- .SUPERIOR COURT - . ORIGINAL HE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO In?, Individually, and Individually, Plaintiffs, vs. CASE NO. Defendant Doe 2Lr La Jolla Church; Defendant Doe 2, Linda Vista Church; Defendant Doe 3, Supervisory Organization; Defendant Doe 4, Perpetrator; and Does 5 through 100, Defendants. DEPOSITION OF JESUS MONTIJO February 9, 2011 10:03 a.m. 12555 High Bluff Drive Suite 260 San Die-o California tollfree (877) DEPO 9-1-1 Dormer: vs . Doe Jesus HUNTIJO ZISIZOIJ A. Yes, and if there are witnesses. Dig? you ever hear that Gonzalo Campos had sexually abused a child? A . Hot abused . Through the mother of the young man. That's all. Q. What did you hear? MR. MC CAEE: I don't know when he heard it. going to find out by that: question. time period you're talking about? That's fine. MR. STOREY: BY MR . STOREY: I'm going to object: as to time. I don't think you?re Can you clarify the . Do you know when you heard from Gonzalo Campos -- pardon me . Do you know when you heard that Gonzalo Campos had acted inappropriately? I . A. About 1982. Thereabouts. I'm not exactly Q. And how did you learn? A. The mother notified us. I Q. Okay. Did you speak with the mother? A. Yes. Q. Was the mother a? A. Q. Thank you. A. With a O. {877) DEPDQ1 1 . Inc. .mDEPosrl??Lcom Page 3 6 Damn vs. Doe JESUS mm when o. A. - That's what I think. Q. And what did she tell you? A.W That her son. told her that he had been touched. She didn't tell me exactly. I don't remaile exactly. I Q. Okay. And who did you talk to about this'i .15.. With a body of elders. 9. So the body of elders considered this complaint? - A. Yes, two elders spoke later on with -. 3. were you one of those elders? 1 A. I don't remember. I heard. I heard it at the beginning and another elder -- but I don?t know who was assigned later. Q. Did you ever speak to A. I don't remember. Q. Did you ever speak to Gonzalo? A. The elders the elders had to talk to Gonzalo. I don't remember if I myself spoke to Gonzalo. Q. Okay. But your understanding is that at least two elders would have spoken to Gonzalo? A. Yes. Q. And is it" your understanding that those two elders would have also spoken to?? (877) DEPO 9-1-4 DEP091 1 . Inc. Page 3 '7 rm; awe-?e awn-?eeisz 1.?in gm? .m i 9- wane - 25:. 22 23 34 25 JESUS MONTIJO Bowman vs. Doe 219l2011 A. They had to talk to her, the lady. Q. Is it your understanding that those two elders would have also spoken to THE INTERPRETER: MR. STOREY: -. THE INTERPRETER: .va MR. MC CARE: THE INTERPRETER: I. - - THE WITNESS: THE INTERPRETER: MR. STOREY: Yes. THE WITNESS: Yes, two elders had to be assigned to the case. BY MR. STOREY: Q. Okay. Do you know what was the result of that investigation by those two elders? A. Yes. Q. What was the result? w115.. They didn't find a bihlical basis in those two, three miitnesses, and there was no confessiori; Q: So no judicial committee was fox-Inga? A. No. I Q. Did you ever speak to anyone else about an accusation that Gonzalo Campos had acted inappropriately? {377) have 9-14 mjoaoanmm DEP0911. Inc. Page 36 -.-. -mwmu mug..? .- . m4.- ?In- - NH til-OiDamn vs. Doe JESUS HONTIJO 2/ when she told you about what happened with Gonzalo Campos and her son? A. There were two of us. I don't remember who the other was. I'm not sure. It's been too many years. Q. And then after you heard from that this had happened. did you present that issue to the body of elders? A. Yes. the body of elders were -- had met. Q. And who was present when the body of elders A. All five. Q. What was said at that meeting? A. What - had said. Q. Was there then discussion about who would be assigned to investigate the claim? A. Two were assigned. I do remember. Q. Were they given specific instructions on how to proceed with the investigation? A. No. Q. Did you understand never mind. Strike that. Did tell you where the conduct by Gonzalo Campos took place? A. Well, in her home. (2. Is it your understanding that Gonzalo Campos was staying with the family? DEPO 9.1.1 m.nspoa11.com DEP0911 . Inc. Page 40 karma-ammo {13585 MONTE-JO Damn vs . Doe 219!2911 A. We found out later that he was staying there. Q. How did you find that out later? A. Because said it. Q. So did you have more than one conversation with A. No, I just remember that she commioated that to us. I don't remember speaking with her later. I don't know. Q. You said she communicated that to you. Were all of her communications oral? A. The Communication was oral. Q. There was never a written complaint? A. No. Q. And there would not have been a would there have been a written finding by the elders who investigated the claim? A. It didn't proceed. There were no witnesses. There's no file. Q. Did you make an announcement do the elders make an announcement to the congregation to find out there were other victims? a . An announcement is never ?made . Q. Were any efforts undertaken to determine if there were any other victims of Gonzalo Campos? A. I Well. the matter was investigated, but it was (877) DEPO 9-1 -1 I 1. Inc. Page 41 mimm.?Batman vs . Doe Jesus