chancellors before me or after. 25 Q. Did you, at any time while a Bishop of the www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 120 1 Archdiocese, ever become aware of a compilation of a 2 list of offenders who had been accused or credibly 3 accused in the Archdiocese of St. Paul/Minneapolis? 4 A. No. 5 Q. Did -- to your knowledge, did anybody ever 6 7 try to compile such a list? A. I think lists may have been compiled in 8 dioceses at the time of the John Jay study. 9 aware of -- I am not aware of any list in the I'm not 10 Archdiocese, and I'm not aware of any list anywhere 11 before that. 12 Q. So nothing before 2002 in any case? 13 A. Whenever that was. 14 Q. Okay. Actually, the charter was 2002. You 15 attended the meeting of the Catholic Conference of 16 Bishops in 2002. 17 result of that, John Jay was commissioned, correct? They made a promise, and then as a 18 A. Yes. 19 Q. And then some data was supplied to them, and 20 then some lists were compiled sometime after that, as 21 you understand it? 22 A. 23 what we did. 24 Q. 25 In the Archdiocese of Sioux Falls, that's In the mid-'80s, let just say the '82, '83, '84 time frame, Archbishop, how much time do you think www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 121 1 was devoted to handling and dealing with allegations 2 of sexual abuse that were surfacing at that time in 3 your capacity? 4 A. I would -- just guessing. This is an 5 estimate. 6 would be well less than 10 percent of my time. 7 less than five percent. 8 Q. I have no -- I didn't keep a record. It Maybe And after you protested the assignment of 9 Adamson to another parish to Archbishop Roach and he 10 was assigned anyway, were you taken off the handling 11 of all sexual abuse cases, or just that one? 12 A. For a while, it may have been all of them. 13 If I was back on, there would be a document like this. 14 I don't know how long that was, though. 15 of Adamson. 16 Q. Okay. Certainly off So you can't be sure today whether 17 you were allowed to continue on other cases. 18 taken off that one? 19 A. 20 others. 21 Q. 22 23 For sure, I was taken off that one and maybe I was not very popular. Who besides the Archbishop with whom -- who else were you not popular with? A. 24 25 You were I don't know. You would have to ask them. MR. GOLDBERG: You mean present company excluded? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 122 1 MR. ANDERSON: 2 A. That I'm aware of, I was a priest, remember, 3 and then I was auxiliary. 4 auxiliaries. 5 I don't know. 6 Q. No, no. Maybe some of the I don't know. Maybe the Vicar Generals. I was just out of the loop for a time. (By Mr. Anderson) I'm going to go through -- 7 there's a couple of exhibits. 8 going to show it to you, and on it there's a stamp 9 that I'm going to ask you about and have you tell me 10 One is 275, and I'm about what that means. 11 And I'm handing you Exhibit 275. It's dated 12 April 7, 1992. 13 McDonough from Archbishop Roach. 14 a stamp that says "File, location, sex abuse. 15 4/7/92 by" -- whose initial is that? It's a memo to Bishop Carlson, Father At the top, there's Date, That would be -- 16 A. I don't know. 17 Q. So what is the stamp, and what does this 18 "Location, sexual abuse" file refer to here? 19 20 A. Q. 25 Do you know in '92, was there a separate sex abuse file being maintained somewhere? 23 24 I've never seen this stamp before, so whoever used it, I don't know. 21 22 I assume a file. A. I don't know. I was out of the loop at that Q. There's a little handwriting up at the time. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 123 1 right-hand corner of the stamp, and I can't read it on 2 the copy that I have. 3 handwriting? 4 A. I can't. 5 Q. Do you know who wrote, under "location," 6 "sex abuse"? 7 than the upper right-hand quadrant. Can you identify that Because it's a different handwriting 8 A. I don't. 9 Q. Look at Exhibit 276, and as she's handing 10 that to you, we've got the same stamp, and this one's 11 dated April 7, 1992, and it's a letter from Archbishop 12 Roach. 13 redacted, but the stamp, the same stamp appears. 14 the top, somebody writes in hand, "sex abuse." 15 handwriting is that? The recipient is blocked out, as we say, At Whose 16 A. I have no idea. 17 Q. And then again we see a "location, sex 18 abuse," and it's kind of the same thing of the earlier 19 document. 20 stamp is or where this file is and what this means? 21 22 23 A. Can you illuminate me on -- on what the I never saw the stamp, so I don't know. I also was not Chancellor at this time. Q. Let's go back to 275 for a moment. It's to 24 you from Archbishop Roach and to also Father 25 McDonough, and it says, "I met Blank on April 6, 1992. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 124 1 They received [sic] with me the long history of their 2 family association with Michael Kolar, Ken LaVan, Bob 3 Kapoun, Jim Finnegan, Joe Wajda, Tom Adamson and 4 Sister Sue Ahmiller." 5 history was and what you know about that. 6 MR. WIESER: Now, tell me what that long Just note it for the record 7 that that was a misstated -- the first line of that 8 paragraph. 9 MR. ANDERSON: Did I read it wrong? 10 MR. GOLDBERG: The word "reviewed." 11 MR. ANDERSON: Oh, okay. 12 again. I don't -- it was inadvertent. 13 14 MR. WIESER: MR. ANDERSON: 16 MR. WIESER: 18 19 20 21 22 23 24 25 He can -- the witness can obviously read it. 15 17 I'll read it Q. Is it okay? Yeah. (By Mr. Anderson) So the question is what can you tell me about this? A. I have absolutely no memory of ever receiving this. Q. Do you remember taking any action responsive to this at all? A. I was involved with parishes in St. Paul at the time. Q. This is '92. www.midwestlitigation.com You're an Auxiliary Bishop. MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 125 1 2 A. By that time, we had been divided into three regions. 3 Q. You had a vicariate. 4 A. I had a vicariate sample. 5 Q. But you had a history with Mike Kolar. You 6 had been a year behind him and had known him a long 7 time. 8 A. He was my spiritual director at one time. 9 Q. You also were a year behind him at the 10 11 12 seminary, right? A. A close friend. No, not a close friend. He was my spiritual director. 13 Q. Okay. 14 A. You don't usually choose close friends as 15 your spiritual director. 16 Q. And you know Kevin LaVan? 17 A. I followed him into a parish. 18 Q. And you had known Bob Kapoun? 19 A. He was another associate with me at 20 St. Raphael's. 21 Q. And Jim Finnegan, how did you know him? 22 A. I think I taught him in the seminary, one 23 24 25 course on marriage. Q. And what do you know about his -- what history he had that's being referred to here? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 126 1 A. I have no idea. 2 Q. So you know nothing about this document or 3 the history being referred to here? 4 A. 5 received it. 6 Q. 7 8 9 10 11 12 Based on the stamp, I don't think I ever Well, it's sent to you, though. Why would you say you didn't receive it? A. I have no memory of receiving it. believe I did receive it. I don't I don't know why my name's on it. Q. But the other document I showed you, you said you had no memory of receiving it either? 13 A. I didn't prepare this one. 14 Q. In here, Kapoun is mentioned. I'm going to 15 ask you some questions about him. 16 think you just mentioned this -- you were at 17 St. Raphael's with him in Crystal? In 1971 to '73 -- I 18 A. Correct. 19 Q. And did it come to your attention that 20 21 Kapoun had abused? A. I was informed after I left the parish by 22 the family of one person. I'm not sure if he's the 23 one that came forward or not. 24 Q. And what were you told? 25 A. I was told by the parents after he had been www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 127 1 removed from the parish that their son had been abused 2 by him. 3 Q. And what did you do? 4 A. They said they had called the diocese. 5 I didn't do anything. 6 Q. Did you call the police? 7 A. I did not. 8 Q. What year was that? 9 A. I don't remember. 10 Q. Was it while you were at St. Raphael's or 11 after you had been at St. Raphael's? 12 13 14 A. It was after I had left St. Raphael's in Q. How long after you left St. Raphael's -- 1972. 15 actually, I think you left St. Raphael's in '73; 16 didn't you? 17 A. I thought it was '72. 18 Q. In any case, how long after you left St. 19 20 21 22 23 24 25 Raphael's did you get this report? A. Well, I don't remember, because I was a social friend of the parents at some point. Q. What led you to believe that it had been reported to the Archdiocese? A. I believe they told me, but I'm not sure that -- they told me it had been reported, but I'm not www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 128 1 sure if they're the ones that reported it or didn't. 2 I just don't remember. 3 Q. Do you recall, Archbishop, that, in fact, 4 Kapoun was still in the parish, and it was the family 5 that was so upset because their son had been so -- had 6 been abused, and they were insisting that he be 7 removed? 8 9 10 Do you remember that? A. I don't remember if that was the family that talked to me. Q. Okay. Let's look at Exhibit 282. 11 dated April 12, 1984. 12 R. Roach. 13 by you, correct? It's It's a memo to Archbishop John It's from you. 14 A. That's correct. 15 Q. "Subject: That means it was prepared Father Robert Kapoun." It 16 states, "Bishop Bullock and I met with Father Kapoun 17 on Wednesday, April 11, 1984 to discuss his 18 relationship with Blank and the Blank family." 19 remember that meeting? 20 21 22 A. Do you I don't remember it, but if I wrote it here, it's what happened. Q. Okay. It goes on to state, "Blank is saying 23 that Father Kapoun invited him to the house rather 24 often. 25 period of about two years. They would give each other back rubs for a www.midwestlitigation.com Father would give Blank MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 129 1 haircuts. 2 shorts, and Father Kapoun was nude. 3 haircut, they would take showers together, washing 4 each other's back, and Blank said that Father Kapoun 5 would masturbate himself." 6 abuse; isn't it? He had the boy strip down to his underwear After the This is a report of sexual 7 A. Correct. 8 Q. And do you remember receiving this 9 information? 10 11 A. happened. 12 13 I don't remember it, but if I wrote it, it Q. Do you remember Father Kapoun's explanation for his conduct? 14 A. I don't. 15 Q. Let's look at the next paragraph. You 16 write, "Father Kapoun states that masturbation never 17 took place and that he has no problem with 18 masturbation. 19 mucous." 20 way out of that one? The boy described it as a flow of Do you remember Kapoun trying to wiggle his 21 A. I don't. 22 Q. It goes on to state, "The boy stated that on 23 several occasions he and Father would sleep in the 24 same bed, and Father Kapoun had to be very close to 25 him. This would happen even when there were other www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 130 1 2 3 4 empty beds in the same room." A. Do you remember that? If it's here -- if this what was said to me, I don't remember it. Q. You go on to write, "Father Kapoun would 5 take Blank to racquetball clubs and insist that they 6 take a sauna together in the nude." 7 like what Adamson had been doing, huh? It sounds a lot 8 A. There seems to be a similarity. 9 Q. On recommendation, this would be a 10 recommendation to the, again, Archbishop Roach, 11 correct? 12 A. Correct. 13 Q. You write, "The family insists that Father 14 Kapoun move. 15 county sheriff. 16 Bishop Bullock." If this does not happen, they will go to The father of the boy stated this to You recorded that, correct? 17 A. I did. 18 Q. And so Kapoun was moved; wasn't he? 19 A. I believe he resigned the parish and went 20 21 into treatment. Q. And when he resigned the parish, the people 22 in the parish were not told the real reason for his 23 resignation; were they? 24 25 A. I can't say for sure, because the case I talked about was another person who -- www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 131 1 2 Q. So it wasn't even this one. It was a different one? 3 A. Okay. 4 Q. And the one you were talking about was 5 before this? 6 A. I don't know if it was before or after. 7 Q. Well, this is '84. 8 This is about ten years after you left St. Raphael's, so -- 9 A. I don't remember. 10 Q. In any case, it was not reported to the 11 police because the Archdiocese moved Kapoun out of the 12 parish at the request of the father and in lieu of a 13 report, correct? 14 15 16 17 18 19 A. I've sent this to the archbishop. I wasn't involved after that. Q. It was the Archbishop that made the choice to move him out, the conscious choice to move him out? A. I don't know who made the final choice. The Archbishop is the only one that can act on the choice. 20 Q. But you made the recommendation. 21 A. I made these recommendations, yes. 22 Q. Let's look at Exhibit 245. This one is 23 dated April 13, 1984. 24 CC'd to Korf from Archbishop Roach regarding Kapoun. 25 You received this, I trust? www.midwestlitigation.com It's a memo to Bishop Carlson, MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 132 1 2 3 A. I'm just in the process of reading it. I don't remember receiving it. Q. Okay. It is written, in any case, to you, 4 and in the third paragraph, it states, "I'm asking 5 Bishop Carlson to call the father to assure him that 6 Father Kapoun is moving and ask the father now to drop 7 the whole situation." Did you do that? 8 A. No. 9 Q. How can you assert to me that you didn't do 10 that when you can't remember anything about this event 11 until you made that assertion? 