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CAUSE NO. 141-198356-03
  1. My name is A. W. Richard Sipe (Aquinas Walter Richard). I am over the age of twenty-one (21). I have never been convicted of a felony. I am competent to testify to the truth of matters stated herein. I have personal knowledge of the matters stated her and know such matters to be true and correct. 

Background & Experience:

  1. Currently I am involved in full-time research and consultation about celibacy and the sexual practices of Roman Catholic clergy. I conducted a 25 year ethnographic study (1960-1985) of the celibate/sexual practices of Roman Catholic priests in the United States. I have authored five books on the subject. I have served as a consultant or expert witness in over 250 cases of sexual abuse of minors by Roman Catholic clergy in the United States and Canada, usually on behalf of plaintiffs. I have been an expert trial witness in the States of Arkansas, Minnesota, and California. I served as an expert witness at the sentencing hearing of a priest in the Federal Court in Des Moines, Iowa. I have been a consultant to the District Attorneys’ offices, department of criminal investigation of child abuse for Orange County, California and Los Angeles. Deputy District Attorneys for Ventura County and San Francisco also participated. I also was hired by the Deputy Attorney General for the State of California to be an expert witness in criminal trials of priests who had allegedly abused minors. I was a consultant to the office of Attorney General of the State of Massachusetts in their preparation for grand jury hearings regarding sexual abuse. I was a witness before the Philadelphia Grand Jury investigating sexual abuse by priests in that jurisdiction. These are among my activities primarily over the past five years.
  2. I was trained as a psychotherapist/counselor specifically to deal with the mental health problems of Catholic clergy and religious. I served on the staff of a psychiatric training hospital operated by Catholic nuns. This hospital was well known as a treatment center for priests and religious. I was trained at this hospital and served on its staff as a counselor. I have been active in my field for over 40 years. I was a Psychiatrist Assistant certified in the State of Maryland from 1982 to March 1, 1999, when I retired. My certification extended until 2002.
  3. I held an appointment as Instructor in Psychiatry (part-time), Johns Hopkins School of Medicine, Department of Psychiatry, division of children and adolescents, Baltimore, Maryland, for 25 years until I submitted my resignation in 1997.
  4. I have taught at three major Roman Catholic seminaries and a Catholic college from 1967 to 1996. I held the position of Assistant Professor of Pastoral Counseling, St. John’s University and Seminary, Collegeville, Minnesota (1967-1970). I have continued to lecture periodically at this seminary, the most recent series being in January 1996. I was Lecturer in Pastoral Counseling at the Jesuit seminary, Woodstock College, Woodstock, Maryland (1968-1970). I have been Adjunct Associate Professor of Psychology, Loyola College, Baltimore, Maryland (1971-1975) and Adjunct Professor of Pastoral Counseling, St. Mary’s Seminary and University, Baltimore, Maryland (1972-1984). The latter institution is a Pontifical Seminary. Most recently, in May 2005, I gave a day of recollection on celibacy to priests in the Diocese of Rochester, New York.
  5. I attended Roman Catholic parish grade school, Catholic high school, college, and seminaries in Rome, Italy and in Minnesota.  I entered a Benedictine Monastery in 1952 and was ordained a priest in 1959. I taught for five years in a Catholic high school until 1964 when I began full time training for counseling. I remained a monk and priest until 1970, when I requested and received permission from the Vatican to be dispensed from my vows as a monk and a priest. I was married in a Roman Catholic ceremony in 1970 and remain a church member in good standing.
  6. During my career as a therapist I have consulted with or treated over 3,000 clients, half of whom had been sexually abused as minors (one-third of those were abused by a Catholic priest or religious.)  I have been involved with 500 priests in a counseling or consultation relationship. Of these, 69 had been sexually involved with a minor at least once. In addition I have reviewed over 1,700 case histories of Catholic priests including those who have abused minors, and over 2,000 complaints or histories of adults who have alleged sexual abuse by a Catholic priest or religious when they were minors. A true and correct copy of my Curriculum Vitae is attached to this document. (Attachment 1)


  1. In preparation for this declaration I have read and reviewed the following documents: The Protective Order Regarding Confidential Information (October 4, 2004) signed by the Presiding Judge in the District Court of Tarrant County, Texas in the Case of John Doe I & John Doe II v. Roman Catholic Diocese of Fort Worth et. al.; Interveners'’ Post-Hearing Brief submitted by The Dallas Morning News and The Fort Worth Star-Telegram (June 24, 2005); and the Affidavit of Mary A. Connell (September 9, 2005). This is a preliminary report, and I reserve the right to revise it, as new documents are made available to me.
  2.  I have been asked to render opinions on a) the effects—positive and negative—or the foreseeable value to victims of sexual abuse by Roman Catholic Clergy that the public disclosure of documents relating to the knowledge of bishops of the pervasiveness of sexual abuse of minors by Catholic priests in the United States from 1950 onward; b) the effects of public disclosure of such documents for the general welfare of society and the prevention of further abuse of minors even beyond the Catholic clergy and their employees.


