Royal Commission Case Study 29 (Jehovah's Witnesses) — Hearing Transcript, Day 148 (2015)

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ROYAL COMMISSION INTO INSTITUTIONAL RESPONSES TO CHILD SEXUAL ABUSE

Public Hearing - Case Study 29 (Day 148)

Level 17, Governor Macquarie Tower Farrer Place, Sydney

On Tuesday, 28 July 2015 at 10am

Before The Chair: Commissioner:

Justice Peter McClellan AM Professor Helen Milroy

Counsel Assisting:

Mr Angus Stewart SC

.28/07/2015 (148)

15237 Transcript produced by DTI THE CHAIR: Yes, Mr Stewart.

MR STEWART: If your Honour pleases, Mr Jackson is still giving evidence.

<DOUGLAS JAMES JACKSON, on former oath:

[10.05am]

<EXAMINATION BY MR STEWART CONTINUING:

MR STEWART: Q. Mr Jackson, I'd like to show you paragraph 57 of [BCB]'s statement. It will come up on the screen. Perhaps you can start at paragraph 56. You'll see that [BCB] here is talking about the meeting that you spoke about yesterday, too, and she says she felt uncomfortable, she could not bring herself to tell the elders everything that had happened, she felt like she was still Bill's victim, and she was so scared of saying anything that would get her or Bill into trouble. Then at paragraph 57 she says:

I remember that at one point in the meeting, Max said to me, "Is there anything else you wish to tell us?" I remember looking across the room at Bill and saying "no". It was already very hard to talk about sex in a room full of men. It was especially hard to talk about what Bill had done to me while he was sitting there in front of me. I didn't feel like it was a safe environment and I was scared of what the consequences would be if I told the whole truth. Perhaps if a Sister who I was comfortable with had been there too, it might have been easier.

Mr Jackson, I take it you accept that it was very hard for [BCB] to talk about sex in a room full of men? A. I do, yes.

Q. And it was hard for her to talk in front of Bill - Bill Neill that is - who was her abuser?

A. Yes, I'd say that, as she said, it would have been very hard.

Q. And that it did not feel like a safe environment for her?

A. Yes. I don't know why she would have felt that, because we tried to comfort her.

I just can't remember the scriptures that we used and the way that we spoke, but I would say that we tried to comfort her and to help her.

Q. But you appreciate that, whatever you might have said, it couldn't have been enough in those circumstances?

A. I'd say that's correct, yes.

Q. In circumstances where she has to face a number of men who are her elders in the church?

A. Yes.

Q. Including one of whom is the person whom she accuses of having abused her?

A. Yes, yes.

Q. And she has to face him?

A. Yes, yes.

Q. And then she says, as you saw, that perhaps if a sister whom she was comfortable with had been there it might have been easier, and you suggested yesterday there might be space for that, and we started a discussion about that. I'd like to take you back to what I showed you just before we finished yesterday, which is at tab 120, page 90 or Ringtail 91 of that document, paragraph 3.

This document, you'll recall, is the Shepherd the Flock of God. Of course, it's the position now, not back then, but I'm content to discuss what the position is now. As I showed you yesterday, you see that it says that in a judicial hearing, procedure observers should not be present for moral support. You answered yesterday that you thought that if the accused - not the accuser but the accused - wanted moral support, there may be space for that. But you'll accept that under this there's no space for the accuser to have someone present for moral support? A. In that particular paragraph, it demonstrates and it mentions that, but I think in the publication around chapter 12 it does talk about that. We need to take into consideration the person and that we would, you know, really try to help them and, if need be, now, certainly have someone there to help. I think it was paragraph 18 and 19 - I think.

Q. So that's at Ringtail 132. This is dealing specifically with child abuse. There are the paragraphs 18 and 19?

A. Yes, it must have been another one, but I know that, if need be, and we certainly can have - they can have, the one that is being abused, they can have someone there, whether a friend, parents, ones of their choice, and make them feel comfortable.

Q. It's not in those paragraphs 18 and 19, you accept that - do you accept that?

A. Sorry, yes. I thought it was there.

Q. And it would be against the paragraph 3 we were looking at earlier insofar as a judicial hearing is concerned?

A. Yes, sorry.

Q. These guidelines are published by Bethel in Brooklyn - that's right?

A. Yes.

Q. It says in paragraph 18 on the screen now, in the last sentence:

The branch office will then give direction based on the circumstances involved in each situation.