12 A. Because I have no memory of asking anybody 13 to drop anything. 14 the police. 15 16 Q. In fact, I encouraged them to call Whose little initial is that at the bottom of that? 17 A. Archbishop Roach. 18 Q. Exhibit 250 reflects that Kapoun was then 19 assigned by the Archbishop to other parishes. 20 MR. GOLDBERG: Can we have that? 21 MR. ANDERSON: If you want to. 22 MR. GOLDBERG: Well, I don't -- it's not -- 23 24 25 it's your deposition, but you're referencing that. Q. (By Mr. Anderson) The records reflect that he was assigned to a parish in Heidelberg and www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 133 1 Lexington. 2 make any -- or any official of the Archdiocese make 3 any disclosure to the parishioners at Heidelberg or 4 Lexington or any other parish where Kapoun worked 5 about the history now known to the Archdiocese and the 6 reason for his transfer? 7 A. My question to you is did the Archdiocese I don't know. Other than the initial 8 involvement, I don't think I was involved, other than 9 the initial menu -- memo, and this was not in my 10 region, so I wouldn't have been involved in handling 11 anything. 12 Q. My question to you, then, is more global. 13 At any time, to your knowledge, at any time when a 14 priest was moved or transferred by reason of sexual 15 abuse, was there ever a public disclosure made to the 16 parish where he had been now newly assigned about the 17 history of abuse known to the Archdiocese, in your 18 experience? 19 20 MR. GOLDBERG: Object to the form. There's no time frame. 21 MR. ANDERSON: At any time. 22 MR. GOLDBERG: You're talking about during 23 his entire tenure in Minneapolis/St. Paul? 24 MR. ANDERSON: Yes. 25 MR. GOLDBERG: Archbishop or what? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 134 1 2 MR. ANDERSON: Q. Yeah. (By Mr. Anderson) Was there ever a 3 disclosure of sexual abuse to the parishioners where a 4 priest was assigned who had a history? 5 A. It's a difficult question to answer for this 6 reason, because we've done so much of that in the 7 other three dioceses where I've been in, and I don't 8 remember when it all started and when it all ended. 9 But we were most aggressive in the number of dioceses 10 I've been in in reporting people who had been abused 11 and going out to all the parishes. 12 to a case in 1941 or something. 13 14 Q. We even went back That was in Sioux Falls you're talking about. 15 A. But I remember -- I can't sort it all out. 16 Q. Okay. I have to direct your attention now 17 to the Archdiocese of St. Paul/Minneapolis, you know, 18 which brings you up to 1994. 19 Archbishop, can you think of any instance where the 20 Archdiocese made a disclosure to a parish and those in 21 it concerning a priest being assigned to that parish 22 who had a history of sexual abuse, such as Kapoun or 23 Adamson or anybody else? 24 25 A. In that time, I wasn't involved in any of those actual assignments, so I don't know. www.midwestlitigation.com I do know that I went MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 135 1 out to parishes before I left the Archdiocese, at 2 least one or two cases, and I had told them that the 3 priest had abused. 4 Q. When was that? 5 A. I don't remember the year, but it was the 6 parish by the Mendota Bridge. 7 Q. What priest? 8 A. I think it was Turner. 9 Q. Any others in which you either made a 10 disclosure to any of the parishioners or, to your 11 knowledge, the Archdiocese made any disclosure to 12 parishioners who are now being -- having a priest 13 assigned to a parish who had a history of having 14 offended? 15 16 A. The one I mentioned comes to mind. No others do. 17 Q. In the case of Kapoun, look at Exhibit 246. 18 It's dated 1987. 19 St. Luke's or St. Bernardine Clinic from Frank 20 Valcour; is it not? 21 A. And this is a letter to you from I don't remember ever seeing this, so I'd 22 have to read it to see, or I'll check the name at the 23 end. 24 25 Q. Okay. Well, it's addressed to you, in any case? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 136 1 A. I see that. 2 Q. Do you remember sending Kapoun to see 3 Valcour? 4 A. I don't. 5 Q. Beyond what we have covered, do you have any 6 independent memory of how you handled Kapoun or what 7 you did or recommended to the Archbishop to do beyond 8 what has been covered? 9 A. No. 10 Q. Do you remember that Kapoun was diagnosed 11 with ephebophilia? 12 A. I do not. 13 Q. Do you remember he was identified as a risk 14 of harm to children? 15 A. I don't remember that either. 16 Q. Do you remember the Archbishop permitting 17 him to continue in parishes without warning or 18 disclosure to the parishioners about the diagnosis or 19 the risks known? 20 A. I don't. 21 Q. Do you know what ephebophilia is? 22 A. Ephebophilia, I believe, is the sexual 23 24 25 attraction to teenagers. Q. Ephebophilia and pedophilia are often interchanged in nomenclature; aren't they? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 137 1 2 A. I don't think ephebophilia is very well understood. 3 Q. It's more in the medical community? 4 A. Uh-huh. 5 Q. Yes? 6 MR. GOLDBERG: What? 7 MR. ANDERSON: The medical community. 8 MR. WIESER: 9 10 I didn't -- Foundation. Objection, foundation. Q. (By Mr. Anderson) I'll direct your attention 11 to Exhibit 247, Archbishop. 12 pulls it out -- June 1st, 1987. 13 Archbishop Roach from you, Bishop Carlson, regarding 14 Reverend Robert Kapoun. 15 confirmation at Heidelberg yesterday, I met with 16 Father Bob Kapoun concerning his report from the 17 St. Luke Institute in Maryland." 18 just referred you to. It's dated -- as she It's a memo to It begins by stating, "After That's the report I 19 A. Okay. 20 Q. And do you remember this? 21 A. I don't. 22 Q. Okay. Look at Item No. 2. You write to 23 Archbishop Roach, "Father Kapoun will meet with me 24 every three months." 25 A. Were you required to do that? I don't remember if the Archbishop told me www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 138 1 or not, but it's there. 2 Q. Did you do that? 3 A. I don't remember. 4 Q. And was that to do -- to supervise him, to 5 6 7 8 9 10 keep him from re-offending? A. I assume the Archbishop asked me to do this. I don't remember what he had in mind. Q. In 1996, the case of Dale Scheffler vs. the Archdiocese of St. Paul/Minneapolis went to trial. Did you testify in that? 11 A. I don't think I did. 12 Q. I'm going to ask you some questions about 13 Father Ken LaVan, who is another priest mentioned in 14 that document. 15 MR. GOLDBERG: Which document? 16 MR. ANDERSON: It was an earlier document 17 where there was a number of priests listed. 18 LaVan -- 19 MR. GOLDBERG: Oh, 275? 20 MR. ANDERSON: Yeah. 21 MR. GOLDBERG: Okay. 22 Q. Ken (By Mr. Anderson) Did it come to your 23 attention in 1988 that he had abused two teenaged 24 girls? 25 A. I don't believe so. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 139 1 Q. Did you ever learn that he had abused kids? 2 A. I don't believe I ever did, but, again, 3 there may be a memo. 4 Q. Let's look at Exhibit 33, and it is dated 5 later in time, but makes a reference back in time, and 6 the exhibit, just for the purposes of brevity, let me 7 represent to you is to Archbishop Flynn, Pates, Sister 8 Dominica, Andrew Eisenzimmer from Kevin McDonough. 9 Now, it's dated November 3rd, 2005, but it refers back 10 to a history now being referred to, so you may know 11 something about, so let me direct your attention to 12 that. 13 written by McDonough, "It embarrasses me to 14 acknowledge once again a lapse in memory on my own 15 part. 16 about his boundary violations with adult females, I 17 had forgotten that there were two allegations in the 18 late 1980s concerning sex involvement with teen-aged 19 girls." In the middle of the second paragraph, it is Although I have dealt with LaVan for many years 20 My question to you is do you know anything 21 about LaVan's sexual involvement in the mid-'80s with 22 teen-aged girls that Kevin McDonough is referring to 23 here? 24 25 A. Kevin is referring to the late '80s. I have no knowledge. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 140 1 2 Q. Okay. Do you recall sending LaVan to Gendron? 3 A. I don't. 4 Q. Let's look at Exhibit 251. This would be a 5 letter from Joe Gendron dated February 14, to you, 6 "The Most Reverend Bishop Robert Carlson" and 7 regarding Father Kenneth LaVan, and begins by stating, 8 "Dear Bishop Carlson, I saw Father Kenneth LaVan for 9 psychiatric evaluation and had Dr. Paul Arnold see 10 him for psychological testing." 11 you? You got this; didn't 12 A. I don't remember getting it. 13 Q. Do you have any memory of, or did you ever 14 take any action concerning LaVan, either by sending 15 him to St. Luke's or returning him to ministry? 16 A. I don't remember doing that. I notice this 17 is with an adult woman. 18 two teen-aged girls, so I'm a little bit confused. 19 Q. Yes. Before you were talk about Kevin McDonough is referring to him 20 having had a history with -- inappropriate conduct 21 with adult women, but also the two teen-age girls. 22 This one refers to adult women, correct? 23 A. It says that, yes. 24 Q. Do you recall him being identified as 25 dangerous? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 141 1 A. I don't. 2 Q. Look at Exhibit 252. It's dated 3 February 25, 1986, a memo to Archbishop Roach, Father 4 Michael O'Connell and Father Bill Kenney from Bishop 5 Carlson. 6 sentence -- and that's your initial there; isn't it? Subject: Report from Dr. Gendron. The last 7 A. It is. 8 Q. The last sentence, you write, "Given the 9 liability it involves and the fact that this report 10 puts on notice, I think we will have to treat this as 11 a rather serious case." 12 What can you tell me about what you're 13 writing and why you're writing it and what's going on 14 here? 15 16 MR. GOLDBERG: Object to the form of the question. 17 A. I don't remember what went into writing it, 18 but I can say whatever I wrote was what the facts 19 were, and that's what I said, but I don't remember 20 anything more. 21 Q. (By Mr. Anderson) What about Father Hedrick? 22 Father Hedrick is a priest you knew because you had 23 been assigned as a co-pastor with him at some point in 24 time? 25 A. Yes. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 142 1 Q. And where was that parish at? 2 A. St. Margaret Mary's in Golden Valley. 3 Q. And what period of time? 4 A. I was there, I think -- I thought it was 5 6 7 1972 to 1975 or '76. Q. Well, '72 would have put you at St. Raphael's. 8 A. Well, we moved in the summertime. 9 Q. Okay. 10 So did you go from St. Raphael's to St. Margaret Mary? 11 A. Yes. 12 Q. And you were there with Hedrick? 13 A. I was. 14 Q. What did you -- did you learn that he had 15 abused? 16 A. 17 I don't believe I learned that when I was there. 18 Q. When did you learn it? 19 A. I believe I was told when I came to do his 20 funeral. 21 Q. And what year was that? 22 A. I don't remember. 23 Q. And before his death, it's your testimony Whatever year he died. 24 that you never received any information, reports or 25 had any knowledge that he, in fact, had abused youth? www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 143 1 A. I don't believe I did. 2 Q. And what did you learn after he died about 3 his history, and from whom? 4 A. I don't remember who it was from, but when I 5 was coming to do his funeral, they said we've got to 6 know this exists, and I thought it was somebody he 7 abused at the state training school. 8 remember. That's what I 9 Q. There was a training -- for boys? 10 A. Correct. 11 Q. And that's all you knew or heard? 12 A. That's what I heard, and it's the kind of 13 thing you hear sacristy as you're getting ready to say 14 Mass. 15 Q. 16 Jerome Kern. 17 Archdiocese? 18 A. Yes. 19 Q. And did you learn that he had been reported 20 I'll direct your attention to Father Kern, You knew him to be a priest of the to have abused two boys in 1969? 21 A. I don't remember that. 22 Q. Did you ever hear or learn that he had been 23 24 25 reported to have abused minors? A. I don't remember hearing that, but I would have written a memo if there was. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 144 1 Q. Let's look at Exhibit 293. Archbishop, this 2 one is dated June 15, 1987. 3 O'Connell. 4 Sexual Abuse of Minors by Father Jerome Kern." 5 begins by stating "On May 4, 1987, Bishop Robert J. 6 Carlson and Father Michael J. O'Connell met with 7 Blank." 8 the victims' names have been taken out of there to 9 protect their identity. It's from Michael J. The subject is an "An Incident of Alleged And it And presumably the victims or the families of It goes on to state, "They 10 asked to meet with us because of the publicity around 11 Father Adamson's sexual abuse of children case in the 12 Blank, brought the Blank events back. 13 vindictive about their motives. 14 they were never given any information by the 15 Archdiocese after Father Kern was moved from Blank, 16 and they wanted to know if he had been given any 17 treatment or had any follow-up after he was moved to 18 Edina in 1969." 