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Correspondence between priests relating to their sexual interests

Amended complaint - Heroux v Carpentier, et al
Rhode Island Superior Court litigation stating claims against a Rhode Island priests and the diocesan hierarchy for child sexual abuse, and raising claims of fraud and concealment on the part of the hierarchy. This is one of nearly such cases presently before the Rhode Island Superior Court. The Heroux complaint, authored by Mr. Conlon and Attorney Richard Cappalli, serves as the model adopted in all of the Rhode Island cases.

Documents referenced in the complaint regarding the prior knowledge of Rhode Island's bishops also are available for public review.

Letter from "Joe" to Father William C. O'Connell
Only a review of this document captures its import. The letter, in an envelope with a return address of
"St. Mary Magdalen Rectory
621 Dock St
Millville, New Jersey 08332"

was postmarked Dec 2, 1969 to:

"Rev. Father William C. O'Connell
Holy Ghost (Spirit) Church
311 Hooper St.
Tiverton, Rhode Island, 02878"

and was introduced in the Federal Court litigation as an exhibit to the deposition of Father Richard A. Bucci.

Page 1 Page 2 the "PS" The enclosure

Depositions of Louis E. Gelineau, Bishop of Providence
Defendants have repeatedly sought stays in federal and state court litigation relating to clerical child sexual abuse. Notwithstanding, Louis E. Gelineau, then Bishop of Providence was questioned on April 2, April 11, and April 16, 1997, by Susan McGuirl, (formerly an Assistant Attorney General for the State of Rhode Island, lead counsel for two plaintiffs in Federal Court), and Mr. Conlon, on behalf of plaintiff Kenneth Smith. Each of these transcripts is available on-line.

NOTE: Bishop Gelineau and his counsel repeatedly asserted "first amendment" privileges as a basis for refusal to answer questions regarding clerical misconduct and the Church's response to same. Accordingly, questioning of the Bishop was suspended pending rulings on these objections. Plaintiffs anticipate pressing these first amendment claims at further depositions in the state court matters.
Deposition of Daniel P. Reilly, Bishop of Worchester
Rielly served as "administrator" of the Diocese of Providence during the period between the death of former Bishop McVinney, and the succession of McVinney by Gelineau. Reilly confirms receiving a report from an individual regarding misconduct by one priest, but refused to provide additional information.
Deposition of Bessell van der Kolk
Dr. van der Kolk is a leading authority on trauma and its effect on memory. He has published extensively on the topic. His testimony led to admission of repressed memory by the United States District Court for the District of Massachusetts. Dr. Christopher Barden, an attorney with a Ph. D. in child and adult psychology, with experience in asserting "false memory" claims, questioned Dr. van der Kolk on December 27 and December 28, 1996. He pursues FMSL's "methodolgical attack" with Dr. van der Kolk.
Deposition of Elizabeth Loftus
Dr. Loftus is accepted as one of the leaders in the attack on traditional traumatic memory theory. As such, she has testified extensively on behalf of those defending child sexual abuse claims. Her deposition, conducted on March 3, 1997, by Mr. Conlon, explores the scientific basis, if any, for the claim that a given memory is the result of some "false memory syndrome," as opposed to just a mistake, and pursues the issue of whether a memory expert has any expertise for determining a given memory to be false.

In 1983, the Rhode Island Family Court decreed that the States Juvenile Diagnostic Center (JDC) could not be used for shelter, thus ending the state's practice of dropping wards for whom it had no placement in a building serving as a Juvenile Psychiatric facility. The DCYF no longer operates the JDC, but a recent report prepared by Rhode Island's Public Expenditure Council suggests that many children are 'stuck' in Rhode Island's psychiatric hospitals, due to DCYF's failure to provided needed out-patient services and/or placement, and indeed that at any given time, as many as 50% of the children in the psychiatric hospitals don't need to be there. Investigation to date has included reports of children being held over for lack of placement for months, even up to a year. Other children are released to free up beds, only to go on 'night-to-night' placement, leaving them essentially homeless upon discharge. A petition, signed by hundreds of DCYF employees terms this practice: 'as abusive as any situation we remove these children from'

A letter to doctors at the two psychiatric facilities was delivered April 27, 2001, and encloses a memo to the residents and notice to the children of the rights secured under Rhode Island's Children's Bill of Rights, including their right to an attorney, and the right to seek judicial relief.