Effects of Public Disclosure on Victims of Abuse:

bulletSexual abuse of minors (and others) by Catholic clergy has been a persistent problem for centuries. The facts have been memorialized in church documents with unremitting frequency. (Cf. Attachment 2, Chronology: Sex, Priests & Secret Codes. 2006)
bulletThe harm to victims of sexual abuse by any trusted adult, and particularly by a representative of an institution that holds itself to speak for divine and eternal values are long-lasting and severe. (Cf. Attachment 3, Unspeakable Damage)
bulletMy long-term and consistent experience with victims of sexual abuse by Catholic priests and bishops is that the revelation, and recognition that the authorities of the church did indeed know about the problem of abuse, their own abuser, and others carries with it a positive and healing result.
bulletIn 1988 I reviewed files of 1,800 complaints of clergy abuse. Not one of these files threatened or wanted to sue the church. Over and over again the letters were asking for recognition that they were telling the truth, were not alone, that there was a possibility of a hearing and vindication from Church authority.
bulletVictims have reported re-victimization in having to fight for these goals in the processes—legal and otherwise—established by some dioceses. In many of the depositions I have had to review in my work some church lawyers do appear to be ruthless in trying to “break down” the plaintiff.
bulletIn spite of difficulties, many victims consider themselves survivors once they have entered the process of vindication. The public disclosure of documents that reveal perpetrators, and the diocesan knowledge of abuse add to the healing reality that the victim was not alone and not to blame for his or her assault.
bulletDisclosure of documents has proven to give many victims the courage and support they need to come forward and begin the process of healing. This fact has been amply verified in diocesan experience, in the press, and in public awareness.
bulletI can say from my experience, research, and training, with reasonable psychological certainty, that most of victims of clergy sexual abuse derive positive results from the public disclosure of church documents that expose the extent of knowledge and the history of its disposition in any given diocese.

 Effects of Public Disclosure of Church Documents for the General Public Welfare:

bullet The problem of sexual abuse by Catholic clergy over the past 50 years is a matter of record (Cf. below). The salient factor in brining attention and remedial action to the problem was because the Boston Globe petitioned and was granted the unsealing of church documents from the Court in Massachusetts. This action by the court has had such profound effects on the awareness of problem of the sexual abuse of minors in the United States (and around the world) that many people date the crisis to January 6, 2002 when the Boston Globe published the first of 1,200 articles on the subject.

As a direct result:

bullet In June 2002 the Catholic Bishops of America met in Dallas and authored a zero-tolerance policy for abuse of minors by Catholic clergy.
bullet The US Bishops inaugurated a National Board to investigate the crisis. They also commissioned the John Jay College of Criminal Justice to conduct a survey to determine the scope of the crisis of sexual abuse of minors by Catholic clergy. It estimated that between 3 and 6 percent of all Catholic priests in the United States in the last 50 years have sexually molested children. The report states that 4,394 (or 4 percent of the total) Catholic priests have been credibly accused of abusing minors between 1950 and 2002. They concluded that the rate of abuse they project is probably low because of self-reporting and the unwillingness of 3 dioceses to participate in the study plus other limits of survey techniques. The report found that 10 percent of priests during the 1970s and 8 percent during the 1980s were abusing minors according to credible reports in the data they collected. (Cf. The Report of the John Jay School of Criminal Justice, February 27, 2004) The number of alleged abusing priests who are known has increased to over 5,000 since the report was finished (1,000 additional reports were filed between 2004 and 2005, 750 listed names of priests not mentioned previously). As more accurate numbers are recorded it is clear that the projected norm is greatly exceeded. For instance, the Diocese of Tucson Arizona had over 20 percent of its active priests in 1986 accused of abusing minors. The Boston Archdiocese admits that over 7.6 percent of its priests over a 50-year period abused minors; New Hampshire recognizes that 8.2 percent of its priests abused. Priests credibly accused of abusing children in the Los Angeles Archdiocese numbers 244. In 1983, 11.4 percent of the active priests in that jurisdiction are now credibly recognized as abusers of minors. Seventy-five (75) percent of the parishes in the Los Angeles Archdiocese have had at least one sexual abusing priest on their staff (several have employed 5 to 8).
bullet In my opinion the real number of Catholic priests who have sexually abused a minor at least once during the past 50 years will prove to be 9 percent when all studies are completed.
bullet Between 2002 and 2004, 700 priests who had been credibly accused of abuse and still active in the priesthood were relieved of their duties in ministry.
bullet The Catholic Bishops established an Office of Child Protection to promote prevention of sexual abuse by clergy and others working for the church.
bullet Twelve grand juries were convened across the country to investigate Catholic clergy abuse. The reports from these investigations have resulted in a deeper understanding of the structure and mechanisms that foster and perpetuate abuse of minors, and form an impetus to greater action to protect minors from abuse. Three reports produced cause for indictments (New Hampshire, Phoenix, Detroit) but pleas were worked out with district attorneys in each case. The reports from Massachusetts and Philadelphia said that there was evidence of criminal activity, but state laws in each case impeded bringing criminal charges.
bullet The effects of the release of documents by the Massachusetts court have had positive effects for the prevention of child abuse and the protection of minors far beyond the Catholic clergy and the United States. The awareness and attention to the problems of minor abuse and the need for prevention have extended around the world. This is demonstrated by the increased concern about child pornography and child prostitution in several countries as well as the United States (Thailand, the Philippines, Rumania, etc.).

The problems of sexual abuse of minors in society and by Catholic clergy have not been solved in spite of advances in prevention and expanded education. Documentation of abuse held by Catholic Dioceses in secret has already been, and is still crucial to combat this social evil. Many Catholics still hope that bishops will step forward with complete transparency and accountability to help not only the members of their own flocks, but of American society.

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