19 tell me about this? 20 A. They are not Rather, they felt My question to you is what can you I have no memory of this at all. It says I 21 was there, so I guess I was there, but I don't 22 remember. 23 Q. The third paragraph down says, "Blank 24 indicated that he was picked up by Father Kern 25 allegedly to help him to swim, although Blank www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 145 1 indicated that he could swim very well without 2 assistance. 3 his hand inside his tight cut-off jeans and, in fact, 4 touched his genitals." 5 abuse? Blank alleges that Father Kern slipped You knew that to be sexual 6 A. I don't remember even hearing that. 7 Q. But in any case, at least as described in 8 this memo, to which you are at least in attendance, 9 sexual abuse is being described here, correct? 10 A. That's that I would assume, given the period 11 that Father O'Connell handled it from there. 12 remember. 13 Q. I don't And the last sentence of the next paragraph, 14 it goes on to state, "And touched his genitals on a 15 number of occasions." You knew that to be a crime? 16 A. I don't remember him saying it. 17 Q. But you knew a priest touching the genitals 18 of a kid to be a crime; did you not? 19 A. Yes. 20 Q. The second page, the top of it, it states, 21 "Father Kern did not deny that he did these things to 22 the boys." Do you remember that? 23 A. I don't. 24 Q. The third paragraph down says, "On June 5th, 25 1987, Bishop Robert Carlson, Father Michael O'Connell www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 146 1 and Father Jerome Kern met in Father O'Connell's 2 office." Do you remember that? 3 A. I don't. 4 Q. The next paragraph says, "When Father 5 O'Connell asked him if his motives and intentions were 6 as inappropriate as the events seemed to describe, he 7 admitted that his actions were totally inappropriate." 8 Do you remember that? 9 A. I don't. 10 Q. Did you or to your knowledge any official of 11 the Archdiocese report any of this as included in this 12 memo to any law enforcement agency? 13 14 15 A. I did not report it, and after this meeting, I wasn't involved. Q. The last paragraph -- the second-to-last 16 paragraph says, "Bishop Carlson told Father Kern that 17 he saw Father Kern enter a part of Loring Park in 18 Minneapolis at a time of night when a high degree of 19 homosexual soliciting takes place." 20 me about what you saw in that connection and what this 21 refers to? 22 A. What can you tell We were coming from a gathering of clergy of 23 St. Olaf's, and at the time I was at a parish in South 24 Minneapolis, and I forget the street that you drive 25 around the park to get to, but it's where the Guthrie www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 147 1 used to be, and then you head south. 2 Q. So what did -- what did you see? 3 A. I saw him walking into the park. 4 Q. I'm going to refer to Exhibit 133, and it is 5 a 1987 -- excuse me, 1993, the file of Jerome Kern 6 from Kevin McDonough. 7 Abuse by Alan Michaud." 8 page, you are copied on this. 9 having seen it? 10 A. No, I don't. 11 Q. Okay. The subject is "A Report of And you'll see at the second Today, do you remember This document reports sexual abuse, 12 and McDonough, given the fact that there's some 13 publicity, makes a statement to the parish. 14 become aware of statements being made to the parish at 15 that time? 16 17 A. No. Did you This would have been Bishop Sharon's area, so I wouldn't have been involved. 18 Q. Alan Michaud made a complaint similar to 19 that that was read before that Kern put his hand on 20 his genitals. 21 Roach and Kevin McDonough represented to the parish 22 that there had been no earlier accusations concerning 23 Kern? Did you become aware that Archbishop 24 A. I did not. 25 Q. Did you become aware that they led the www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 148 1 people in the parish in 1993 to believe that Kern had 2 been wrongfully accused by Al Michaud? 3 A. I did not. 4 Q. So you didn't know anything about the 5 6 7 8 9 Michaud matter and Kern? A. No. It was not in my area. I wouldn't have been involved. Q. What about Jeub? Did you get involved with Jeub and allegations of abuse against him? 10 A. No. 11 Q. Unless there's a document that says I did. 12 Exhibit 260. 13 Exhibit 260 is a memo dated April 11, 1991, to 14 Archbishop John Roach, Bishop Robert Carlson and 15 Father Michael O'Connell. 16 right? Let's look at that for a moment, and So here we have a memo, 17 A. We do. 18 Q. And the topic, it's from McDonough, and it's 19 "Another alleged victim of Father Richard Jeub." 20 you remember this, Archbishop? Do 21 A. I do not. 22 Q. You don't dispute that the memo was sent to 23 you; do you? 24 A. 25 I don't dispute the fact that it lists that the memo was sent to me, but I have no memory of it. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 149 1 Q. In the second paragraph, it says, "First 2 this woman was a childhood friend and associate of 3 another young woman who, as a teenager, was also the 4 victim of some sexual misconduct on the part of Father 5 Jeub." Does that refresh your recollection? 6 A. It does not. 7 Q. On the second page, in the middle of the 8 paragraph, the third paragraph begins by stating, 9 "This is the first allegation I have heard that the 10 Archbishop had prior knowledge that Jeub exhibited 11 abusive or exploitive behavior. 12 knowledge could be demonstrated, it would indicate a 13 serious problem with our dealing with him in the late 14 1960s or early 1970s." 15 recollection about this? Clearly, if such Does that refresh your 16 A. It does not. 17 Q. Do you recall that Jeub -- and then the 18 third paragraph, at the end of the last sentence, it 19 states, "I am afraid, however, that Jeub's 20 recollection will be just as idyllic and inaccurate. 21 And it leads me to question the progress that he has 22 made in therapy." 23 So it's indicating here that Jeub is, like, 24 denying the abuse. 25 1994, serving the Archdiocese and even to today, is it www.midwestlitigation.com In your experience from 1970 to MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 150 1 your experience, Archbishop, that these offenders, 2 when confronted, usually deny the abuse? 3 A. Not all. 4 Q. But more often than not? 5 A. Many did. 6 Q. Yeah. 7 Many did. And you also met with a lot of victims too; haven't you? 8 A. I have, and continue to meet with victims. 9 Q. And in that experience, Archbishop, is it 10 fair to say that it's painful for you and painful for 11 the victims to even be discussing this? 12 A. It's painful for both of us. 13 Q. And is it also your experience, informed by 14 the many years in ministry and various -- when victims 15 come forward, oftentimes they don't report the abuse 16 at the time of it, that it takes them years to do so? 17 A. I have no sense of that in any, you know, 18 organized or official way. 19 different people, but I don't know. 20 Q. I think it's different for How many reports have you received at any 21 time where the abuse was recent? 22 the last year or two. 23 24 25 A. That means within Well, we had one in this Archdiocese about a year ago. Q. But other than that one, were there any www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 151 1 reports made to you where the abuse was recent in time 2 in contrast to all the others where the abuse was back 3 in time, and now the survivor was -- 4 5 A. The one I mentioned, but I just don't remember. 6 MR. GOLDBERG: I wonder is this a good time 8 MR. ANDERSON: Sure. 9 MR. GOLDBERG: Well, you know, I don't want 7 10 to -- you running out of time. 11 12 MR. ANDERSON: Oh, no. I think we should take a break. 13 14 That's most important. VIDEOGRAPHER: The time is 3:00 p.m. off the record. 15 (Whereupon a break was taken.) 16 VIDEOGRAPHER: 17 MR. ANDERSON: questions. THE WITNESS: 21 VIDEOGRAPHER: 22 the record. 23 Archbishop Carlson. 25 We are Archbishop, I have no further Thank you. 20 24 The time is 3:10. back on the record. 18 19 We are Thank you. The time is 3:10. We are off This concludes today's deposition of MR. WIESER: I have no questions for the Archdiocese. www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 152 1 2 MR. BRAUN: Winona. 3 4 And none for the Diocese of MR. WIESER: E-tran. Send the page to me. 5 MR. BRAUN: 6 MR. ANDERSON: 7 We want the condensed. 8 DVD. 9 waived.) 10 Condensed. I'll take the same. Everything. We want the E. We want the regular and HD (Signature not (WHEREIN, the deposition was concluded at 3:00 p.m.) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 153 1 CERTIFICATE OF REPORTER 2 3 I, Brenda Orsborn, a Certified Court 4 Reporter (MO CCR No. 914) and Certified Shorthand 5 Reporter (IL CSR No. 084-003460), do hereby certify 6 that the witness whose testimony appears in the 7 foregoing deposition was duly sworn by me; that the 8 testimony of said witness was taken by me to the best 9 of my ability and thereafter reduced to typewriting 10 under my direction; that I am neither counsel for, 11 related to, nor employed by any of the parties to the 12 action in which this deposition was taken, and 13 further, that I am not a relative or employee of any 14 attorney or counsel employed by the parties thereto, 15 nor financially or otherwise interested in the outcome 16 of the action. 17 18 19 20 ______________________ 21 Brenda Orsborn 22 23 24 25 www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 154 1 COURT MEMO IN THE CIRCUIT COURT, CITY OF ST. LOUIS TWENTY-SECOND JUDICIAL CIRCUIT STATE OF MISSOURI 2 3 DOE 1 4 5 vs. ARCHDIOCESE OF ST. PAUL AND MINNEAPOLIS, DIOCESE OF WINONA and THOMAS ADAMSON ) ) ) ) ) 6 7 8 9 10 11 12 13 14 CERTIFICATE OF OFFICER AND STATEMENT OF DEPOSITION CHARGES (Rule 57.03(g)(2)(a) & Sec. 492.590 RSMO 1985.) DEPOSITION OF ARCHBISHOP ROBERT CARLSON MAY 23, 2014 Name and address of person or firm having custody of the original transcript: Mr. Jeff Anderson Jeff Anderson & Associates P.A. 366 Jackson Street, Suite 100 St. Paul, Minnesota 55101 TAXED IN FAVOR OF: Mr. Jeff Anderson TOTAL: $ TAXED IN FAVOR OF: Mr. Thomas B. Wieser TOTAL: $ TAXED IN FAVOR OF: Mr. Thomas R. Braun TOTAL: $ 15 16 Upon delivery of transcript, the above charges had not yet been paid. It is required that all charges will be paid in the normal course of business. 17 18 19 20 21 22 23 24 25 MIDWEST LITIGATION SERVICES 711 N. 11th Street St. Louis, Missouri 63101 __________________________ NOTARY PUBLIC My Commission Expires: www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 155 1 MIDWEST LITIGATION SERVICES 2 June 5, 2014 3 Mr. Thomas B. Wieser Meier, Kennedy & Quinn 4 Bremer Tower, Suite 2200 445 Minnesota Street 5 St. Paul, Minnesota 55101 6 IN RE: DOE 1 vs. ARCHDIOCESE OF ST. PAUL AND MINNEAPOLIS, DIOCESE OF WINONA and THOMAS 7 ADAMSON 8 Dear Mr. Wieser: 9 Please find enclosed your copies of the deposition of ARCHBISHOP ROBERT CARLSON taken on May 23, 2014 in the 10 above-referenced case. Also enclosed is the original signature page and errata sheets. 11 Please have the witness read your copy of the 12 transcript, indicate any changes and/or corrections desired on the errata sheets, and sign the signature 13 page before a notary public. 14 15 Please return the errata sheets and notarized 16 signature page to Jeff Anderson for filing prior to 17 trial date. 18 19 Sincerely, 20 21 22 Ms. Brenda Orsborn, RPR/CSR/CCR 23 24 Enclosures 25 www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 156 1 ERRATA SHEET Witness Name: ARCHBISHOP ROBERT CARLSON 2 Case Name: DOE 1 vs. ARCHDIOCESE OF ST. PAUL AND MINNEAPOLIS, DIOCESE OF WINONA and THOMAS 3 ADAMSON Date Taken: MAY 23, 2014 4 Page #_____ Line #_____ 5 Should read: ____________________________________ 6 Reason for change: ______________________________ 7 8 Page #_____ Line #_____ 9 Should read: ____________________________________ 10 Reason for change: ______________________________ 11 12 Page #_____ Line #_____ 13 Should read: ____________________________________ 14 Reason for change: ______________________________ 15 16 Page #_____ Line #_____ 17 Should read: ____________________________________ 18 Reason for change: ______________________________ 19 20 Page #_____ Line #_____ 21 Should read: ____________________________________ 22 Reason for change: ______________________________ Witness Signature: ______________________________ 23 24 25 www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Page 157 1 STATE OF _______________) 2 3 COUNTY OF ______________) 4 5 I, ARCHBISHOP ROBERT CARLSON, do hereby certify: 6 That I have read the foregoing deposition; 7 That I have made such changes in form 8 and/or substance to the within deposition as might 9 be necessary to render the same true and correct; 10 11 12 13 14 15 That having made such changes thereon, I hereby subscribe my name to the deposition. I declare under penalty of perjury that the foregoing is true and correct. Executed this _____ day of _______________, 20___, at ___________________________. 16 17 18 19 __________________________ 20 ARCHBISHOP ROBERT CARLSON 21 22 __________________________ 23 NOTARY PUBLIC 24 My Commission Expires: 25 www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 A ability 20:5,7 153:9 able 18:15 56:22 62:15 above-referenc... 