Would it be your understanding that that is direction within what these rules allow?

A. Yes.

Q. In other words, the branch office wouldn't have authority to override these rules which are published and distributed from New York?

A. No, but they could include saying we should give support - as much support to the victims as possible.

Q. What about if the complainant is a child still at the time that she's complaining, that she raises the allegation, how do you deal with that?

A. In the KS10 - I'm just trying to think of the chapter, whether it's - but there's, again, just the support - if it's a child, then the parents would be permitted to come there, unless, of course, one is an accuser, it's a little bit different. But, again, we try to give them as much support as we can to help them.

Q. Well, Mr Jackson, you and other overseers and elders have given evidence or have in their statements that you received training from time to time; is that right? Does that training ever cover how you should deal with children who are making complaints of child sexual abuse? A. I cannot remember exactly when, but I'd say yes, that it does deal with that, and appreciating that every situation is different, the way that it would be handled.

Q. What training specifically on how, for example, to interview a child complainant?

A. We, of course, try to be as kind and as considerate, thinking of Bible principles involved, how we can be of support to these ones. Again, looking to the publications as well.

Q. Do you accept that it's a specialist area of how to respond to children making allegations of abuse?

A. Yes, we do, and we certainly appreciate that, and even after, we don't discourage if - if the parents or the individual wants to seek other help through individuals or through - depending on the circumstances - qualified people.

Q. So --

A. A psychiatrist or counsellors.

Q. Insofar as the interviewing itself is concerned, you wouldn't, though, be able to give up your role as an elder in conducting an interview to a professional outside of the church, would you?

A. Do you mean being involved in the meeting?

Q. Yes, interviewing the child.

A. No, that's true, we don't, no. But we try to give them as much support as we can - as I've said, either through an individual who they feel comfortable with - but when the situation is dealt with, we certainly - you know, don't encourage them, but we say that if they want to, they can, you know, go to counsellors, psychiatric help or within the congregation there may be someone that can give them definite help.

Q. If we can look at tab 126, starting on the first page, you'll see that this is from World Headquarters in August 2013 and it's to Branch Committees and it's Guidelines for Branch Office Service Desks, in other words, how branch offices should respond.

Attached to the letter is some Guidelines for Branch Office Service Desks. Is this a document you've seen before? It wouldn't typically go to you because you've not served in a branch office, have you? A. No, no.

Q. In any event, you'll see there the guidelines are there, but can I take you to, in particular, page 9, Ringtail 84, question 14:

When should elders interview a young child who is a victim of child abuse?

That's the question put, as it were, to the service desk and as I read the document this is what the direction to the service desk is:

When elders call the branch office regarding a child abuse matter they may ask about the need to interview the victim. In such cases, help the elders to balance the need to investigate with the dangers of inadvertently further the traumatising a young child abuse victim. For example, has the accused already confessed to the wrongdoing? Is there more than one accuser and thereby already sufficient evidence to handle the matter judicially. In such cases there is likely no need to interview the young child.

Still nothing there about being able to get a trained professional to do the interview, or to assist? A. No, that's why I said generally it's after that we encourage them, if need be, but if they do want support during the meeting, then either the parents or somebody else that they feel comfortable with, yeah.

Q. Returning to the direction in Shepherd the Flock that we were looking at earlier, which says that observers should not be present for moral support, can you conceive of what the justification can be for that direction?

A. For moral support?

Q. Yes, that an observer should not be present for moral support?

A. No, I can't, and that's why I thought in other chapters of the book - but I just can't recall them, I thought that one was in chapter 12 I just quoted, but it's not - 18 and 19.

But I find that - well, I don't find, but with the letters and the publications, we certainly do try to make the person feel at ease so they feel free to be able to express themselves.

THE CHAIR: Q. The problem, Mr Jackson, is really not addressed in that way, though, is it? The problem -- A. No.

Q. -- is the whole structure of the arrangement with two male elders, a male accused and then a female, in an environment in which she could never feel comfortable being asked to tell intimate details of a sexual nature - the structure doesn't work, does it?