just what said. Q. When the body of elders discussed this isSue. was there any concern that Gonzalo may have done this to other children? A. No, because nothing had ever been heard, and nothing was heard later either. Q. Is it your understanding that Gonzalo Campos joined the La Jolla congregation? A. When it was divided. yes. because he lived or he lives in Pacific Beach. Q. Was any warning given to the La Jolla congregation that Gonzalo Campos had been accused of acting inappropriately with a child? A. NO. Q. Were the police contacted when brought this complaint forward? A. No. Q. Has anyone outside the congregation contacted? A. I don't believe so. It wasn't that matter. Q. Would that matter have been shared with peeple who were not on the body of elders? A. I don't believe so, no. Q. Here any restrictions placed on Gonzalo Campos at that time? A. No. (877} DEPO 9-1-1 m.DEPoa11.com DEP0911. Inc. Page 42 I'm- ln-I' 0 if ail-unfitORIGINAL SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN DIEGO individually. and individually, Plaintiffs, vs . Case Number DEFENDENT DOE 1, DEFENDANT DOE 2, LINDA.VISTA.CHURCH: DEFENDANT DOE 3, SUPERVISORY 4, and DOES 5 through 100, De endant . INTERPRETED DEPOSITION OF JUSTINO DIM, called on behalf of the Plaintiffs, at 12555 High Bluff Drive, Suite 260, San Diego, California, on Tuesday, February 2011. commencing at 10:14 before Judy Runes, California CSR No. 5974. (877) DEPO 94-1 toll free any- .. "mm-.5 - ?mug-.JUSTIN DIM Dom? Doe Ila/eon put it in a letter: like this? A I'm not sure because I did not speak to them with regard to this matter. Did you ever speak to anyone with regard to Gonzalo Campos and any accusation against him? MR. Objection. I'm assuming you don't meaniany conversations with me. BY MR. Excluding any conversations with your attorney. A No. Were you ever made aware, other than conversations with your attorney and today, that any accusations had been made against Gonzalo Campos? A If you'll repeat it again, please. . 0 Other than conversations with your attorney and here today, were you ever made aware that there had ever been an accusation against Gonzalo Campos? A The mother of the one who sypposjedly Campos abused. And tell me about that. What did she tell r23? A Hell, that Gonzalo Campos attempted to, or gbused, sexually abused her son. 3 And she told you about that?_ (B77) DEPO 9-1-1 Page 2 8 Batman vs . Doe JUSTINO 1 A Yes. 2 MR. STOREY: Can we go off the record for just 3 a second? 4 (Off the record 11:09 to 11:10.) 5 BY MR. STOREY: 6 Who was the wom?g?ggm 7 A The mother of a And what did she tell you? 9 A Just that, that he tried to abuse him. 10 don't know to what disagree.w 11 How did you respond to that? 12 A Well. the matter never again was discussed. 13 Did you think this was a serious matter? 14 A Well, it woulgg??ieelggif be. because then later i 15 Gonzalo's mother and mother spoke and 16 they took care of the matter amongst themselves. 1'7 Since they resolved the issue between 18 themselves, did you believe there was no need for a 19 judicial comitteeL 20 A. Uh?huh. 21 At that time, did you investigate to see if 22 Gonzalo Campos had tried to do anything similar to other 23 childrenDid you tell anyone else about wheag {8771 DEPO 9-1-1 m.DEP0911.com DEPOQH. Inc. Page 29 Barman vs. Doe JUSTINE DIAZ woman 1 MR. MCCABE: Off the record. 3 2 (Recess taken from 11:22 to 11:35.) 3 BY MR. STOREY: 4 I don?t have a whole lot more for you today. 5 I'd like to confirm, if you know, what year 6 you became an elder in the Linda Vista Spanish 7 congregation . a A ?79. .jkwaff? 9 So at the time you spoke to ?r you 10 gore an elder?_ 11 A Yes . - 5on1: 12 After you spoke with A did you speak 13 wi th Gonzalo? 14 A No. 15 Did anyone speak with Gonzalo at that time? 16 A Not that I recall, no. 17 . Because they resolved it between them, the two 18 mothers, Gonzalo'a and the other boy's mothering my 19 When you heard this complaint from 20 ?did you think that it was seriousyour knowledge, pardon me scratch that. 23 In your time with the Linda Vista Spanish 24 congregation, had anyone else ever been accused of 25 sexually abusing a child? I don't need names. (377) DEPO 9-1-1 0.5130911, Inc. Page 34 Batman vs. Doe JUSTINE) DIAZ 215/2011 No. no. So this is the only one? The only one . it) 53 HQ ?tr 5 . '13 What did you understand happened to Well, since the two women didn't seem vesy upset, that I didn?t take if; as being that serious. What was the specific conduct that: Gonzalo was accused of doing? ?f?k?g A Well, mother said that -- that he tried to to touch his parts., Do you understand it to be a crime for an adult to touch a child's parts, as you ued the word? A Yes . So you know that this conduct at the time in 1980 scratch that. When this complaint Was made. you realized that this conduct may be criminal? A Yes. But you didn?t think that it was serious? .8 i thought that: it wasn't serious. Did you think it was possible that Gonzalow Campos would attempt to sexually ahhse anothexg child? A It could happen .. (877) DEPO 9-1-1 Inc. Page 35