155:10 absolutely 124:19 abuse 12:3,19 13:4,4 15:1 16:7 23:16 24:4 24:11 26:22 27:15,23 28:1 29:16,24 30:7 31:6,15,22,25 33:12 34:7 45:7 56:8,16,17 57:3 68:2 69:3,6 72:12 77:25 86:9 87:7,11 88:2 89:8 90:12 91:4 93:2 97:14 101:4,12,16 107:14 112:21 113:3,15 114:7 115:4 116:1 117:2 121:2,11 122:14,18,22 123:6,14,18 129:6 133:15 133:17 134:3 134:22 144:4 144:11 145:5,9 147:7,11 148:9 149:24 150:2 150:15,21 151:1,2 abused 10:13,19 44:13,25 48:2 54:16,20 56:6 60:14 63:21 64:11 72:16 97:25 98:9,13 99:20,25 111:11 126:20 127:1 128:6 134:10 135:3 138:23 139:1 142:15,25 143:7,20,23 abusers 87:18 abusing 18:5 88:2 abusive 149:11 accept 57:11 access 112:7 119:11,18,23 accuracy 10:15 10:23 11:9 13:7 14:3,15 15:6 17:16 18:2 21:2 22:5 23:20 24:6 24:9 27:5,21 30:3 31:24 33:10,18,24 45:14 46:10,14 47:8 51:17 63:9 65:1 92:5 accurate 19:1 20:14 24:17 45:9 49:12 54:6 57:14 65:18 accurately 20:21 46:11 92:19 accusations 147:22 accused 10:13 14:25 25:7 26:22 30:1,7,19 34:7 93:2 120:2 120:3 148:2 acknowledge 139:14 act 131:19 Acting 90:9 action 14:6 28:18 28:22 33:3 34:24 57:17,18 57:23 66:20 69:8 124:21 140:14 153:12 153:16 actions 33:15 www.midwestlitigation.com 101:20 146:7 activity 55:9,21 56:7 98:20 actual 134:24 Adams 107:2 Adamson 1:7 3:7 3:22 10:22 13:16,22 14:6 24:20 27:3,7,9 28:1,16,20 29:6 29:17,25 30:7 30:19 32:25 33:11,16,22 34:5,20,25 35:13,18 36:1 36:13,16,18,25 38:18,22 40:5 40:10,13,23 41:3,14,17 42:17 43:19,24 44:7,12,24 45:25 46:8 48:2 48:9 49:2 50:10 52:17,18 53:1 53:14,19,25 54:2,8,15 57:3 58:2,22,24 59:17 60:10,14 60:19,20 62:2 64:8,10 65:12 67:7,9,10,19 68:13,15,21 69:6,25 70:12 71:8,9,23 72:14 72:16 73:11,24 74:13 77:20 78:1 79:8,10 81:14 89:8,18 90:13 94:12,13 95:6 97:7,15,20 98:8,12,20 99:10,24 102:10,20 106:16 107:3,3 107:8 111:24 112:1,13 121:9 121:15 124:3 130:7 134:23 154:5 155:7 156:3 Adamson's 144:11 Adamson/Tom 64:9 additional 98:4 address 49:19 154:9 addressed 37:24 135:24 administrator 70:23 76:21 administrators 108:12 admission 56:5 99:23 100:12 admitted 54:12 55:8 64:11 91:13 98:8,13 99:4,9,24 146:7 admitting 54:15 54:19 99:20 adult 108:22 109:10,14 139:16 140:17 140:21,22 adults 88:2,2 advance 48:18 advice 52:12 66:21 87:12 advise 11:13 12:11 16:16 17:8,18 97:13 113:13 114:5 115:2 advised 16:25 17:10 18:18 19:3 23:12,14 24:2 48:4 52:4 52:9 103:8 113:23 115:6 advising 48:22 52:10 advisory 11:22 affiliate 107:18 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 affiliated 116:19 Affirmation 107:9 110:9 111:9 afraid 149:19 age 8:9 77:25 agencies 113:15 agency 113:4 146:12 aggressive 134:9 ago 10:15 14:2 14:14 18:21 19:20 22:2 24:10 30:11 33:11,25 38:18 41:25 46:13 50:13 54:5 100:16 117:5 119:2 150:24 agree 20:23,25 21:6,11,16 40:23 52:8 76:8 92:20 agreed 6:1 7:7,8 7:11 41:3 58:5 58:12 59:17 98:20 agreement 90:13 ahead 87:22 108:19 109:8 Ahmiller 124:4 air 29:23 al 6:17 49:2 148:2 Alan 147:7,18 Albuquerque 107:9 alive 73:2 allegation 31:22 149:9 allegations 28:1 31:6,15,25 97:15 121:1 139:17 148:9 alleged 144:3 148:19 allegedly 144:25 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 alleges 145:2 allowed 121:17 ambiguity 114:3 Ambrose 31:10 31:11 amended 50:3 America 16:1 25:17 Anderson 2:4 4:3 4:4 6:25,25 7:15 8:3,12 12:16 19:9,21 19:25 20:3 21:11,16 22:7 22:14,15 32:19 32:23 33:13 37:9 39:8,9,10 39:12,19,23 40:3 45:18,24 46:6 49:13,16 49:19 50:1,4,6 51:15 55:17,18 64:15,21 67:18 70:10,22 71:14 71:22 73:3 74:10 76:15 77:3,16 78:6,8 79:25 81:1,6,9 81:19 83:4 84:23 85:1,8 89:1,3,5 90:6 90:21 91:19,23 94:6,8 96:19,20 96:24,25 100:18 101:2 103:21 104:24 106:12,23 108:18,20 109:2,6,9 110:21,25 111:5,7,17,22 112:4,6 114:2,4 114:14,17,22 115:1,23 116:7 116:9 117:20 117:24 122:1,6 124:9,11,15,17 132:21,24 133:21,24 134:1,2 137:7 137:10 138:16 138:20,22 141:21 151:8 151:11,18 152:6 154:9,10 154:12 155:16 Anderson's 2:21 7:8 Andrew 102:12 139:8 and/or 16:12 23:11 33:2 44:8 85:13 97:2 155:12 157:8 Angels 70:24 71:3 annual 86:15 answer 20:19 21:2 31:2 33:6 39:14 44:23 50:4,11,19,23 76:15 82:17 96:11,15 100:11 104:21 111:14 112:23 113:7,21 134:5 answered 31:13 answers 8:19 19:15 100:19 anybody 19:3 28:15 50:16 52:13 107:1 113:22 116:4 116:11,17 120:5 132:12 134:23 anymore 118:21 anytime 70:18 anyway 121:10 Apparently 102:7 104:13 appear 93:8 108:5 APPEARANC... www.midwestlitigation.com 57:11,19,24,25 5:1 58:11,21 59:8 appeared 19:18 61:4 62:9 63:3 25:18 84:2 63:14,16,23 appearing 7:1,4 64:1,5 66:10,21 88:22 67:6 69:9,19 appears 8:22 9:3 70:11 72:7,22 9:6 83:11 73:23 74:11,12 123:13 153:6 75:5,18 76:2,9 Apple 74:15 76:19 77:17,18 appoint 74:14 81:2 83:16 85:8 appointed 9:19 92:7,25 93:22 12:20 15:18 94:2 95:4,5,21 appointment 95:25 97:14 25:4 53:9 75:23 100:20 102:21 approximately 102:23 104:3 6:15 104:16 105:20 April 19:11 106:13 108:15 122:12 123:11 109:9 111:15 123:25 128:11 112:11,25 128:17 131:23 119:20,22 148:13 120:25 121:9 Aquinas 52:22 121:21 122:13 arch 11:11 123:11,24 archbishop 1:11 128:3,11 3:10 6:4,16 7:5 130:10 131:14 7:8,13,15,16 131:16,19,24 8:8,13,25 9:7 132:17,19 9:14,15,20 10:7 133:25 134:19 11:12,12,13,16 136:7,16 11:20 12:1,12 137:11,13,23 12:18 17:13 137:25 138:6 18:4,23 19:10 139:7 141:3 19:14 20:4 144:1 147:20 21:12 23:2,3,7 148:14,20 27:11 28:22 149:10 150:1,9 29:6,7,11,16,20 151:18,23 30:2 31:13 154:7 155:9 32:23 34:10 156:1 157:5,20 35:25 36:23 Archbishops 37:12,17,25 102:2 38:16 39:4,15 Archbishop's 40:9 41:1,16 11:17 28:23 45:8,24 47:13 39:17 58:6 47:23 48:9,13 66:25 118:1,2 48:16,17 49:6 Archdiocesan 50:7 52:8,17 106:14,18 53:1,17 56:19 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 108:6 115:3 Archdiocese 1:6 3:6,21 4:8,14 6:17 7:23,25 8:2 9:5,18,21 10:4,10,17 11:2 12:3,17 14:24 15:13,22 17:7 24:3,12,22 25:6 26:5,7,13 40:17 42:19 43:11 44:7 45:8 49:2 52:20 54:23 55:12,24 59:24 70:3 71:24 76:11 80:7 84:17 90:12 92:15,24 93:22 94:2 100:2,5,21 102:16 104:8 105:2,7,8,21 107:25 109:24 110:8,14 111:12 112:7 113:2,8,12 116:2,3,17 117:8 120:1,3 120:10,22 127:23 131:11 133:1,2,5,17 134:17,20 135:1,11 138:9 143:17 144:15 146:11 149:25 150:23 151:25 154:4 155:6 156:2 Archdiocese's 105:18,24 archive 119:10 119:11,18 archives 119:3 area 26:4,7 147:17 148:6 argue 20:1 argumentative 21:10,14,21 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 46:4 51:11 91:16 115:20 Arnold 140:9 article 2:11 88:16 88:22 89:12 90:7 91:22 92:15 93:20 ASAP 59:24 ascertain 104:19 asked 12:22 21:5 22:8 34:14,16 36:25 44:6,16 44:24 46:20 50:17 57:11,22 67:16,17 71:8 85:10,12,14 98:7,12 99:6,13 99:22 100:5,11 102:9 109:4 114:14 138:6 144:10 146:5 asking 14:13 33:23 34:1 44:9 45:5 46:12 58:2 64:21 71:14 76:5 96:17 132:4,12 aspects 111:20 assert 132:9 assertion 21:17 132:11 assign 11:18,21 assigned 10:3 12:17 15:17 37:1 53:14,15 69:25 74:23 76:1,21,22 121:10 132:19 132:25 133:16 134:4,21 135:13 141:23 assignment 2:8 26:1 37:11 52:16,20 53:1 75:22 76:10,17 76:20,23,24,25 77:10 121:8 assignments 11:13,14,15 40:8 41:18 134:25 assistance 145:2 associate 10:5 52:21 68:4 74:14 76:22,25 125:19 149:2 Associates 4:4 154:10 association 124:2 assume 23:17 28:10 29:13 31:16 38:7 44:14,18,21 48:10 60:21 63:4 64:3 65:7 66:23 68:17 70:20 79:24 83:19 94:20 99:15 103:24 118:4 122:19 138:6 145:10 assumes 21:21 assuming 83:10 assumption 18:2 27:22 assure 93:21 132:5 attached 2:21 attendance 43:8 145:8 attended 58:16 86:17 120:15 attention 27:18 49:5 50:6 52:14 53:16 64:4 126:19 134:16 137:10 138:23 139:11 143:15 attest 93:18 attorney 50:9 52:13 80:7 153:14 attorneys 6:23 attraction 136:23 www.midwestlitigation.com attributable 88:20 92:8 94:17 attribute 81:24 95:1 108:1 attributed 93:7 93:25 103:8 August 35:11 auxiliaries 122:4 auxiliary 9:4,7 10:6 26:21 86:19,23 104:2 109:24 113:1 118:19 122:3 124:25 available 38:19 avoid 77:12 avoiding 102:3 aware 106:25 113:17 120:1,9 120:9,10 122:2 147:14,20,25 a.m 1:14 6:15 58:7 126:4 basically 59:7 basis 39:18 bear 108:5 becoming 87:24 bed 129:24 beds 130:1 began 78:11 begins 67:7 137:14 140:7 144:5 149:8 behalf 1:12 7:24 8:2,10 45:7 94:1 behavior 57:7 90:11 91:5 149:11 belies 91:12 believe 28:6 32:4 45:10,10 47:21 53:6 54:9,18 56:15 57:4,14 60:3 62:5 69:20 72:7 73:8 80:3 80:14,16 93:23 B 97:22 107:20 B 2:6 4:9 154:13 126:9 127:22 155:3 127:24 130:19 back 9:17 17:21 136:22 138:25 32:4 35:12 139:2 142:16 43:19 44:8 142:19 143:1 45:23 46:21 148:1 50:14 56:3 69:3 benefit 56:18 72:16 85:7,10 Bernardine 101:8 106:12 135:19 107:22 108:8 best 44:22,23 121:13 123:23 50:23 51:5 52:6 128:24 129:4 103:8 105:13 134:11 139:5,9 105:14 153:8 144:12 151:2 better 88:24 89:4 151:17 95:16 101:21 background beyond 23:11 88:21 24:20 136:5,7 bad 100:22 112:4 Bill 32:3 141:4 based 20:20 Binz 9:1 39:16 40:1 Bishop 9:4,4,7 103:13 104:22 10:6 15:17,18 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 25:4 26:21 36:24 38:5,10 42:18 47:3,11 50:19,25 60:5 73:2 77:19 85:19 86:24 95:5 102:21,23 103:3,7 104:3 105:12 107:7 109:23,24 113:1 119:25 122:12 124:25 128:16 130:16 131:23 132:5 137:13 140:6,8 141:4 144:5 145:25 146:16 147:16 148:14 Bishops 86:9,12 86:13,14,18,22 107:19,20 120:16 bit 96:4 140:18 blacked 36:11 54:14 55:19 Blahnik 50:8 blank 33:21,23 54:13 67:20 68:6,21 123:25 128:18,18,22 128:25 129:4 130:5 144:7,12 144:12,15,23 144:25 145:2 blocked 123:12 board 9:20,22,25 11:11,15,22 25:19 26:19 35:4 36:2,4,18 36:24 37:3 38:13,21 39:3,5 39:13 40:22 41:3,8,9,16 42:2,4,5,13 52:19 53:4,14 71:20 79:5,6 boardroom Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 28:13 Bob 124:2 125:18 137:16 bottom 36:12 74:18 83:21 132:15 boundary 139:16 boy 98:9 129:1 129:18,22 130:15 boys 143:9,20 145:22 Braun 4:15,15 7:24,24 37:8 152:1,5 154:14 break 45:17,18 45:21 84:24 85:1,5,12 151:12,15 breaking 7:11 Bremer 4:10 155:4 Brenda 3:16 5:3 6:5,20 153:3,21 155:22 brevity 139:6 Bridge 135:6 brings 134:18 brother 41:12 brought 29:5 47:25 54:1 60:14 67:20 144:12 Browning 4:20 8:4,4 Buckley 4:20 8:5 8:5 building 91:17 Bulletin 75:24 Bullock 128:16 130:16 business 154:16 C C 4:1 Cafe 73:14 calculate 79:18 calculated 82:15 82:16 calculation 80:12 82:18 call 17:2,3 22:25 71:2,6,10,21 73:11,12 105:13 115:7 115:22 127:6 132:5,13 called 48:13 51:22 116:15 127:4 calling 48:18 calls 71:19 76:12 100:15 cancer 20:10 canon 15:24,25 26:10,14 32:5 capacities 10:3,6 capacity 9:7 121:3 care 35:6 112:8 carefully 33:8 Carlson 1:11 3:11,14 6:4,16 6:20 7:5,9,15 8:8,15 19:10 50:19 60:9 64:9 77:19 90:12 91:6 92:11 95:5 122:12 131:23 132:5 137:13 140:6,8 141:5 144:6 145:25 146:16 148:14 151:23 154:7 155:9 156:1 157:5,20 case 7:6,10,17,17 7:17 15:7 22:10 27:15 41:14 48:7 55:10,22 56:9 59:10 70:20 72:1,6 73:11 91:4 93:12 111:8 www.midwestlitigation.com 117:14,16,16 120:12 127:18 130:24 131:10 132:3 134:12 135:17,25 138:8 141:11 144:11 145:7 155:10 156:2 cases 7:16 12:6,7 121:11,17 135:2 Catholic 15:25 25:17 35:10 75:24 86:13,17 107:18,21 120:15 cause 3:18 63:22 caused 16:16 17:8 47:23 82:19 CCR 5:3 153:4 CC'd 131:24 cease 62:3,6,25 celibacy 107:14 Center 4:16 40:18 110:10 centers 107:10 107:13,17,18 107:21 110:7 certain 3:18 97:8 certainly 25:11 45:10 75:20 88:5 89:18 92:19 101:5,21 121:14 CERTIFICATE 153:1 154:6 certification 49:11 certified 3:16 6:5 49:21 153:3,4 certify 153:5 157:5 Chackes 3:14 6:19 challenge 87:10 chance 92:11 94:20 chancellor 10:5,5 12:8 26:20,20 35:6 113:1 116:4,6,7 118:15,21,23 119:20,23 123:22 chancellors 119:24 chancery 18:13 25:9,15 28:10 30:9 31:9 54:1 73:1 119:16 change 106:5 156:6,10,14,18 156:22 changes 112:23 155:12 157:7 157:10 charge 59:6 charged 12:5,7 67:10 charges 67:20,21 97:8 154:6,15 154:16 Charles 7:4 charter 120:14 check 84:21 135:22 chemical 20:11 107:15 chief 11:19 child 10:13 16:11 18:5 99:1 childhood 149:2 children 136:14 144:11 child's 22:24 choice 75:18 76:1 131:16,17,18 131:19 choices 108:7 cholesterol 73:21 choose 65:24 125:14 Christa 4:21 8:1 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Church 52:22 74:15 Circuit 1:1,1 3:1 3:1,18,20 6:18 154:1,2 circumstance 63:19 circumstances 27:20 41:2,17 City 1:1 3:1,19 6:18 154:1 civil/criminal 81:5 claims 45:7 clarification 110:19 117:14 clarify 111:5 Clark 93:8,20 clear 32:16 38:9 clearly 28:21 79:12 149:11 clergy 25:20 146:22 cleric 14:25 24:4 clerics 10:19 107:13 114:7 climate 106:5 Clinic 135:19 close 40:22 125:10,11,14 129:24 Cloud 77:22 97:9 97:24 clubs 130:5 coincidence 51:4 colleagues 24:2 113:13 114:5 114:10,15 116:2 Collegeville 86:18 87:2 Collins 102:12 107:2 Columbia 68:5 78:13 column 90:7 92:6 come 11:4,7 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 24:24 34:13 36:18 42:17 112:22 126:19 138:22 150:15 comes 13:15 45:24 46:2 86:8 94:15 117:10 135:15 coming 18:6 33:1 143:5 146:22 comment 24:18 Commission 154:24 157:24 commissioned 120:17 committed 99:11 100:12 committee 117:4 communication 117:3 community 137:3,7 company 121:24 compilation 120:1 compile 120:6 compiled 120:7 120:20 complaint 14:5 17:19 147:18 complaints 13:4 13:9,11 completed 7:12 38:18 completely 33:21 complicit 106:15 compound 33:5 70:8 106:22 concealing 106:16 Conception 68:4 68:6 70:1 78:14 concern 20:13 22:3 63:15,25 70:19 102:1 concerned 16:11 63:17 70:11,12 87:24 105:23 105:25 concerning 10:18 14:6 28:1 33:2 33:16,21 35:18 40:13 45:25 46:8,20 54:2 65:9,12 67:8,19 68:12,19 70:14 97:8 112:13 134:21 137:16 139:18 140:14 147:22 concerns 106:12 concluded 67:8 152:10 concludes 41:10 151:22 concur 37:8 condensed 152:3 152:7 condition 20:6 conduct 67:24 91:14 98:25 99:12,22 110:3 129:13 140:20 Conference 86:13,14,18 120:15 confidential 1:15 95:22 117:25 118:3,9 119:5 confirm 91:10 confirmation 137:15 confronted 103:6 150:2 confused 12:24 18:13 78:5 140:18 confusion 66:14 conjunction 12:10 conjunctive 109:5 connection 12:18 146:20 www.midwestlitigation.com connotes 60:1 conscious 131:17 consequence 106:5,6 consider 20:16 58:3 84:13,16 