A. Well, I agree, your Honour, I certainly do.

Q. What can the church then do about changing the structure?

A. Well, maybe, after hearings like this, where it's been brought to the fore, I just feel that over a period of time, only through matters of letters that I've read, that it does indicate that other persons for support are able to help them through.

Q. But even support is not going to help, given the structure of the whole arrangement.

A. Yeah, yeah. Well, maybe, as I said, after meetings like this - hearings like this, sorry - there could be a structure change. You know, I'm not in that position to say, but there could be.

Q. Well, how would structure change occur?

A. I guess just what you're saying, with the individual --

Q. How would it be initiated inside the church? How does the church make the changes that are necessary?

A. Oh, well, it would go through the governing body, or suggestions would be to the governing body.

Q. Which is in America, is it?

A. Yes, but, in turn, it could go through the branch here,the suggestions.

Q. Do people like you take forward suggestions to the A.

Well, I haven't.

branch here?

Q. But do they?

A. Yes, they do.

Q. I want to know how the system works?

A. Yes, they do.

Q. What's the process?

A. Yes, they do, they make recommendations, and these recommendations go to the branch of the governing body and then situations can change in those areas if - if the governing body decides to do that. But we can make anyone is free to write and make these recommendations your Honour.

MR STEWART: Q. Mr Jackson, in your statement you say that the complaint that was made when you were there investigating it - the complaint that was made involved [BCB] discovering Bill Neill looking at her as she was taking a shower, which Neill admitted to. You recall that. And [BCB] complained that Neill had touched her breasts from the outside of the night clothing when kissing her good night, but he said that if it occurred it was inadvertent. Do you remember that? A. I just remember Bill Neill looking at her in the shower and the comment made on the touching of the breasts.

Q. You don't remember the complaint about repeated tongue-kissing over a period of time?

A. No.

A. No.

Q. You don't remember that?

A. No, and, to me, I don't know if it was even raised.

Q. Let us look at tab 70. If we can scroll down so, Mr Jackson, you can see this. Do you recognise that this is your report to the branch following your investigation with Mr Horley? A. Yes yes

Q. I understand you wrote this letter; is that right?

A. I did, yes, with comments from Brother Horley or Max Horley.

Q. If we see at the end, both you and Mr Horley signed it?

A. Yes, correct.

Q. Did you write this letter from any notes you had taken during the course of your interviews or investigations?

A. I would have taken, yes, on some of those days, but also discussing it with Max Horley as well - like, the contents of the letter.

Q. So you took notes during the interviews as to what was being --

A. I think we both did - as far as I can remember, I think we both took some notes.

Q. As to what the complaints were?

A. Yep.

Q. And, presumably, what the responses were?

A. Correct.

Q. And where are those notes now?

A. Well, I - I don't have them. I don't know whether they were kept in the congregation file or --

Q. Well, you were the circuit overseer at that time. Would your notes have ordinarily gone into the congregation files?

A. Normally, if I was serving that congregation, it would have gone there. The only letter would have been this to the branch, but I really can't remember. I know I never took notes - not only from this situation but any anything else that I dealt with; it went to the congregation. Sometimes there may have been matters that I passed on if I - another circuit overseer followed me or took over the circuit that I was doing, but I cannot remember with regards to that, and I would say that possibly it was just left with the congregation.

Q. You see, the Royal Commission subpoenaed and received documents from the congregation files, but there are no notes there.

A. Yeah, well --

Q. Can you explain that?

A. I cannot, no.

Q. Are you really saying, Mr Jackson, that your ordinary practice was that the overseer's notes would go into the congregation file?

A. Yes, and information, as this letter, would go to the branch. I don't think anything went to the branch other than that letter.

Q. You see in this letter on the first page, where you report to the branch, you say you're writing in reply to another letter and you say:

I investigated the matter further with the other elder ...

Then you set out some aspects of the investigation in the first paragraph. Then in the second paragraph you say:

We also spoke to other brothers and sisters in the congregation who knew about the matter through another sister who had spread the story after being told about it ...

You go on dealing with other people knowing. Going to the next paragraph, you say:

After interviewing the brothers and sisters and reviewing the scriptures ...

