The following is the affidavit of Maurice E. DeMontigny, a confidant of the late Bishop Christopher J. Weldon and longtime lay religious officer in the Springfield Roman Catholic Diocese. This affidavit was filed in opposition to a recent court motion by the diocese seeking the dismissal of suits relating to sexual abuse allegations before 1971, a period when charitable immunity laws protected the church.

I, Maurice E. DeMontigny hereby make affidavit upon my personal knowledge and belief as follows:

1. I reside at 210 Johnson Road, Unit 4, in Chicopee, Massachusetts.

2. Until I moved on June 30, 2003, to Chicopee I had lived at 87 Sunnybrook Road, Springfield, Massachusetts, for 46 years (April 20, 1957).

3. I have been married to the former Madeline T. Vincent for 50 years (June 20, 1953). I retired on Sept. 25, 1992, after 41 years of service to the City of Springfield as the Water Registrar, (better known as the "financial officer").

4. My family has been members of the Parish of Saint Catherine of Siena at 1023 Parker St. in Springfield since the parish was first formed; we were part of the original founding parishioners. I was parish religious education coordinator under the Confraternity of the Christian Doctrine (CCD), religious education ministry for a number of years. I have also been the parish representative to the Springfield Deanery of the CCD and was appointed to the Diocesan Board of Religious Education. As a member of both the Deanery and Diocesan Boards I served on many committees and assisted with many conferences. I was appointed the Springfield Diocesan Treasurer for the New England Congress of Religious Education and later appointed chairman of another congress of Religious Education and was the co-chairman for a third congress. All of these appointments were made by the Most Rev. Bishop Christopher J. Weldon.

5. I enjoyed a close personal relationship with Bishop Weldon, and with my pastors Father Thomas P. Griffin and Father Leo E. O'Neil, who in 1980 became auxiliary bishop in Springfield. My pastors gave me keys to our church and the diocesan director of religious education, the Rev. Howard McCormick, gave me keys to the diocesan office buildings for religious education. At the Diocesan Office (of) the Confraternity of Christian Doctrine, on Carew Street, I actually supervised a staff of personnel and volunteers on a part-time basis and spent weeks of my vacation auditing funds, making disbursements, and reporting to Bishop Weldon. I feel as though I was a confidant of my bishop, my pastors, and Father McCormick.

6. I specifically recall one Sunday when Richard Lavigne was a curate at our parish (St. Catherine's, where Lavigne was posted between June 1967 and May 1968), Father Griffin called to me and asked to speak with me outside. Although I often spoke with Father Griffin, this time was unusual in that I noted urgency in his manner. He told me he needed my help for a serious and grave matter and asked that our conversation be held in the strictest confidence. He told me that "someone in the parish had come to him with a complaint on Father Lavigne that involved their sons and they could not press charges with the police." He inquired as to whether one of my young nephews who also attended St. Catherine's was also having a "problem." He further told me that the family did not want to go to the police and that he wanted to know "how widespread the problem was and who and how many of the boys in the parish were involved." Father Griffin was very upset and breathing hard. He was being careful with his words. I understood him to be confiding in me that the family had accused Richard Lavigne of molesting their child and he suspected that other boys may have been molested as well.

7. On another occasion shortly thereafter I remember casually asking Father Griffin in a friendly way, "how are things?" His response was "no change, the family hasn't changed their position" or words to that effect. He was troubled with the statement. I was not looking for a follow-up on our earlier conversation but got it.

8. I recall another time when I was in the rectory with Father Griffin and Father O'Neil, this was one of the very first days that Father O'Neil came to our parish. I would say that it had to be about late June or early July of 1968 because Lavigne left on June 29, 1968. We were disapprovingly talking about Father Lavigne's close activities with boys. I recall Father O'Neil saying, "You won't be seeing any boys coming into my room," or something to that effect. I also remember him commenting, "I know one thing, no one will be coming into my room." I had the distinct impression from Father O'Neil, that he did not want to come to St. Catherine's parish because of Father Lavigne.

9. I believe it was in 1972 when a Grand Jury was investigating (altar boy) Danny Croteau's murder that I was in the parish with both Father (later Bishop) O'Neil and Father Griffin. Father Griffin started up a conversation about Lavigne and the murder. I felt he was referring to our prior conversation with his inquiry and with some of the references he made. He once again inquired about my relative and how he was doing with all of the talk, meaning the murder and the focus on Lavigne.

10. During the Grand Jury investigation I was passing information I received from Gene Galeziowski (father of plaintiff David Galeziowski) to Father Griffin, who told me he was passing on the information to Bishop Weldon. Gene Galeziowski worked in the Hampden County Courthouse and had learned details about the investigation into Father Lavigne's (alleged) involvement in the murder. Given the fact I knew Bishop Weldon to be quite close to Father Griffin and given the fact I was part of the process in passing information to Bishop Weldon, I am sure that Father Griffin would have directly reported to Bishop Weldon any allegations of sexual abuse.

11. I recall a specific incident in the early 1970s when Lavigne told me that his pastor had admonished him concerning boys being in his bedroom. I believe the pastor was Monsignor Harrington, but the records would tell for sure the pastor's name. The pastor was upset about boys being in the rectory and in Lavigne's bedroom. Lavigne was contemptuous of the pastor's attempt to exert his authority over him. He said something to the effect that "they can't do anything to me" and laughed about it.

12. In the early 1990's (when) the negotiation sessions (regarding a lawsuit targeting Lavigne) were taking place, and I was in attendance, one of the victims told me on a personal basis that Father Griffin walked in on them in the kitchen of the rectory and a sexual act was taking place. This incident took place during Lavigne's residency from May 6, 1967, to June 29, 1968. I am sure that Father Griffin would have admonished Lavigne and reported this to Bishop Weldon.

13. I author this affidavit in support of the victims of clergy abuse who have come forward recently and those who have yet to come forward, to document my personal knowledge that diocesan officials (including my late friend Bishop Weldon) knew that Father Lavigne was molesting children as early as the late 1960's.

14. These are not new allegations that I am making. When Lavigne was accused of molesting children in the early 1990's, I wrote a personal statement for the victims' attorney (Exhibit 1). There was a meeting with Bishop Marshall as part of the settlement with the victims who came forward in the early 1990s. I accompanied the victims and participated in that meeting as I had in the negotiation sessions. I took issue with Bishop Marshall's statement that neither the priests nor the Bishops had any idea of (Lavigne's) conduct. I wrote a polite letter to him indicating that I knew that as early as the late 1960's, my pastor, and in all likelihood Bishop Weldon, was aware of accusations that Lavigne had molested children. (Exhibit 2). I have also recently learned that Bishop Marshall's statement then was less than truthful as the diocese has now publicly admitted they knew in 1986 that Lavigne had molested children. We were never told at that meeting that the Diocese knew in 1986 that Father Lavigne had molested at least one child, and had been sent for an evaluation.

15. I believe, based upon my familiarity with the workings of my parish and of the Diocese of Springfield, that Diocesan officials knew, as of the late 1960's, that Lavigne was a child molester.

Signed under the pains and penalties of perjury this 15th day of August, 2003.

Maurice E. DeMontigny