considered 85:22 119:2 considering 80:5 84:4 constituted 11:11 constitutes 86:5 consult 106:19 112:2 Consultation 40:18 110:9 contact 11:5 40:22 50:11 54:13 55:8 62:23 66:9,12 74:6 79:11 83:23 90:14 98:21 102:20 contacted 77:21 contained 83:15 continue 39:23 42:19 75:11 121:17 136:17 150:8 continued 5:1 66:11 78:12 94:10 100:1 continuing 37:6 39:17,19 93:1 continuously 15:22 contradict 91:24 contrast 151:2 control 109:18 controversy 116:11 117:15 conversation 38:17 48:23 51:24 52:1,2 73:8 99:18 100:17 115:17 116:25 117:1 conversations 23:7 103:10,12 103:14 117:7,9 cooperation 107:7 copied 38:13,21 74:13,18 76:2 147:8 copies 38:25 155:9 copy 49:12 61:23 88:25 89:4 123:2 155:11 corner 38:13 49:7 123:1 correct 8:24 9:2 9:9 10:7,8 11:10,23,24,25 13:9 15:19 16:3 18:8,19,20 20:23 23:8 26:11 37:22,23 37:25 38:1,3,4 38:11 50:1 52:23 53:2,3,20 53:21 54:21 55:1,13,25 56:4 56:19,20 57:3,8 57:9 58:13,14 58:19,22 63:12 65:6 66:3,13 67:2,9,11 68:14 68:16 74:17 78:1,2,14,15,19 78:20 79:16 81:15 82:10,19 86:20 89:9 93:15 94:21 95:7,8 97:15 98:11,14,15 99:3 102:24 103:12 104:4,5 105:18 107:15 110:4,15 111:12 113:9 113:23 116:21 116:23,24 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 120:17 126:18 128:13,14 129:7 130:11 130:12,16 131:13 140:22 143:10 145:9 157:9,13 corrected 78:6 corrections 49:18 155:12 correctly 62:4 98:10 cost 110:20,25 counsel 6:2,2 85:10 88:24 106:23 117:13 153:10,14 counseling 78:18 97:24 counselor 75:10 75:10 77:22 84:12 102:6 counselors 75:12 89:19 100:25 105:5 111:23 county 130:15 157:3 couple 22:23 30:21 34:14 75:8 122:7 course 7:19 15:16 22:1 24:15 25:7 28:25 31:12 42:23 54:22 57:23 87:12 125:23 154:16 coursework 43:6 court 1:1 2:21 3:1,16,18 5:2 6:5,18 18:24 49:22 153:3 154:1,1 cover 49:3 covered 136:5,8 covering 106:16 cover-up 89:6,8 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 89:14,16,21 co-counsel 50:9 co-pastor 141:23 credibly 93:2 120:2 crim 99:21,21 crime 81:14 98:14 108:22 109:10,11,12 109:14,17,25 145:15,18 crimes 99:1 106:16 criminal 67:24 79:18,25 81:6 83:8 91:13 98:25 99:11 100:13 102:11 106:14,19 110:2 criminally 70:13 crossed 23:4 Crystal 126:17 CSR 5:4 153:5 culture 108:9 cure 92:10 94:19 94:24 cured 87:20 88:3 88:5 89:20 cures 88:18 current 115:24 currently 97:9 custody 154:9 cut-off 145:3 D D 2:1,6 dad 16:21 19:4 23:12 daily 18:6 Dakota 113:6 Dale 138:8 dangerous 140:25 data 120:19 date 6:14 9:15 13:1,8 35:13 36:22 37:16 47:13 49:2 57:19 64:7 78:4 85:16,24 88:11 88:13 89:10 96:16 97:12 122:14 155:17 156:3 dated 37:14,21 53:18 64:5 74:11 77:17 88:16 95:4 122:11 123:11 128:11 131:23 135:18 137:11 139:4,9 140:5 141:2 144:2 148:13 dates 12:25 18:14 23:20 32:10,13 David 5:9 6:21 day 3:12,14 37:21 157:14 days 50:13 64:6 67:5 75:11 87:13 119:1 deal 73:20 dealing 70:18 75:13 107:14 108:9 121:1 149:13 dealt 139:15 Dear 38:16 52:18 140:8 155:8 death 115:15 142:23 deceased 65:16 December 64:7 65:8,10 66:13 67:5 68:11 decided 90:12 decision 11:17 68:1 declare 157:12 Defendant 4:8,14 Defendants 1:8 3:8,23 6:3 www.midwestlitigation.com degree 98:21,24 99:21 146:18 delivery 154:15 demonstrated 149:12 denial 89:13 denied 89:6,7 deny 51:18 91:9 91:11 93:12 145:21 150:2 denying 42:3 149:24 departure 117:7 depend 30:15 dependency 107:15 Depending 119:1 depends 26:15 31:20 deposed 7:15 19:9 deposes 8:10 deposition 1:11 1:14 2:8 3:10 6:3,12,16,19 7:6,9 21:25 22:3 46:18,25 47:5,5 48:7,18 49:1,4,6,12,21 50:16,20 51:1 103:7,9 132:23 151:22 152:10 153:7,12 154:6 154:7 155:9 157:6,8,11 depositions 7:12 7:18 9:11 14:22 18:24 19:13,20 describe 146:6 described 19:5 23:23 129:18 145:7,9 desired 155:12 desk 23:4 destined 105:10 destroy 61:22 destroyed 61:12 destroys 55:11 55:23 detail 19:12,19 determination 90:10 determine 30:24 111:24 devoted 121:1 diagnosed 136:10 diagnosis 20:9 136:18 died 112:16 142:22 143:2 different 7:10,16 9:5 10:18,18 11:4 12:25 24:16,25 29:1,1 30:21 33:9 43:15 75:8 105:12 114:12 123:6 131:2 150:18,19 differently 104:23,25 difficult 62:18 134:5 difficulty 92:1 diocese 1:6 3:6 3:22 11:7,19 25:21 36:17,19 38:2,5 40:25 41:4 43:8,13,19 70:23 110:20 127:4 152:1 154:5 155:6 156:2 dioceses 9:5 24:16 33:9 36:19 43:14 120:8 134:7,9 direct 37:19 49:5 50:6 52:14 53:16 64:4 88:19 134:16 137:10 139:11 143:15 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 directing 27:17 direction 153:10 directly 113:4 director 12:6 25:10,14 31:17 32:11 35:6 38:25 41:24 71:20 73:9 125:8,12,15 directors 31:21 32:1 disabilities 88:18 disagreed 34:10 discern 109:13 109:16 disclosure 133:3 133:15 134:3 134:20 135:10 135:11 136:18 discuss 29:24 40:7 47:23 48:14 50:9 53:25 128:17 discussed 50:15 68:20 87:6 89:17 115:23 115:24 116:10 116:13 discussing 150:11 discussion 41:7 46:15 48:15 51:2,13,15,19 51:19 52:7 73:25 85:18 87:9 discussions 47:3 47:10 48:8,12 disease 87:19 92:10 94:19,25 disorder 20:6 87:19 88:3,4 dispute 10:1 42:12,13 47:1 59:5,11 148:22 148:24 disservice 75:12 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 divided 125:1 document 10:24 13:6,19,24 14:8 16:10,19 17:4 17:11,20 18:22 20:15 22:5 43:21 44:5,10 44:15,20 45:1 52:2,3,4 54:8 55:19 56:23 66:17 69:13 72:1,24 76:8 91:17 100:9 103:24 121:13 123:19 126:2 126:11 138:14 138:15,16 147:11 148:11 documented 14:18 33:8 documents 9:11 14:16,21 15:3,7 15:14 18:3,25 19:16 22:6,17 22:20 24:19 27:4 28:4 91:12 91:24 112:20 Doe 1:3 3:3,20 6:17,25 7:6 154:3 155:6 156:2 Doell 5:9 6:21 doing 75:6 84:21 94:7 102:15 130:7 140:16 Dominica 139:8 doubt 42:8 47:8 54:5 56:25 58:9 59:3,21,25 60:8 63:13 68:10 74:21 78:10 81:22 103:1 109:20 Dr 78:18,23,25 102:10 110:9 112:14 140:9 141:5 drive 146:24 drop 132:6,13 duly 153:7 duties 54:23 DVD 152:8 D.C 16:2 26:9,14 enclosed 155:9 155:10 Enclosures 155:24 encounter 37:11 encourage 15:5 16:4 E encouraged 15:3 E 2:1,1,6,6 4:1,1 16:7 132:13 4:16 152:6 ended 134:8 earlier 66:17 enforcement 79:11 85:15 15:1 16:5,8,25 86:1 91:12 70:6 113:4,15 107:24 113:25 113:23 114:6 123:18 138:16 146:12 147:22 engage 108:22 early 26:8 88:10 109:10,14,17 88:11 101:8 engaged 37:10 149:14 40:24 Edina 144:18 engaging 65:11 edits 49:17 enter 146:17 effect 108:15 entire 133:23 effective 53:9 ephebophilia effectively 74:16 136:11,21,22 effectiveness 136:24 137:1 55:11,23 err 102:2 effort 71:23 76:9 errata 50:3 77:10,11 155:10,12,15 Eisenzimmer 156:1 102:12 116:4,6 especially 14:15 116:8 139:8 essence 89:20 either 9:12 20:8 estimate 29:15 27:10 29:25 29:21,22 121:5 30:6,18 37:2 estimates 10:16 72:18 83:10 et 6:17 49:2 84:6 102:8 evaluating 68:15 108:3 109:19 evaluation 59:18 126:12 135:9 60:5 68:13 136:15 140:14 110:15 140:9 Eleventh 5:5,10 evening 3:13 embarrasses event 16:24 139:13 18:16 21:17 emotional 107:16 54:22 132:10 employed 153:11 events 20:7 22:21 153:14 45:25 46:8 employee 153:13 65:20 66:5 empty 130:1 144:12 146:6 www.midwestlitigation.com evidence 21:22 46:5 103:20 evident 97:24 exactly 13:23 15:15 16:18 22:2 27:12 34:12 35:13 68:23 93:18 examination 8:11 49:5 examined 3:11 8:9 examples 113:17 excluded 121:25 excuse 15:21 16:2 39:6,14 40:4 49:8 69:13 78:3 147:5 Executed 157:14 exhibit 2:7,7,8,8 2:9,9,10,10,11 2:11,12,12,13 2:13,14,14,15 2:15,16,16,17 2:17,18,18 6:9 35:22,25 36:1 37:7,14,19,20 37:22 39:4 40:1 42:8 48:24,25 52:15 53:17,17 64:5,6 66:22 67:4 74:11,11 77:17 88:14,15 95:3,3 103:20 122:11 123:9 128:10 131:22 132:18 135:17 137:11 139:4,6 140:4 141:2 144:1 147:4 148:12,13 exhibited 149:10 exhibits 2:20 19:13 86:1 122:7 exist 22:19 107:10 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 existed 70:20 exists 143:6 expect 48:20 expected 19:17 experience 62:10 77:3 87:16 133:18 149:24 150:1,9,13 experienced 101:20 experiences 93:17 expert 88:8 Expires 154:24 157:24 explain 19:18 27:12 33:20 explanation 129:12 exploitive 149:11 explored 112:20 exposure 104:8 105:16,17,22 106:3,4,4,5,19 express 75:3 expressed 75:5 expressly 6:7 extent 22:18 35:7 106:22 eyes 66:25 95:23 118:1,2 E-tran 152:3 F F 2:1,6 face 106:14 fact 16:24 21:7 21:18,24 34:9 36:21 42:17 44:3 88:6,8 98:8 103:11 128:3 132:13 141:9 142:25 145:3 147:12 148:24 facts 21:21 46:16 104:20 115:8 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 116:5 141:18 failures 105:24 fair 18:4 45:6 58:16 81:19 96:9 97:5 150:10 fairness 19:14 Falls 15:18 25:4 101:22 120:22 134:13 familiar 71:1 families 144:7 family 43:3 116:21,24 124:2 126:22 128:4,8,18 130:13 father 31:10 32:3 36:9,11,13,16 36:25 40:5,7,7 40:10,23 41:14 45:11,12 48:2 50:10 52:18 53:11,19,24,24 53:25 54:2,15 56:6 58:11,21 59:17,18 60:4,9 60:10,13 62:2 63:4,8,12 64:8 64:9 65:4 66:15 67:9,19 68:3,7 68:12,13,21,25 69:5 72:5 77:20 78:17 80:4 84:4 95:6 96:7 97:6 98:7,20 102:9 102:20 107:8 122:12 123:24 128:15,16,23 128:25 129:2,4 129:12,16,23 129:24 130:4 130:13,15 131:12 132:5,6 132:6 137:16 137:23 138:13 140:7,8 141:3,4 141:21,22 143:15 144:4,6 144:11,15,24 145:2,11,21,25 146:1,1,4,16,17 148:15,19 149:4 FAVOR 154:12 154:13,14 February 36:3 37:15,21 49:3 74:12 88:17 89:11 140:5 141:3 feel 104:15 feeling 75:14,16 feelings 104:20 felt 107:24 144:13 females 139:16 fifth 102:19 figured 61:7 file 16:10 36:1 49:2 53:19 56:18 61:23 64:8 66:24 118:5,6,8,24 119:5,13 122:14,18,19 122:22 123:20 147:5 filed 49:21 117:14,17 filing 155:16 final 59:19 131:18 financial 111:20 financially 153:15 find 64:19 71:8 71:23 155:9 finish 108:18 finished 60:5 Finnegan 124:3 125:21 firm 154:9 first 10:11,21 www.midwestlitigation.com 11:5 12:10,16 14:18 18:9 20:4 20:19,25 21:5 22:8 25:9 35:2 36:17 38:23 40:5 42:22 52:18 53:7,8 64:18,24 80:20 81:24 83:2 86:8 87:25 88:15,21 90:7,14 92:23 96:14,20 98:21 98:24 99:21 104:9 109:13 109:16 113:5 124:7 149:1,9 firsthand 113:19 115:6 Fitzgerald 72:17 72:19 73:2 Fitzpatrick 70:24,25 72:13 72:23 73:5,11 73:24 74:5 Fitzpatrick's 73:13 five 121:7 floor 119:15 flow 129:18 Flynn 116:25 117:4 139:7 focusing 105:20 follow 73:10 followed 125:17 following 35:10 47:5 117:7 follow-up 144:17 foregoing 153:7 157:6,13 forenoon 3:13 forget 146:24 forgotten 139:17 form 12:14 21:20 23:5,8 33:5 37:7 39:18,20 51:10 67:12 70:7,15 71:11 72:20 74:2 76:12 77:14 79:21 81:16 82:23 90:3,18 91:16 94:4 100:14,23 104:18 106:8 106:21 108:17 108:25 115:19 133:19 141:15 157:7 formal 59:10 67:15,16 formally 12:20 former 70:22 116:2,7 forward 126:23 150:15 found 90:5 foundation 37:6 39:16 51:11 72:22 77:2 79:21 80:25 81:17 110:16 137:8,9 four 14:22 22:2 24:16 33:8 fourth 68:18 102:9 frame 12:14 18:7 18:10 26:21,25 34:22 72:21 111:16,17 120:25 133:20 Frank 135:19 Friday 36:3 68:11 97:6 friend 125:10,11 127:21 149:2 friends 125:14 full 8:14,15 fully 7:12 108:11 full-time 38:20 funded 107:19 107:20 funding 110:14 111:7 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 funeral 142:20 143:5 further 63:12,22 102:19 151:18 153:13 G garage 112:16 gathering 146:22 Gendron 78:18 78:23,25 79:2,8 102:10 108:4 110:9 112:8,14 140:2,5 141:5 Gendron's 115:15 general 12:7 27:11 30:13,18 30:24,25 105:6 Generals 30:22 31:4,8 122:4 genitals 145:4,14 145:17 147:20 geographical 26:4,7,12 getting 63:21 83:6 140:12 143:13 girls 138:24 139:19,22 140:18,21 give 8:19 19:21 24:20 29:21 31:2 52:13 57:12 84:25 128:24,25 given 9:12 48:7 52:12 59:23 66:21 100:24 104:7 105:15 106:2 112:1 113:25 141:8 144:14,16 145:10 147:12 glad 13:6 65:21 global 133:12 go 7:20 9:17 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 16:17,25 17:8 18:18 23:12,14 34:15 41:23 43:19 44:8 48:4 50:7 57:22 67:4 67:18 68:3,18 68:25 74:8 78:11,16 80:4 84:3 86:22 87:22 91:3 92:6 95:3 98:7,19 105:22 108:8 108:19 109:8 118:2 119:5 122:6 123:23 130:4,14 142:9 goes 36:23 37:9 54:12 128:22 129:22 144:9 145:14 going 12:13 17:21 19:6 20:1 21:9 22:7,15 32:25 33:4 35:22,23 37:5 39:15,25 47:14 47:18 48:24 50:17 51:9 52:14 53:16,22 64:4,23 68:18 74:10 77:13,16 79:20 84:23 91:15 101:8 105:25 108:16 108:24 112:5 113:24 114:18 122:6,8,9 126:14 134:11 138:12 141:13 147:4 Goldberg 7:3,4 12:13 19:6,21 19:23 20:1 21:9 21:13,20 22:12 32:16,20 33:4 45:16 46:4 49:8 49:14,17,23 50:2 51:9 64:14 64:19 67:12 70:7,15 71:11 71:16 72:20 74:2 76:14 77:13 78:3 79:20 80:24 81:3,16 82:22 84:20 88:24 89:2 90:2,18 91:15,21 94:4 96:17,22 100:14,23 104:18 106:8 108:16,19,24 109:4,8 110:18 110:22 111:1 113:24 114:12 114:16,20,25 115:16,19 117:13,19,21 121:24 124:10 132:20,22 133:19,22,25 137:6 138:15 138:19,21 141:15 151:6,9 Golden 26:3,18 142:2 good 7:3 8:13 37:10 84:20 101:22 112:5 151:6 grateful 40:6 41:13 great 22:5 73:15 Greg 46:18,23 48:1,3 97:8 98:13 101:3 Gregory 77:23 97:25 grievous 105:3 gross 55:10,22 ground 7:20 Guardian 70:24 71:3 guess 13:2 18:7 www.midwestlitigation.com happy 20:14 harm 136:14 Harry 116:25 117:3 Hayden 31:10,12 HD 152:7 head 116:22 147:1 H headline 89:5 H 2:6 hear 143:13,22 haircut 129:3 heard 109:6 haircuts 129:1 143:11,12 half 79:16 80:1 149:9 80:12,22 81:11 hearing 143:24 81:13 82:7 83:9 145:6 hand 97:11 hearsay 51:12 123:14 145:3 Hedrick 141:21 147:19 141:22 142:12 handing 122:11 Heidelberg 123:9 132:25 133:3 handle 29:18 137:15 30:6 59:8 97:14 Heights 68:5 handled 24:15 78:13 34:11 117:2,2 held 6:19 70:5 136:6 145:11 help 11:12 22:18 handling 12:2 35:23 41:12,17 31:5,14 45:7 88:13 111:23 107:25 115:24 144:25 115:25 121:1 helpful 111:15 121:10 133:10 helping 97:13 handwriting high 87:18 90:5 122:25 123:3,6 146:18 123:15 highlighted 34:9 handwritten history 76:10 60:25 61:8,11 99:10,24 61:17,18,22,24 101:16 102:11 65:6 108:8 124:1,5 happen 129:25 125:5,25 126:3 130:14 133:5,17 134:4 happened 18:17 134:22 135:13 23:18 24:10 139:10 140:20 34:18 46:2 47:7 143:3 61:11 66:7,8 homosexual 69:20 96:10,13 146:19 96:15 97:1 hopefully 7:19 128:21 129:11 hours 3:12 happens 