You identify them:

... we felt that "uncleanness" had been committed on several occasion but it was not "loose conduct". We felt that Brother Neill could not speak with confidence ...

And so on. You don't identify in that letter at all what the actual allegations were?

A. Well, that's true, yes. In hindsight, I'd say that we should have done that, and - yeah.

Q. You see, both Mr Horley and [BCB] say that there were also allegations made with regard to tongue-kissing - in the meeting that you were at. I take it that you don't contest that; you just say you don't remember it?

A. I don't remember it. I didn't think that it was, but I don't remember.

Q. So what was the uncleanness that you identify in that letter?

A. Well, the matter of the - Bill Neill watching her in the shower and the touching of the breast.

Q. Now, this report to the branch, is that a requirement, that you report to the branch when an elder is removed or deleted from being an elder?

A. Yes, yes, because the appointments back then came through the branch.

Q. The appointments of elders?

A. And recommendation, deletions, yes.

Q. And that's still the case, though, isn't it?

A. Yes, it is.

Q. And you say there:

... unfortunately there may be worldly people who also know but we are not sure.

In respect of people knowing, why is it that you drew the distinction between worldly people and people within the congregation, what's the relevance of that? A. It was mainly just to show how far it had got and, therefore, his qualifications - how far the information about Bill Neill had got, not just in the congregation but outside, and therefore his qualifications came into question - because of that and because of ones in the congregation and because of what actually happened.

Q. Was the disqualification because he couldn't be trusted with young girls?

A. Well, in this particular case, yes.

Q. That isn't what you say in the letter. The disqualification is that he couldn't speak freely, he didn't have freedom of speech?

A. Oh, well, sorry, yes.

Q. That's different, isn't it?

A. Yes.

Q. You were concerned that he couldn't speak with authority in the congregation, because of how people in the congregation might view him?

A. Yes, yes. Yes. So the wording, again, would be something that we would - I would consider different.

THE CHAIR: Q. Mr Jackson, the letter refers to you feeling that uncleanness had been committed, but not loose conduct. What's the difference? A. Uncleanness in the sense of what they actually did, or he did I should say. Loose conduct is where it's actual intercourse, other inappropriate things that could happen.

Q. So that's referred to as "loose conduct"? A. Well, also in the Bible as immorality, porneia.

Q. Where does the expression "loose conduct" come from Is that a Jehovah's Witnesses expression?

A. No, just in that reference material - I'm not sure if it's in there, but I would say that it's an expression that is mentioned in the Bible. Just offhand I can't remember the scripture, but also, too, the publications have explained it and even going into more detail in later publications, just explaining it.

Q. If a man deliberately touched the breast of a girl, how would that be classified?

A. Deliberately?

Q. Yes.

A. I would say as uncleanness, yeah.

Q. And if a man deliberately touched the breast of a girl on more than one occasion, how would that be described?

A. Well, you're getting into the area of loose conduct.

Q. Well, in this letter, you say that uncleanness had been committed on several occasions. Do you see that? A. Yes.

Q. Now, one can understand an accident?

A. Yes.

Q. But it's different, isn't it, if you've got several occasions?

A. Yes. Yes, that's why I say with the wording of it, I would probably word it as different.

Q. Well, if you've got several occasions, you're into the area of finding deliberate conduct, aren't you?

A. Mmm.

Q. Well, does that suggest the way that you classified these events, even on your limited reference to them, was wrong?

A. At the time, I would say that I felt that, or we felt that, it was correct, but I can also see what you're saying now and also, too, with additional information that we've received over the years, it could certainly be classified as different.

Q. Leaving aside the different information over the years, just looking back on what you knew then, as you recall it --

A. Yes.

Q. -- is the letter correct?

A. Well, as I said, it's correct in the sense that we, with our understanding then, but as you're saying, as it mentions "several occasions", then it would come under the field of loose conduct.

Q. Well, it's not my record; it's your words?

A. Yes, I know.

Q. Is the letter wrong?

A. I'd say the wording, yes.

Q. It might be suggested that the letter has been written in a way which is favourable to Brother Neill and more favourable than, in fact, the facts that you knew meant it should have been.