114:23 house 107:9 29:23 50:19 64:6,17 95:18 144:21 guessing 121:4 Guthrie 146:25 guy 45:7 80:22 81:13 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 110:8 111:9 128:23 huh 130:7 human 19:16 I IC 78:12,13 idea 20:12 84:25 123:16 126:1 identification 35:24 identified 38:10 86:1 136:13 140:24 identify 123:2 identity 144:9 idyllic 149:20 IL 153:5 illegible 89:2 91:18 Illinois 5:4 illness 20:6 illuminate 123:19 Immaculate 68:4 68:6 70:1 78:13 immediate 59:18 immediately 74:16 imminent 47:4 impeded 20:12 impedes 20:5,7 implemented 92:24 important 20:17 46:10,15 151:10 imposed 62:25 66:9 impossible 14:14 99:19 inaccurate 97:22 149:20 inadvertent 124:12 inappropriate 21:14 90:11 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 91:5 140:20 146:6,7 incident 16:9 23:11 68:20 90:10 144:3 incidents 69:2,5 78:16 included 146:11 increasingly 87:24 independent 54:7 69:14 96:14,21 136:6 indicate 10:25 149:12 155:12 indicated 69:1 72:13 144:24 145:1 indicating 149:23 inform 77:23 informally 7:11 information 10:12 11:8 17:8 18:5 23:14,15 29:5,11 33:1,3 37:2 38:20 41:20 43:7 47:22 63:21 66:22 72:18 74:7 83:15,23 94:17 113:19 113:19 115:7 129:9 142:24 144:14 informed 43:18 43:24 44:3 126:21 150:13 initial 96:4 122:15 132:15 133:7,9 141:6 inmate 97:9 inmates 77:23 inpatient 69:11 input 96:8 inside 145:3 insist 130:5 insisting 128:6 insists 130:13 installed 9:14 86:23 instance 17:6 102:5 134:19 instances 23:6,22 88:6 92:2 Institute 137:17 institution 110:23 institutions 111:10 intend 93:19 96:2 102:22 intended 95:23 103:21 intention 93:24 intentions 146:5 interactions 33:14 34:23 interchanged 136:25 interest 105:14 interested 153:15 interpose 39:15 interview 26:23 interviewed 93:20 introduce 6:23 introducing 19:8 40:1 investigate 12:11 13:3,9,12,14 26:24 59:7 67:17 investigated 13:10 investigating 12:2 31:5,14 investigation 14:6 25:8 67:8 67:10,15 investigations 31:23 investigator 12:17,21 www.midwestlitigation.com invited 128:23 inviting 22:25 117:4 involved 25:23 27:14 30:18 31:5,8,18,22,25 32:24 33:11,15 35:17 45:13 59:10 70:12 72:4 75:20 111:20,22 124:23 131:15 133:8,10 134:24 146:14 147:17 148:7,8 involvement 33:2 33:22 34:6,25 46:1,3 62:4,7 62:12,16 63:1 133:8 139:18 139:21 involves 141:9 issue 27:23 29:16 issues 107:16 112:20 issuing 89:13 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140:19 147:6 147:21 key 119:20,21 K kid 54:13,16,20 Kapoun 124:3 55:7 56:7 60:14 125:18 126:14 64:10 98:14 126:20 128:4 99:10,21 128:15,16,23 108:22 109:10 129:2,4,16,19 109:14,17 129:24 130:4 145:18 130:14,18 kids 44:13,25 131:11,24 57:5 72:16 132:6,18 133:4 75:18 88:2 134:22 135:17 93:23 99:12,25 136:2,6,10 110:11 111:11 137:14,16,23 139:1 Kapoun's 129:12 kind 20:11 24:13 keep 39:20 61:22 26:15 36:4 45:6 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 61:7 74:5 79:1 112:17 115:13 123:18 143:12 kindergarten 65:14 Kinney 32:3 40:7 knew 38:5 40:16 46:21 68:14,24 72:16 75:17 79:2,9 87:15 88:4 90:4 94:9 94:13 98:24 107:10 108:20 108:23 109:9 109:11,21,25 110:4 112:21 141:22 143:11 143:16 145:4 145:15,17 know 7:13 13:2 14:10 16:19 18:21,23 22:6 22:20 24:18 32:12,14 33:11 34:11 41:8,19 46:11 47:13 48:1 50:2,21 58:24,25 61:14 62:13 63:18 64:2,25 65:3 67:14,17 69:17 73:7 75:11,13 75:15 79:9 80:11 81:4 82:10,14,14,18 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127:22 147:25 left 126:21 127:12,14,15 127:18 131:8 135:1 left-hand 38:12 L legal 6:21 19:22 lack 37:6 39:16 106:23 lacking 46:2,5 letter 2:7,8,10,13 lapse 139:14 2:15,16 36:24 late 26:7 88:11 37:18 38:16,24 139:18,24 39:5,13 41:7,10 149:13 41:19,21,22 LaVan 71:3,4,5,7 42:5,7,11 52:25 71:8,10 72:14 74:12 75:22 72:18 73:4 123:11 135:18 www.midwestlitigation.com 140:5 letters 39:1 42:1 let's 25:13 67:4 81:9 82:5 85:1 88:14 90:6 92:6 94:20,21 95:3 97:5 114:22 123:23 128:10 129:15 131:22 139:4 140:4 144:1 148:12 Lexington 133:1 133:4 liability 106:15 141:9 lieu 131:12 life 43:3 92:2 liked 74:5 limit 25:13 limitations 79:15 79:19 80:1,13 80:21 81:4,7,11 82:7 83:8 limits 26:12 line 50:7 124:7 156:4,8,12,16 156:20 list 120:2,6,9,10 listed 83:18 138:17 listen 21:5 64:17 114:19,22 lists 120:7,20 148:24 litigation 5:4,9 6:22 115:24 116:10 154:17 155:1 little 14:20 50:15 64:5 95:16 96:4 122:25 132:15 140:18 live 26:9 LLP 3:14 located 35:9 location 122:14 122:18 123:5 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 123:17 long 41:25 54:5 83:1 101:3,8,16 121:14 124:1,4 125:6 127:14 127:18 longer 72:4 long-term 55:11 55:23 look 9:3 13:6 17:22 18:25 77:7 79:13 88:14 90:6 95:14 96:18 97:3,5 101:21 123:9 128:10 129:15 131:22 135:17 137:22 139:4 140:4 141:2 144:1 148:12 looked 12:2 91:13 looking 101:24 looks 36:7 50:21 62:2 83:12 92:8 95:16 loop 122:5,23 Loras 38:6 49:4 Loring 146:17 lot 85:18 130:6 150:6 Louis 1:1 3:1,15 3:19 5:5,10 6:18 7:10 9:6 9:15 154:1,19 lower 38:12 Luke 137:17 Luke's 107:22 111:10 135:19 140:15 lunch 73:16 84:24 M M 2:1 main 119:15 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 maintained 118:8 122:22 making 11:13 17:22 39:20 56:18 71:18,21 71:23 73:12 75:18 104:2 man 15:8 mandated 84:17 mandatory 84:13 85:17,22 86:5 108:14 109:1 March 19:10 37:12 Margaret 26:2 26:18 142:2,10 marked 6:11 19:13 35:24,25 37:19 48:25 117:25 118:3 119:4 marks 92:8 marriage 35:7 37:11 125:23 Mary 26:18 142:10 Maryland 137:17 Mary's 26:3 78:23 79:6 142:2 Mass 62:23 143:14 masturbate 129:5 masturbation 129:16,18 material 118:9 118:24,25 materials 9:11 matter 6:16 20:17 46:18,21 48:9 49:1 61:16 116:1,10 148:5 matters 13:3 14:17 19:12,18 McDonough 45:11 95:18 96:7 97:7,12,19 98:12 99:5 116:3 117:6 118:21 122:13 123:25 139:8 139:13,22 140:19 147:6 147:12,21 148:18 mean 18:4 68:22 75:15 95:22 96:2 121:24 means 58:21 75:24 80:22 81:1,12 94:22 96:1 105:17 122:10 123:20 128:12 150:21 medical 112:8 137:3,7 meet 25:6 26:22 27:6,9 28:9 30:8,10 58:6 60:9,19,19 68:16 112:12 137:23 144:10 150:8 meeting 2:7 27:18,20 28:15 28:19 29:6,7 30:13 34:21 36:3 40:12,15 42:15 54:2,4,10 55:2,4 58:8,11 58:16,18,21 59:12 60:15,23 61:1,21 73:13 73:23 78:9 86:15,17,21 87:1,3,5,8 97:12,19 98:5 103:17,22,23 111:23 112:14 112:15 120:15 128:19 146:13 meetings 27:18 www.midwestlitigation.com 28:10,16,19 29:15,19 61:3 70:5 86:22 103:2,5,12 Meier 4:10 155:3 member 37:3 42:3 53:13 members 42:2 memo 2:9,9,10 2:11,12,12,13 2:14,14,15,16 2:17,17,18,18 23:4,8 27:12 29:3,9,13 30:4 31:16 53:18 57:14,19 58:15 59:11 60:16 61:10 64:7,12 65:2,3,5 66:13 67:6 77:18 79:13 82:11,25 83:16 95:4,6 96:6,21 97:3,5 97:21 98:2 102:5 103:17 117:24 118:2 122:12 128:11 131:23 133:9 137:12 139:3 141:3 143:25 145:8 146:12 148:13,15,22 148:25 154:1 memories 32:24 memory 13:13 14:9,20 16:13 16:20,23 19:3 20:4,12 21:3,7 23:21 24:7,14 29:4,10 30:5,17 33:21,23 34:17 36:21 37:12 38:23 39:12 40:14 42:22 44:2,4,6,16 46:1,5 54:11 55:2,4 63:7,8 64:16 69:14,15 70:2 72:17,23 73:22 75:15 78:24 80:17 82:2 83:13,14 87:2 93:25 96:21 97:22 103:13 112:18 113:22 124:19 126:8,12 132:12 136:6 139:14 140:13 144:20 148:25 memos 23:25 24:5 33:19 46:11 56:3 70:4 79:11,23 95:10 114:9 119:4 Mendota 135:6 mentioned 12:25 16:4 19:8 27:2 116:12 126:14 126:16 135:15 138:13 151:4 mentioning 12:24 menu 73:18 133:9 met 25:12 27:3 27:10,13,25 28:6 30:5,10 34:19 35:13 47:15,15 48:1 53:24 54:8,16 64:25 68:12 86:9 97:7 123:25 128:16 137:15 144:6 146:1 150:6 Michael 31:10,12 32:5,6 124:2 141:4 144:2,6 145:25 148:15 Michaud 147:7 147:18 148:2,5 mid 120:24 139:21 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 middle 139:12 149:7 Midwest 5:4,9 6:22 154:17 155:1 mid-1970s 11:10 Mike 125:5 mind 13:15 17:2 34:13 45:16 47:25 86:8 94:15 109:20 115:22 117:10 135:15 138:7 mine 95:18 minimize 105:3 minimized 104:9 ministry 75:21 93:1 94:3,9,10 94:12 111:25 140:15 150:14 Minneapolis 1:6 3:6,22 4:8 9:19 44:8 92:25 109:25 146:18 146:24 154:5 155:6 156:2 Minneapolis/St 133:23 Minnesota 4:5,11 4:11,16 38:19 42:24 43:2,6,11 43:16 47:20 85:22 86:12 154:11 155:4,5 minors 67:24 143:23 144:4 minute 19:6 45:17 51:9 64:14 minutes 2:7 33:10 36:5,6 mischaracterizes 113:25 misconduct 89:6 149:4 misjudgment Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 55:22 mismanagement 55:10 misquoted 93:17 Missouri 1:2 3:2 3:15,17,19,20 5:3,5,10 154:2 154:19 misspelled 62:3 misstated 55:14 78:4 124:7 misstates 82:20 103:19 116:5 mistake 17:22 105:3 mistaken 32:4 mistakes 105:5,6 105:7,9 107:25 MO 153:4 mom 16:21 19:4 23:11 moment 14:11 49:20 79:20 123:23 148:12 Monday 53:23 Monsignor 31:10 months 77:24 137:24 morning 7:3 8:13 114:1 Morphew 93:9 93:20 mother 80:4 84:3 motives 144:13 146:5 move 130:14 131:17,17 moved 26:8 72:2 72:9 89:18 130:18 131:11 133:14 142:8 144:15,17 moves 25:24 moving 132:6 mucous 129:19 N N 2:1,1,1,6 4:1 154:18 name 6:20,21 7:3 8:14,15 10:21 15:8 22:24 24:20 47:25 48:3 54:13 55:7 55:18 65:1 70:24 115:22 135:22 154:9 156:1,2 157:11 named 83:20 names 144:8 name's 71:1 126:9 nation 108:15 nature 67:23 69:2 necessarily 118:7 necessary 22:17 39:22 157:9 need 12:14 21:4 22:20 41:12 64:24 65:22 needed 41:3 needs 19:15 40:24 neither 153:10 Neuberger 65:11 65:13 never 11:15 12:20 51:8,23 73:1 103:10 105:25 111:20 113:9 117:5 122:19 123:21 129:16 142:24 144:14 newly 133:16 news 88:22 newspaper 2:11 88:16 night 146:18 nine 3:12 64:6 nodding 116:22 nomenclature 136:25 www.midwestlitigation.com noon 53:10,11 normal 119:5 154:16 North 5:5,10 Nos 6:9 notarized 155:15 notary 154:23 155:13 157:23 note 7:7,14 27:3 37:21 39:3 42:4 61:22 124:6 notes 13:19 42:12 60:23 61:1,8,12 61:15,17,18,20 61:24 65:6,9 95:11,18,19 notice 49:9,10 140:16 141:10 noticed 7:6 November 53:18 53:24 56:10 57:19 66:11 139:9 nude 129:2 130:6 number 10:8 29:23 36:10 59:17 134:9 138:17 145:15 numbers 49:7 113:24 115:19 133:19 141:15 objection 19:7,22 19:23,25 21:13 37:6,6 39:16,17 39:20 46:4 70:17 76:14 77:2 80:24 82:20,22 103:19 109:6 115:16 137:8 objections 39:21 observing 7:1 obtain 102:11 obtained 29:5 obvious 72:11 obviously 20:8 51:12 58:24 59:10 60:11 62:8 63:2,16 74:16 75:16 82:25 83:16 94:16 97:17 100:16 103:5 103:15 104:22 106:10 124:14 occasion 29:4 occasions 7:18 14:23 15:2 129:23 145:15 O occur 84:11 O 2:1,1,6 occurred 46:8 oath 8:17 14:13 101:1 52:5,11 occurrence 18:6 object 12:13 21:9 offended 24:23 21:20 33:4 30:1 94:3,9,10 51:10 67:12 110:11 111:11 70:7,15 71:11 135:14 72:20 74:2 offender 111:24 76:12 77:13 offenders 87:17 79:21 81:16 120:2 150:1 82:23 90:2,18 offending 25:7 91:15 94:4 offer 52:20 100:14,23 office 28:11,12 104:18 106:8 35:9 58:6 146:2 106:21 108:16 OFFICER 154:6 108:24 110:16 offices 3:14 6:19 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 official 10:6 24:12 25:5 30:1 30:6 52:25 54:23 70:3,11 80:7 93:22 100:5 112:7 113:2 133:2 146:10 150:18 officials 15:13 24:2 31:11 93:1 97:13 102:2 106:14,18 108:6 112:2 113:14 114:6 114:10,11,15 115:3 oftentimes 100:18 150:15 oh 50:11 62:20 91:21 116:7 117:21 124:11 138:19 151:11 okay 10:10 16:4 22:9,21 26:17 32:20 33:7 36:14 39:11 42:10 50:14 58:10,20 59:16 60:13 65:8,15 66:2,3,8,20 73:3,22 76:8 77:9 79:7 81:10 82:2,5,9,14 83:4,15,20 84:2 92:21 96:14 101:1 107:6 109:2,7 111:5 114:19 115:1 117:6,21 118:6 119:10 120:14 121:16 124:11 124:15 125:13 128:10,22 131:3 132:3 134:16 135:24 137:19,22 138:21 140:1 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Olaf's 146:23 old 119:1 Olive 3:15 once 28:2,4 101:19 118:2 139:14 ones 24:25 32:9 128:1 one's 123:10 opinion 75:12 104:19 opportunity 22:17 opposed 72:2,9 options 58:3 ordained 8:25 26:6 100:1 108:21 order 15:12 113:13 114:5 115:2 ordered 73:17 ordinary 24:13 54:22 organized 150:18 original 2:20 49:15 154:9 155:10 Orsborn 3:16 5:3 6:5,20 153:3,21 155:22 other's 129:4 outcome 153:15 outrageous 19:17 outset 19:8 outside 40:25 41:4 97:21 overheard 71:7 o'clock 3:13,13 O'Connell 31:10 31:12 45:12 141:4 144:3,6 145:11,25 146:5 148:15 O'Connell's 146:1 127:21 parish 53:2,13 P 4:1,1 62:11,15 68:5 page 2:3 36:8 69:18,21 71:8 49:6 50:7,7 71:23 72:2,10 63:4 69:10,13 72:10,15 74:23 88:18,25 90:7 121:9 125:17 91:17,19,22 126:21 127:1 92:6 96:3 104:1 128:4 130:19 114:23 145:20 130:21,22 147:8 149:7 131:12 132:25 152:4 155:10 133:4,16 155:13,16 134:20,21 156:4,8,12,16 135:6,13 142:1 156:20 146:23 147:13 paid 102:16 147:14,21 110:20 111:12 148:1 154:16,16 parishes 62:22 painful 150:10 71:19 124:23 150:10,12 132:19 134:11 paper 116:16 135:1 136:17 papers 35:7 Paracletes 107:8 parishioners 93:21 133:3 108:4 110:10 134:3 135:10 111:9 112:9 135:12 136:18 paragraph 40:3 park 52:22 78:12 40:5,20 41:11 146:17,25 52:18 53:8 147:3 68:18 75:22 79:13 83:2 90:8 parking 112:16 97:23 102:9,19 part 26:23 36:5 36:10 55:11,22 124:8 129:15 75:20 110:15 132:4 139:12 139:15 146:17 144:23 145:13 149:4 145:24 146:4 participated 34:8 146:15,16 particular 13:7 149:1,8,8,18 18:13 23:20 parent 17:1 27:15 117:10 22:22 68:7 particularly 25:5 parents 15:8 75:14 16:10,16 17:2 parties 6:24 17:17 18:18 153:11,14 34:19,20 48:3 pastor 10:5 11:19 80:3,6,9,14 37:10 52:21 81:8,18,25 82:3 53:11 68:4 82:13 83:1,11 74:14 76:22,25 84:6 113:16 87:23 114:8 126:25 www.midwestlitigation.com P pastoral 38:20 40:24 Patel 4:3 7:1 Pates 139:7 Patrice 65:11,13 68:5 Patrick 4:21 7:2 pattern 55:9,21 56:8,8,13,14,17 56:22 57:2 Paul 1:6 3:6,21 4:5,8,11 6:17 9:5,18 35:9 44:7 52:22 77:21 78:12 82:4 83:20 92:24 109:24 124:23 133:23 140:9 154:4,11 155:5,6 156:2 Paul/Minneap... 