A. Because of that comment or --

Q. Yes, because of the finding.

A. Yes, although we did - I did mention there - I just noticed in the last sentence, "He has been given strong counsel and we feel that no further action or restrictions" are needed. So what we actually discussed with him from the Bible or the publications, I'm not sure, I can't remember, but I can't see how we showed him particular favour.

Q. Well, I think we've agreed that the --

A. Yes.

Q. -- facts that you had fell into the category of loose conduct?

A. Yes.

Q. But you didn't make that more serious finding; you'd left it at uncleanness?

A. Yes, yes.

Q. Isn't that favourable to him?

A. Well, again, looking at it, you could say yes, that possibly is the case, but, again, just the wording of it, I would have certainly done it different in thinking about it now.

Q. Again, it might be suggested that you fell into this form of finding and form of words because you were favourably disposed to Brother Neill, you see?

A. I don't think I was or we were, but, by the wording of it, yes, I can see what you're saying, your Honour.

MR STEWART: Q. You see, Mr Jackson, there was only one shower incident, or looking over the shower incident that was complained of, wasn't there?

A. I thought that was the situation, yes.

Q. But there were many instances, over a long period of time, of tongue-kissing.

A. Well, I was unaware of that. I didn't know.

Q. Because by using the words "several occasions", it seems that this may be a reference actually to the several occasions of tongue-kissing.

A. Yes, yes. I cannot say with confidence, but it could have been. But I just cannot recall that that was raised.

Q. Now, the classification of these different sins or severity of sinning, at that time, was as set out in Pay Attention to Yourselves and to all the Flock - is that right - that was published in 1991; is that right?

A. I think it was, yes.

Q. That's at tab 80. Perhaps we can look at Ringtail 24, page 92 of the document. You'll see there under the heading "Uphold Jehovah's Righteousness". The second bold paragraph says:

The Scriptures clearly show that Jehovah forbids certain conduct among his clean people; brothers need to uphold Jehovah's righteous standards regarding the following.

It then sets out various categories of transgression. The first is "Manslaughter".

A. Yes.

Q. Then there is "Sexual misconduct, including adultery, fornication and other forms of 'porneia'". Under that you'll see there are three subcategories? A Yes

A. Yes.

Q. The first one is:

Uncleanness includes an intentional momentary touching of sexual parts or caressing of breasts.

A. Yes.

Q. Then if we scroll down:

Loose conduct is a shocking, flagrant disregard for Jehovah's moral standards.

A. Yes.

Q. And some examples are set out?

A. Yes.

Q. And, thirdly:

"Porneia" involves immoral use of the genitals of at least one human ...

A. Yes.

Q. Then it goes on and sets out examples. So that was the classification you were seeking to employ; is that right?

A. Yes, yes.

Q. Do you know the origins, Mr Jackson, of this word "porneia"?

A. Just scripturally from the Greek. Deals with - as it mentions there - "'Porneia' involves immoral use of the genitals of at least one human", so it involves fornication and other forms of immorality, also including there oral sex, anal sex and mutual masturbation.

Q. So the word itself is of Greek origin, you say?

A. It's of Greek origin.

Q. Going back to your letter at tab 70, at the top of the second page, you'll see in the last sentence of that paragraph you write:

Also brothers, I would recommend that once this has died down and it appears that Brother Neill again has the freedom of speech that he be recommended as an elder again so that he can be of help in the congregation as he has done in the past.

Now, what does "freedom of speech" there mean to you, as you employed it? A. Well, freedom of speech is just, over a period of time, if those that knew about it no longer see it, themselves, as something that is a terrible thing that disqualifies him as an elder. But looking at that now, I certainly would re-write that area, because, even now, you know, one wouldn't be recommended without first of all considering the amount of time and years that that had happened, if at all, that he be recommended as an elder or ministerial servant.

Q. So you say that the time period should have to be considered?

A. Now?

Q. Yes.

A. Yes, and even then - it wasn't just something that was done within six months, but normally it would take a period of time. One of our publications said - I think the wording "many years" or - and even back then it was recommended that it would be several years to live down that sin that had happened.