7:23 8:2 10:4 10:11,17 11:3 14:25 15:23 24:22 32:18 40:17 42:19 43:12 52:21 84:18 113:12 120:3 134:17 138:9 peck 61:21 pedophilia 92:10 94:19,25 136:24 penalty 157:12 pending 3:18 people 11:4 15:3 16:5 17:11 18:1 24:24,25 32:15 57:6 68:8,9 72:12 77:11 79:24 80:19 89:21,23 90:14 92:15 93:23 100:25 105:6 105:11 115:6 115:21 116:12 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 130:21 134:10 148:1 150:19 percent 121:6,7 period 9:17 18:23 25:11 85:15 94:5 98:9 128:25 142:3 145:10 perjury 157:12 permission 68:16 permitting 136:16 person 12:1 16:6 65:1 126:22 130:25 154:9 personally 15:10 15:11,12 19:9 27:18 112:12 personnel 9:20 11:11,15,22 12:6 25:19 26:19 31:17,21 32:1,11 35:4 36:2,4,18 37:3 38:13,21,25 39:3 40:22 41:3 41:8,9,16,24 42:4 52:19 53:4 53:13 71:20 73:9 persons 16:5,6 pertaining 13:21 14:5 23:15 61:15 66:21 89:8 103:16 112:20 113:8 pertains 36:12 pertinent 22:10 physical 20:9 picked 144:24 picture 89:7 Pierre 40:7,10,12 40:16 43:25 44:3 59:18 68:12,14 69:1,5 78:17,22 108:4 110:9 112:8 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Pioneer 90:15 place 22:4 35:23 54:4 58:9 71:8 73:8,15 78:17 118:15,18 129:17 146:19 placed 71:2 72:15 placement 71:19 places 32:21 43:15 101:22 105:12 Plaintiff 1:4,12 3:4,21 4:2 6:2 8:10 please 6:23 8:6 8:13 19:22 155:9,11,15 pleased 52:20 74:14 point 11:25 32:5 32:17 34:9 35:12 40:2 45:7 45:12 47:12 49:24 56:7 59:16 67:3 75:1 90:5 127:21 141:23 pointed 55:9,21 points 59:1,4 police 14:19 15:4 16:17 17:3,9,14 18:18 19:4 22:25 23:13,15 24:4 34:15 48:4 74:8 80:5 84:5 84:8 115:7 127:6 131:11 132:14 policy 38:24 92:9 92:14,21,22,24 93:13 94:18 popular 121:20 121:22 portion 53:22 88:19 possess 14:21 possibilities 76:4 possible 20:21 24:17 40:7 57:23 62:10,19 62:20,21 92:13 possibly 37:1 posture 104:8 105:4 practice 60:25 61:20 67:1 101:25 118:13 practices 105:13 preceding 43:8 precipitated 60:15 predated 101:3 preparation 9:10 50:16 prepare 126:13 prepared 7:21 18:22 58:15 65:5 66:24,25 70:4 86:1 95:7 95:8,9,10 96:6 96:7 118:2 128:12 presence 58:22 present 4:19 6:23 7:9 8:3 28:15 28:17 30:13 58:23 121:24 presented 28:25 41:9 presiding 104:3 Press 90:15 presumably 144:7 presume 65:5 pretty 35:7 54:20 101:22 113:19 previous 21:25 priest 8:23 10:10 10:12,21 11:7 13:14 17:6,18 17:25 18:5 24:11,12,21 25:6,18 26:19 www.midwestlitigation.com 26:22 29:17,25 30:7,19 36:16 36:19 37:10 40:16 43:12 54:19,23 62:11 62:14,15 70:22 78:12 89:6 93:1 100:1,6 108:1 108:21 109:17 113:1,3 122:2 133:14 134:4 134:21 135:3,7 135:12 138:13 141:22 143:16 145:17 priests 11:14 12:3 13:4 16:7 35:5 40:21 41:12 43:15 62:22 79:3,5 85:16,19 88:2 94:3,8 102:3 110:11 111:8 111:10 114:11 115:3 138:17 printed 60:3 prior 6:11 149:10 155:16 prison 84:12 privilege 112:1 probably 34:12 50:12 95:17 96:9,12 98:20 102:14 problem 89:19 108:13 129:17 149:13 problems 43:7,25 107:13,14 proceed 8:7 process 8:16 97:24 132:1 produced 3:11 8:9 71:17 72:24 progress 149:21 prohibited 92:25 promise 120:16 prosecuted 70:13 22:13 25:13 80:23 81:14 27:17 29:17 prosecution 83:8 31:2,4 33:5 protect 144:9 34:4 36:14 39:7 protecting 102:3 40:21 41:15 protested 121:8 42:10 44:10,17 protocol 118:23 45:5 49:9 50:5 providers 112:8 50:8,14,22 providing 110:23 51:10 53:23 psychiatric 140:9 54:14 55:20 psychological 64:18 65:19 20:9 140:10 67:13 68:19 psychologist 69:14 70:8,16 40:18 42:20 71:9,12 72:21 public 70:14 74:3 77:14 73:12,25 89:13 79:14,22 82:18 91:23 108:11 85:10,12,14 133:15 154:23 90:3,9,14,19 155:13 157:23 99:6,14,23 publicity 104:9 100:10,11,15 105:3 106:6,11 101:17 104:19 144:10 147:13 106:9,22,22 publicly 75:25 108:17,18,25 published 75:23 109:3,3,5,7 76:3 111:2,6,16 pull 29:23 112:3,4,5,24 pulls 137:12 113:7,21 114:2 purposes 35:24 114:13,18,19 117:14 139:6 115:1,9,20 put 12:14 20:11 116:9 118:12 23:8 29:8 37:20 124:17 133:1 56:11,12,13 133:12 134:5 59:1 64:16 139:20 141:16 75:18 83:22 144:18 149:21 142:6 147:19 questions 2:4 puts 141:10 8:12 20:19 21:5 putting 88:15 32:17 46:20 P.A 4:4 154:10 50:18 64:22 p.m 7:13 151:13 100:19 117:21 152:10 126:15 138:12 151:19,24 Q Quinn 4:10 quadrant 123:7 155:3 question 7:21 quite 73:12,24 12:14 14:11,18 84:23 95:14 19:7 20:3,15 quotation 92:8 21:2,10,15,21 93:7 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 quote 21:25 90:10 quoted 24:19 88:17 90:8 91:3 92:3,7,18 94:22 quotes 93:8 ready 37:11 143:13 real 130:22 realization 88:1 realize 11:6 realized 108:13 really 10:2,15 R 24:17 62:10 R 4:1,15 37:25 77:10 83:7 77:18 128:12 87:19 92:9 154:14 94:18,24 racquetball 100:17,21 130:5 reason 10:1 42:8 radar 10:22 11:2 47:1,8 48:10 76:10 77:12 54:5 56:25 58:9 rape 77:24 59:3,21,25 60:7 Raphael's 125:20 62:24 63:13 126:17 127:10 74:4,21 76:19 127:11,12,14 78:10 81:22 127:15,19 85:17 87:16 131:8 142:7,9 88:14 97:21 rate 87:11,18 100:20 102:25 90:4 112:15 130:22 read 36:13,15,15 133:6,14 134:6 37:22 40:20 156:6,10,14,18 41:1 52:17 156:22 53:22 55:19 reasons 75:9 58:15 59:11 76:16 77:15 61:10 62:4 reassigned 75:16 64:12,19 65:2 recall 9:21 17:13 65:21,24,25 17:13 38:17 66:2 68:19 46:17 48:17,22 79:13 82:24 70:10 71:9,22 85:10 90:8 92:7 79:10 103:22 96:12,25 98:10 103:23 107:4 105:20 123:1 128:3 140:1,24 124:9,11,14 149:17 135:22 147:19 receive 10:11 155:11 156:5,9 43:7 126:7,9 156:13,17,21 received 17:7 157:6 20:11 23:14 reading 55:16 47:22 50:20 64:23 66:4 72:18 74:16 81:19 82:11 124:1 126:5 91:20,22 96:15 131:25 142:24 104:15 132:1 150:20 reads 96:23 receiving 37:2 www.midwestlitigation.com 74:19,20 124:20 126:8 126:12 129:8 132:2 recidivism 87:11 87:18 90:4 recipient 123:12 recognize 36:3 recollection 22:18 38:22 41:2 42:16 44:22,24 53:12 54:7 65:23 66:4 78:21 98:5 149:5,15,20 recommend 107:7 recommendation 52:19 104:1,2,6 104:7,12,14,16 105:15 130:9 130:10 131:20 recommendati... 11:16,23 131:21 recommended 102:10,11 136:7 recommending 57:18 record 6:13 7:14 8:14 20:2 45:20 45:23 46:24 56:18 58:10 60:18 65:9 68:14 78:3 82:16,19 85:4,7 85:9 98:16,17 99:22 108:5 121:5 124:6 151:14,17,22 recorded 8:20 37:18 55:12,24 56:9,23 58:13 59:19 60:22 63:19 66:3,10 74:24 82:9 98:1 98:2,25 99:14 102:22 130:16 recording 58:17 83:1 records 8:22 9:24 67:3 69:22 132:24 recovery 92:11 94:20 redacted 123:13 redirecting 83:2 reduced 153:9 refer 35:22 77:16 122:18 147:4 reference 19:19 30:12,23 52:15 139:5 referencing 71:16 132:23 referred 36:24 39:4,13 107:2 125:25 126:3 137:18 139:10 referring 30:25 31:19 37:18 71:13 106:3 117:15 139:22 139:24 140:19 refers 69:2,3 139:9 140:22 146:21 reflect 9:24 42:12 46:11 65:3 67:3 69:22 101:20 132:24 reflected 66:13 70:4 reflective 69:12 reflects 42:4 46:24 55:9,21 56:8 76:9 97:11 103:11 132:18 Reformatory 77:22 97:10 refresh 14:9 16:19 21:3 22:18 38:21 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 41:2 42:16,22 65:23 66:4 69:23 78:21,24 98:4 149:5,14 refreshed 16:13 refreshes 64:16 regard 37:7 116:5 regarding 67:7 131:24 137:13 140:7 regardless 19:17 region 133:10 regions 125:2 register 19:7 37:5 regular 152:7 Rehab 77:22 related 7:10 69:5 153:11 relates 91:22 relating 117:22 relationship 79:1 128:18 relationships 85:19 relative 153:13 relied 108:3 religion 93:9 remember 10:2 10:15,20,23 11:1,5,8 13:7 13:18,23 14:1,2 14:4,10,12,19 14:19 15:8,16 16:6,9,15,18,22 16:24 17:1,2,15 17:17,24 18:16 19:17 20:5,7,20 20:21,22 21:6 21:17,18 22:1,8 22:9,11,16,20 22:23,24,24 23:9,19 24:6,9 24:25 27:5,8,16 28:3,8,14,16,17 28:25 29:2,8,14 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 29:19,22 30:3 30:10 31:7,21 31:24 32:1,8,9 33:1,9,11,14,16 33:18,24 34:2,5 34:7,8,11,14,14 34:18,21,24 35:5,12,15,17 35:21 36:17 37:2 40:9,11,12 41:6,7,15,24 42:1,6,7,9,11 42:14,15,25 43:22 44:1,9,18 45:3,5,14,15 46:8,12,13,22 46:23 47:7,10 47:12,16 48:5 48:15,21,23 50:24 51:6,7,13 51:17,25 52:5,9 52:10 53:15 54:4,10,14,17 56:11,22,24 57:15,16,17,24 58:2,7,8 59:3 59:13,14,20 60:6,13,21 62:6 63:23 64:10,18 64:22,24 65:11 65:19 66:20 67:22 68:9 69:4 69:7,8 70:21,25 71:3,5,20 72:3 72:4 73:18 74:5 74:9,19,20,22 74:25 75:1,5,14 75:19 76:1,5,7 76:18 77:8 78:8 78:9 79:7 81:21 82:5,6,13,16 83:5,18,24 85:17,20,24 86:3,7,11,21 87:4,6,9,14 88:7,22 89:12 89:13 90:15 91:1,8,10 92:1 92:13,17,18,22 92:23 93:9,14 93:16,24 94:7 94:11,11 95:1 95:13,20 96:8 97:1,3,4,18 99:6,13,18 100:3,17 101:10,11,14 102:15,18 103:9,14,16 105:19,25 106:17 107:23 109:15,19,22 110:13 111:19 112:14,15 113:5,10 115:5 115:9,11,14 122:2 124:21 127:9,20 128:2 128:7,8,19,20 129:8,10,12,19 130:1,3 131:9 132:2,10 134:8 134:15 135:5 135:21 136:2 136:10,13,15 136:16 137:20 137:25 138:3,7 140:12,16 141:17,19 142:22 143:4,8 143:21,24 144:22 145:6 145:12,16,22 146:2,8 147:8 148:20 151:5 remembered 115:14 remembers 64:20 remembrance 103:4 removed 70:1 72:1,6 75:2,4 91:6 127:1 www.midwestlitigation.com 128:7 render 157:9 repeat 105:10 replace 118:22 replaced 32:6,14 report 14:5,25 15:4,10,11,13 16:5,7 17:14,18 18:17 19:3 23:2 23:12 24:3,11 31:8 36:8 53:10 53:25 54:3 59:8 59:23 60:14 63:3,5 65:4 66:14,17 71:12 71:17 84:8 86:5 113:3,5,14,20 113:22 114:6 115:3 127:19 129:5 131:13 137:16,17 141:5,9 146:11 146:13 147:6 150:15 reported 23:3 24:21 25:1,1 28:22 70:4,5 71:2,6 72:14,17 80:22 81:15 90:22 103:24 113:9 127:23 127:25 128:1 131:10 143:19 143:23 reporter 2:21 3:17 5:2 6:5 8:6 84:14,17 85:22 86:5 92:4,18 93:9 153:1,4,5 reporters 85:17 reporter's 6:20 reporting 14:19 80:5 84:4 87:7 102:6 108:14 109:1 134:10 reports 10:18 12:2,11,18 18:21 24:24 72:11 142:24 147:11 150:20 151:1 represent 6:24 49:11 139:7 representation 94:1 116:6 represented 92:14 147:21 representing 7:22 25:20 35:4 107:3 request 7:8 27:10 131:12 requested 68:8 requesting 68:9 required 78:22 137:24 154:16 requirement 86:6 requirements 87:7 reread 55:17 83:11 resign 72:15 73:5 resignation 57:11 58:3 130:23 resigned 130:19 130:21 resonance 42:20 respond 20:14,17 85:11,13 responded 21:24 response 28:24 69:24 responses 29:2 responsibilities 10:9 26:23 responsibility 11:20 13:5 31:14 59:7 84:12 105:9 108:2,6 responsive 28:19 29:11 33:3 69:9 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 124:21 Restovich 4:15 restriction 66:9 66:12 result 120:17 retained 2:20 61:17,19 return 155:15 returned 111:25 returning 140:15 revealed 101:7 101:10,12 Reverend 37:24 38:18 97:7 137:14 140:6 review 8:22 17:21 22:4,17 reviewed 9:10 91:25 112:19 124:10 re-offending 138:5 Richard 148:19 Riedel 77:23 Riedle 7:17 46:18 46:23 48:1,3 49:1 81:15 83:21 97:9 98:13 Riedle's 101:4 right 9:8 49:14 54:24,25 56:14 76:21 80:23 85:8,9 88:13 94:15 108:23 109:25 110:4 115:22 125:10 148:16 right-hand 49:7 123:1,7 Ringsmuth 77:21 82:4,13 83:3,10 83:12,20 84:6 Risen 69:22,25 74:15 risk 75:18 136:13 risks 136:19 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 Roach 9:20 10:7 34:10 36:23 37:17,25 38:16 39:4 41:12 48:9 48:16 52:17 67:6 74:13 77:19 83:16 95:5 103:18 104:3 119:22 121:9 122:13 123:12,24 128:12 130:10 131:24 132:17 137:13,23 141:3 147:21 148:14 Robert 1:11 3:11 6:4,16 8:8,15 64:8 128:15 137:14 140:6 144:5 145:25 148:14 154:7 155:9 156:1 157:5,20 Robertson 4:21 8:1,1 Rochester 4:16 role 12:9,22,23 13:3 16:12 106:15 Rome 15:24 room 119:13 130:1 RPR/CSR/CCR 5:3 155:22 RSMO 154:7 rubs 128:24 Rule 154:7 run 79:15 80:1 80:21 81:11 running 151:10 S S 2:6 4:1 sacristy 143:13 safe 93:23 sample 125:4 sandwich 73:18 sauna 130:6 Savior 69:22,25 74:15 saw 18:3 39:2 65:16 74:23 123:21 140:8 146:17,20 147:3 saying 20:24 21:1 42:6 49:24 59:12 91:1,3,8 91:9 92:3,13 93:14 100:10 128:22 145:16 says 8:10 36:16 39:3,4 40:4,5 52:18,23 53:8 60:16,18 64:13 66:14 68:17,23 74:13,18 76:25 80:19 90:9 95:21 97:16 102:25 103:15 106:2 122:14 123:25 140:23 144:20,23 145:24 146:4 146:16 148:11 149:1 scandal 63:15,17 63:25 70:14,20 77:12 102:1,4 106:6,10 scandalous 118:9 118:24,24 119:3 scheduled 48:18 Scheffler 138:8 school 108:11 143:7 Scott 4:20 8:4 seal 119:6 sealed 118:6 Sec 154:7 second 40:3,4,20 41:10,11 53:7,8 www.midwestlitigation.com 88:18 90:6,8 92:6 96:3 97:23 104:1 139:12 145:20 147:7 149:1,7 secondly 76:18 91:16 second-to-last 146:15 secret 118:8 119:3,10,11,18 see 15:3,9 19:16 20:18 24:18 36:2 37:14,16 37:17 38:8,12 38:14,15 41:19 41:21,22 42:20 49:3 52:16 60:4 64:12,16 68:8,9 78:22 84:21 88:16 96:20 102:10 103:17 112:22 114:9 123:17 135:22 136:1,2 140:9 147:2,7 seeing 38:24 40:10 41:6 43:25 44:3 68:15 78:17 135:21 seek 106:23,25 seen 39:1 42:11 62:14 78:23 82:25 95:7,24 122:19 147:9 selected 79:7 seminary 25:16 35:9 125:10,22 send 43:14 78:24 79:8 107:13 152:3 sending 136:2 140:1,14 senior 62:22 sense 60:1 150:17 sent 18:22 66:23 83:22,24,25 89:23 105:23 107:8 111:8,11 112:11 118:4 119:3 126:6 131:14 148:22 148:25 sentence 40:4 41:11 53:7,8 55:15 81:25 107:6 141:6,8 145:13 149:18 separate 118:8 122:21 serious 67:19 68:2 99:1 108:13 141:11 149:13 seriousness 104:7 105:16 105:17 106:3 Service 108:4 110:10 111:9 112:9 Services 5:4,9 6:22 40:18 110:10 154:17 155:1 serving 77:24 78:12 149:25 session 68:13 seven 20:10 sex 45:7 87:11 89:6 99:1,21 100:13 108:22 109:10,14,17 122:14,21 123:6,14,17 139:18 sexual 12:3,19 13:4,4 15:1 23:16 24:3 26:22 27:14,23 28:1 29:16,24 31:6,15,22,25 33:12 34:7 54:12 55:8 56:7 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 56:16,17 57:2 67:23,24 68:2 69:3,6 72:11 77:24 86:9 87:7 87:17 88:1 89:8 90:11 91:4,14 97:14 98:19,21 98:25 99:10,11 99:11,21,24 107:14 110:2 112:21 113:3 113:15 114:7 115:4 116:1 117:1 121:2,11 122:18 129:5 133:14 134:3 134:22 136:22 139:21 144:4 144:11 145:4,9 147:11 149:4 sexually 44:12,25 56:6 97:25 share 22:3 shared 22:22 33:7,10 34:13 41:25 42:1,5,13 47:19 77:15 83:16 Sharon's 147:16 sheet 49:3 156:1 sheets 50:3 155:10,12,15 sheriff 130:15 shocking 54:20 shorthand 6:4 153:4 shorts 129:2 show 15:7,15 17:4 20:15 48:24 74:10 122:8 showed 126:11 showers 129:3 shredded 61:13 sic 64:24 77:20 124:1 side 102:3 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 sign 90:13 155:12 signature 6:7 38:9 152:8 155:10,12,16 156:24 signed 38:8,9 49:10,15,21,23 49:25 similar 147:18 similarity 130:8 simple 29:23 simply 11:22 49:9 51:3 Sincerely 155:19 Sioux 15:18 25:4 101:21 120:22 134:13 sir 71:17 Sister 65:11,13 68:5 124:4 139:7 sisters 116:15 117:23 sit 44:9 92:19 situation 132:7 six 3:13 58:12,25 sleep 129:23 slipped 145:2 social 127:21 soliciting 146:19 somebody 17:8 17:14 25:1 27:3 30:8,9 80:9 82:8 94:23 95:12,14,17 106:2 123:14 143:6 someplace 71:25 somewhat 42:23 son 127:1 128:5 sorry 108:19 116:8 sort 134:15 sound 9:8 sounds 130:6 source 10:12 sources 37:3 south 113:5 146:23 147:1 speaking 16:14 57:24 speaks 49:22 specific 19:15 speculate 76:6 speculation 76:13 77:14 100:15 spell 13:24 14:16 spent 112:23 spiritual 125:8 125:11,15 spoke 57:23 58:11,21,24 spoken 68:3 72:23 St 1:1,6 3:1,6,15 3:19,21 4:5,8 4:11 5:5,10 6:17,18 7:10,23 8:2 9:5,6,15,18 10:4,11,17 11:2 14:25 15:23 24:22 26:2,18 32:18 35:9 40:17 42:19 43:12 44:7 52:21,22,22 77:22 78:12,23 79:6 84:18 86:18 87:2 92:24 97:9,24 107:22 109:24 111:10 113:12 120:3 124:23 125:20 126:17 127:10,11,12 127:14,15,18 131:8 134:17 135:19,19 137:17 138:9 140:15 142:2,6 142:9,10 146:23 154:1,4 www.midwestlitigation.com 154:11,19 155:5,6 156:2 staff 30:9 stamp 122:8,14 122:17,19 123:1,10,13,13 123:20,21 126:4 stand 78:6 stands 78:13 started 134:8 Starting 1:14 state 1:2 3:2,17 3:20 8:14 36:23 37:9 44:15 54:12 57:7 98:7 128:22 129:22 143:7 144:9 145:14 154:2 157:1 stated 55:5 129:22 130:15 statement 20:2 22:12 42:8 63:18 90:19,21 91:12,24 92:20 93:13 94:16,21 103:6 147:13 154:6 statements 88:20 147:14 states 38:1,16 40:21 55:8,20 75:23 97:6 128:16 129:16 132:4 145:20 149:19 stating 41:12 81:8 137:14 140:7 144:5 149:8 stationery 38:2 status 38:22 100:24 statute 79:15,18 80:1,12,21 81:6 81:10 82:6 83:7 statutes 81:4 stay 42:18 steak 73:18 sticks 112:17 stink 73:6 STIPULATED 6:1 stop 118:13 stopped 118:11 stream 101:8 street 3:15 4:4,11 4:16 5:5,10 146:24 154:10 154:18 155:4 strictly 7:5 32:17 95:21 117:25 118:3 119:4 strip 129:1 studied 15:25 26:9 study 43:15 120:8 studying 15:24 26:13 32:5 43:3 47:20 subject 17:19 64:9 77:19 95:6 128:15 141:5 144:3 147:6 subordinates 113:14 subscribe 157:11 substance 157:8 substantive 110:15 Sue 124:4 suggested 17:3 41:18 suggestions 15:16 Suite 3:15 4:4,10 154:10 155:4 summertime 142:8 supervise 138:4 supplied 120:19 supporting MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 110:23 111:4 sure 28:3,13 30:8 32:21,21 36:6 46:15 58:23 62:20 63:16 66:1 67:22 71:12 77:10 79:4 84:23 87:13 93:5,6 109:11 110:1 110:19 112:19 113:19 117:15 117:16 121:16 121:19 126:22 127:24 128:1 130:24 151:8 surfacing 121:2 surgeries 20:10 surprised 36:22 surrounding 116:11 survivor 151:3 suspected 10:13 10:19 suspend 57:12 suspicions 24:3 113:3,14 114:7 115:4 swear 8:7 swim 144:25 145:1 sworn 3:11 8:9 153:7 T T 2:1,6 take 7:21 12:23 45:16,18 58:9 64:14 71:9 73:4 84:24 85:1 105:9 117:24 129:3 130:5,6 140:14 151:12 152:5 taken 1:12 6:4 7:18 13:5 14:6 14:22 45:21 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 46:25 49:1,4 57:17 69:8 85:5 121:10,18,19 144:8 151:15 153:8,12 155:9 156:3 takes 146:19 150:16 talk 18:1 25:23 52:13 81:9 85:2 112:10 140:17 talked 86:9 128:9 130:25 talking 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59:9 testified 7:16 60:24 62:17 18:24 27:14,23 65:3,22 68:23 33:12 51:5 72:7 69:3 70:18 testify 48:22 71:25 74:7,8 51:19 52:5,9 75:9,12,13 80:6 56:21 138:10 83:24 86:16 testimony 9:11 87:25 89:17,20 39:17 47:4 89:21 91:5 51:23 82:21 100:4,20,24 113:25 142:23 101:19,22,24 153:6,8 104:24 105:2,5 testing 140:10 105:5,6,8,13,20 Thank 7:21 107:16 108:2,8 39:22 78:6 108:8,10,10,11 151:19,20 108:12 113:24 therapist 88:7 114:8 115:6,21 108:2,3 118:21 119:2 therapists 87:10 119:13 120:7 88:10 108:10 120:25 125:22 therapy 69:11 126:4,16 149:22 127:15 133:8 thereon 157:10 134:19 135:8 thereto 153:14 137:1 138:11 thing 24:13 141:10 142:4 28:21 36:4 150:18 151:11 50:23 51:5 52:6 thinking 63:17 54:20 73:24 www.midwestlitigation.com 63:20 67:4,15 64:2 85:15 69:9 70:2,12 99:19 105:19 72:19,21,21 third 75:22 132:4 74:25 75:21,24 144:23 145:24 83:1,17 84:20 149:8,18 84:22 85:3,6,15 Thomas 1:7 3:7 85:16 89:7,22 3:22 4:9,15 91:4 93:19 94:5 7:24 13:15,21 97:1 98:9 99:8 27:3,6,9 33:11 99:19,23 100:7 35:13 36:13,16 101:5,25 38:18 52:22 104:13,17 53:19 67:7,9,19 105:24 106:20 78:1 95:6 97:7 107:11 111:15 154:5,13,14 111:17 112:23 155:3,6 156:2 112:25 118:10 thomas@resto... 119:4,25 120:8 4:17 120:25,25 thought 47:19 121:2,6 122:5 68:23 73:17 122:24 123:22 75:10 83:1 87:4 124:24 125:1,7 93:3 111:3 125:8 133:13 114:16 127:17 133:13,20,21 142:4 143:6 134:18 139:5,5 three 7:18 14:22 141:24 142:3 22:2 117:4 146:18,23 125:1 134:7 147:15 150:16 137:24 150:21 151:1,3 thrown 61:13 151:6,10,13,16 ticked 74:22 151:21 tight 145:3 times 13:10 21:1 time 1:14 6:14 21:24 23:13 7:11,21 9:17 24:1 27:6 28:6 10:16,21 11:6 29:1 46:7 11:25 12:14 105:11 108:20 15:23 18:7,10 title 16:12 18:23 20:10 today 7:4,12 8:19 25:3,5,11,21 9:10 14:4 17:3 26:6,19,21,25 19:2 24:14 30:12,20 31:9 27:25 33:14,17 34:22 35:5 42:10 44:9,22 38:22 39:13 44:24 45:4 50:5 41:13,13,25 50:17 51:6 43:5,18,24 56:21 92:9,19 45:19,22 50:12 93:14 94:18 51:25 52:15 103:16 109:12 54:5,8,9,10 113:21 121:16 55:5 59:6 61:16 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 147:8 149:25 today's 6:14 151:22 told 16:16 17:14 22:1 23:19 46:7 50:25 51:5 57:10 59:2 62:9 73:4 74:8 79:24 79:25 80:6,9,9 80:14 81:8,18 82:3,8,10,11,24 83:7 84:6 90:20 98:18 102:20 103:25 105:12 113:16,16,22 114:8 126:24 126:25 127:24 127:25 130:22 135:2 137:25 142:19 146:16 tolerated 57:8 Tom 4:20 7:22 8:5 10:22 24:20 28:16,20 29:6 29:17,25 33:16 34:5 36:1,18 45:25 52:17 77:20 94:12 97:19 124:3 top 36:2,8 60:16 63:4 73:18 95:21 122:13 123:14 145:20 topic 29:20,24 88:18 117:8 148:18 TOTAL 154:12 154:13,14 totally 146:7 touched 145:4,14 touching 145:17 tough 50:20 Tower 4:10 155:4 trail 101:3 training 86:4,7 143:7,9 transcribed 6:6 61:9 transcript 2:8,21 154:9,15 155:12 transcription 8:20 transfer 133:6 transferred 69:18 133:14 treat 110:10 141:10 treatment 59:19 89:23 107:10 107:12,17,18 107:21 110:7 110:20,24,25 111:8,12,13 130:20 144:17 trial 7:19 27:13 27:24 33:12 34:8,9,17,18,21 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56:5 61:25,25 105:16 usually 41:23 61:2 71:19 112:10 125:14 150:2 utilize 107:22 110:8 vicariate 125:3,4 Vice 10:5 12:8 26:20 35:6 vice-versa 32:15 victim 55:19 68:7 77:24 148:19 149:4 victims 87:17 89:22 101:3,8 101:11 144:7,8 150:7,8,11,14 videographer 5:8 6:13,21 8:6 45:19,22 85:3,6 151:13,16,21 videotape 8:20 videotaped 1:11 3:10 6:3,15 viewed 112:21 vindictive 144:13 violation 66:12 violations 139:16 visit 102:23 visited 102:21 Vocation 25:10 25:14 35:6,8 Vocational 77:22 vs 1:5 3:5 49:1 138:8 154:4 155:6 156:2 V vacation 26:15 U 43:8 vaguely 45:15 Uh-huh 137:4 Valcour 135:20 Uh-uh 93:11 136:3 ultimately 11:17 Valley 26:3,18 69:17 74:15 142:2 uncommon various 10:3 32:1 43:14 150:14 underlined 95:22 vault 119:14,15 understand 8:17 verbal 23:7 21:4,15 33:6 versus 6:17 34:3 47:14,17 Vicar 12:7 27:11 91:21 109:12 30:13,17,21,24 111:1 112:6 30:25 31:4,7 114:17,18 122:4 W waived 6:7 152:9 waiver 112:1 Wajda 53:25 60:10,13,19,20 63:4,8 64:25 65:10 66:15,18 68:4 124:3 walking 147:3 Wall 4:21 7:2 want 13:2 14:10 17:21 18:25 19:14 20:17,19 24:17 39:23 44:21,21 45:18 46:15 64:17 U MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 76:19 82:14 96:20,25 100:19,21,21 132:21 151:9 152:6,7,7 wanted 15:4 22:25 32:21 84:3 85:11,13 93:23 99:16 113:20 115:7 144:16 warning 136:17 washing 129:3 Washington 16:2 wasn't 23:10 25:9 28:17 42:14 59:21 61:25 64:1 67:24 76:18 100:11 101:13 118:20 130:18 131:1,14 134:24 146:14 Watters 36:24 38:6,9 39:5 41:11 47:3,11 48:13,17 49:4 50:25 51:24 52:1 102:22,23 103:3,7,10,18 107:8 way 20:7 30:18 44:23 79:23 80:20 88:21 89:24 95:9 104:9 105:4 111:2 129:20 150:18 ways 11:4 89:22 Wednesday 128:17 week 112:16 115:18 weeks 38:18 50:12 went 26:15 35:10 47:13 48:19 57:7 75:9 83:19 85:9 86:22 108:14 130:19 134:11,25 138:9 141:17 weren't 48:11 104:10 we'll 22:16 97:3 we're 7:20 32:16 34:22 45:19 63:3 104:19,20 111:17 we've 84:23 101:19 112:19 123:10 134:6 143:5 whatsoever 79:22 whited 36:11 wide 18:10 Wieser 4:9 7:22 7:22 37:5 39:6 39:11,14,21,25 55:14 70:17 76:12 77:2 82:20 103:19 106:21 110:16 111:14 112:3 116:5 117:18 124:6,13,16 137:8 151:24 152:3 154:13 155:3,8 wiggle 129:19 willingness 40:6 Winona 1:7 3:7 3:22 4:14 7:25 11:7 36:16,19 36:20,25 38:3,6 38:10 40:25 41:4 42:17,18 43:8,13,19 44:8 60:5 70:23 72:16 152:2 154:5 155:6 156:2 wish 104:21 www.midwestlitigation.com witness 3:10 6:7 7:5 8:7 71:14 72:25 82:21 88:8 111:3 116:22 124:13 151:20 153:6,8 155:11 156:1 156:24 woman 140:17 149:2,3 women 140:21 140:22 wonder 151:6 word 12:15 56:11,24 89:19 124:10 words 11:23 55:12,24 56:1 104:10,11 work 37:11 38:18,20 40:24 87:16 worked 15:21 79:2,4 133:4 worker 68:5 working 73:1 worried 114:25 worry 114:23 worth 65:24 wouldn't 25:11 56:13 61:3,5,6 118:20 133:10 147:17 148:6 write 53:23 57:13 57:22 58:5,20 59:16,23,24 60:10 61:20 63:11 67:8,18 68:3,7,11,20,25 68:25 77:20 78:11,16 79:14 79:23,24 80:4 80:18 81:10 84:3,5 97:23 98:19 102:19 104:6 107:6 129:16 130:4 130:13 137:22 141:8 writes 123:14 writing 61:10 141:13,13,17 written 63:6 66:6 80:8,10,20 82:17 90:13 93:21 98:25 103:1 104:11 112:11 132:3 139:13 143:25 wrong 124:9 wrongfully 148:2 wrote 22:6 54:9 55:6 57:10 59:15 60:4,9,11 63:9,24 65:18 67:14 68:20 78:1,19 79:16 79:17 81:10,12 81:20,21 82:24 98:22,23 99:7 106:13 110:5 123:5 128:20 129:10 141:18 17:15,21 18:12 18:21 19:20 20:16 21:23 22:2 24:10,15 30:11,20 33:25 37:1 46:13 74:6 79:16 80:2,12 80:22 81:12,13 82:7 83:9 100:16 104:22 117:5 119:2 128:25 131:7 139:15 150:14 150:16 yesterday 137:15 young 15:8 72:12 90:14 149:3 younger 35:4 youth 62:4,7,12 62:16,23,25 66:9,11 75:20 79:11 142:25 0 084-003460 5:4 153:5 1 1 1:3 3:3,20 6:17 6:25 7:6 59:16 Y 65:8 88:25 Yeah 56:3 66:24 91:17 154:3 76:24 83:6 155:6 156:2 1st 37:12 137:12 89:11 95:17 96:14,19 119:9 1:29 85:6 124:16 134:1 10 121:6 138:20 150:6 10:11 1:14 6:15 year 16:14 30:15 10:30 58:7 31:3,20 37:1 100 4:4 154:10 40:24 41:4 67:5 101 2:11 6:9 117:19 125:6,9 88:15,15 127:8 135:5 11 128:17 148:13 142:21,22 11th 154:18 150:22,24 11:12 45:19 years 8:23 9:4,8 11:21 45:22 9:21 10:14 14:2 117 4:16 14:14 15:15 12 49:3 128:11 X X 2:1,1,6,6 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 12:20 85:3 13 77:24 131:23 133 2:18 6:9 147:4 14 77:25 140:5 15 53:9 144:2 16 77:25 88:17 19 86:24 1941 134:12 1960s 149:14 1969 143:20 144:18 1970 8:25 17:6 18:7 25:3,10 108:21 113:2 114:4 115:2 149:24 1970s 149:14 1971 126:15 1972 127:13 142:5 1973 9:25 12:25 25:19,25 26:2 27:1 32:3 35:3 42:4 108:15 1975 142:5 1976 25:10,14 35:3 36:3,17 37:15,21 53:10 1977 9:25 1978 97:25 1979 35:11,20 1980 53:18,24 56:10 57:20 64:7 66:11,13 67:5 68:12 91:25 110:3 1980s 45:8 86:2 139:18 1981 74:12 1982 77:25 98:1 1984 15:18 77:18 77:21 78:4 95:4 97:6 101:13 109:23 110:4 111:17 128:11 128:17 131:23 1985 7:17 19:10 46:17,25 47:6 48:8 86:19 154:7 1986 141:3 1987 19:11,11,11 49:3 73:12 88:17 91:24 92:16 94:6,9,24 135:18 137:12 144:2,5 145:25 147:5 1988 138:23 1990 7:19 34:18 34:21,23 1991 148:13 1992 122:12 123:11,25 1993 26:7 147:5 148:1 1994 15:20,21 17:7 26:8 27:1 114:5 115:2 134:18 149:25 1996 86:9,16 87:4,15 93:4 138:8 2 2 74:12 91:19,22 92:7 137:22 2nd 19:11 20 74:6 157:15 200 3:15 2002 120:12,14 120:16 2005 139:9 2009 9:16 2013 117:20,22 2014 1:13 3:12 6:14 154:8 155:2,9 156:3 21st 19:10 46:25 2200 4:10 155:4 227-9990 4:5 2289-4840 4:17 23 1:13 154:8 www.midwestlitigation.com 155:9 156:3 23rd 3:12 6:14 239 2:8 6:9 48:25 24th 53:24 245 2:14 6:9 131:22 246 2:15 6:9 135:17 247 2:15 6:10 137:11 25 19:20 50:8 74:6 104:22 141:3 25th 53:18 56:10 66:11 250 2:14 6:10 132:18 251 2:16 6:10 140:4 252 2:17 6:10 141:2 260 2:18 6:10 148:12,13 275 2:12 6:10 122:7,11 123:23 138:19 276 2:13 6:10 123:9 28 77:20 282 2:13 6:10 128:10 29 78:4 29th 77:18 293 2:17 6:10 144:1 296 2:7 6:10 37:19,20 297 2:7 6:10 35:25 37:22 39:4 42:8 299 2:8 6:11 52:15,16 3 3 60:4 3rd 139:9 3:00 151:13 152:10 3:10 151:16,21 30 9:7 10:14 14:2 14:14 17:15,21 18:21 19:12,20 20:15 21:22 24:10 33:24 100:16 30th 19:10 301 2:9 6:11 53:17,18 64:6 86:2 302 2:9 6:11 64:5 66:22 67:5 303 2:10 6:11 67:4 304 2:11 6:11 77:17 86:2 305 2:12 6:11 95:3,3 103:20 314 5:6,11 319 2:10 6:11 74:11,11 86:2 32 14:14 30:10 46:13 33 2:16 6:9 139:4 366 4:4 154:10 4 4 60:9 64:7 144:5 4th 19:11 65:10 66:13 4/7/92 122:15 44 8:23 445 4:11 155:4 492.590 154:7 5 5 62:2,25 155:2 5th 37:21 68:11 145:24 5:00 7:13 507 4:17 54 50:7 55 49:6 50:7 55101 4:5,11 154:11 155:5 MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 55904 4:16 57.03(g)(2)(a) 154:7 58 100:1 6 6 2:7,7,8,8,9,9,10 2:10,11,11,12 2:12,13,13,14 2:14,15,15,16 2:16,17,17,18 2:18 36:3 37:15 63:11 97:6 123:25 60s 101:8 63101 3:16 5:5 5:10 154:19 644-2191 5:6,11 651 4:5 7 7 122:12 123:11 70 113:12 70s 46:9 88:11 109:21 711 5:5,10 154:18 72 127:17 142:6 73 26:17 34:22 35:18 126:15 127:15 76 25:13,25 142:5 77 25:16 79 25:16 35:11 8 8 2:4 80 65:8,10 80s 88:11 100:2 120:24 139:21 139:24 82 120:24 83 120:24 84 86:25 87:1 91:25 96:10 100:24 101:16 Fax: 314.644.1334 ARCHBISHOP ROBERT CARLSON **CONFIDENTIAL** 5/23/2014 101:24 120:25 131:7 85 87:1 87 89:11,25 88 73:12 9 9 67:5 95:4 90 35:18 90s 88:5 906 3:15 914 5:3 153:4 92 122:21 124:25 94 18:7 25:4,13 113:2,12 117:8 96 86:15 87:8 www.midwestlitigation.com MIDWEST LITIGATION SERVICES Phone: 1.800.280.3376 Fax: 314.644.1334