Q. Because it's a reputational issue?

A. Yes.

Q. It's about Brother Neill's efficacy or potential efficacy as an elder?

A. Yes, yes.

Q. And the moral authority that he might have in the congregation?

A. Yes, and even - yes. Even, too, taking into consideration that - dealing with young people: would he be able to do that again? And, you know, with our recent letters that we've had, it certainly shows that he wouldn't be quickly recommended, if ever, no.

Q. But at the time that you considered what the proper course was in relation to [BCB], or [BCB]'s complaints, there was no consideration then about his potential reoffending?

A. No, not - no.

Q. Well, shouldn't there have been?

A. Do you mean for him, that we warned him?

Q. No, not that you warned him?

A. I'm sorry.

Q. That you took steps to protect children in the congregation, to ensure that he wouldn't offend against them?

A. Oh, yes, yes, yes. I just can't recall what we said to him or what happened, but we would have taken steps, yeah, that he don't - that he wouldn't get into that situation again.

Q. Insofar as him being reappointed as an elder some time in the future, your recorded concern here is about his reputation once this matter has died down - do you accept that?

A. Yes, and as I say, in hindsight, I definitely wouldn't have said that back then.

Q. But what you didn't consider is whether, over a passage of time, he could be considered to be safe and trustworthy with children?

A. Yes, yes, and that would certainly have been something now that I would definitely put in a letter.

Q. And you should have considered it then?

A. Yes.

Q. Do you accept that?

A. Yes.

Q. Mr Jackson, did you consider at all, when those complaints were made, that the conduct complained of may have amounted to a criminal offence?

A. No, I did not. No.

Q. Did you consider at all reporting the matter to the police?

A. No, I did not.

Q. Did you consider at all encouraging [BCB] to report the matter to the police?

A. I am not sure if we recommended that to her. As far as I'm aware, all we did was to have those meetings and to write that letter. If the branch wanted that further to happen, I guess they would have written to Max Horley on it. But I just cannot recall whether we did talk to her about that, or whether - yeah, I'm just not sure.

Q. In your considerable time and experience as an elder and as a circuit and then district overseer, has there ever been a case where you have reported wrongdoing that may have constituted a criminal offence to the police?

A. Not that I'm aware, because I never really got involved with those cases at all.

Q. So you say you were never involved in a case, within your responsibilities in the church, where the wrongdoing that was complained of was such that it may have constituted a criminal offence?

A. Offhand, I - I cannot recall any situation.

Q. Other than the case of [BCB], of course?

A. Yes, yes.

Q. What is your understanding of when matters should be reported to the police by elders or overseers, and when not?

A. I think the procedure now is that we ring the branch and we tell the person - the legal department - and we tell the one involved about reporting it to the police. I think every State has been different as regards to when this was implemented. I'm not sure, but that's what we've encouraged in the publications.

Q. But if there's no legal obligation to report, then the practice is to not report; is that how you understand it?

A. For sexual abuse, do you mean?

Q. Or any crime, including --

A. No, no, we'd certainly recommend, if a crime has been committed, that it be reported to the police.

Q. What about a crime of sexual abuse, you seem to treat that differently?

A. You mean, first of all, ringing the branch and asking for --

Q. Whether it should be reported?

A. I think we have direction that it should be reported.

Q. If there's a legal obligation to report?

A. Yes, yes.

Q. And if there's not a legal obligation to report?

A. Well, again, if there's any doubts, we are still encouraged to ring the branch legal department, just to seek direction from them what to do.

Q. And you would do as you were directed by them?

A. Yes. And not just one individual, but two individuals doing it.

Q. You mean the two elders?

A. Yeah, yeah.

Q. In your understanding, where do you expect that line to be drawn as to what is serious enough to be reported to the police and what isn't?

A. In a matter of crime?

Q. Yes, that's what the police are principally concerned with - crime?

A. Yeah, well, apart from child sexual abuse, areas of, say, theft, murder - yeah, general crime where they are breaking the law.

Q. As I understand it, you say you have never been involved in reporting a matter to the police?

A. No, that's correct, yeah.

MR STEWART: Those are my questions, your Honour.

THE CHAIR: Does anyone else have any questions?

MS GALLAGHER: I do, your Honour.

THE CHAIR: Anyone else?

MR COYNE: Yes.

THE CHAIR: Who should go first?

MR COYNE: Probably my friend.

THE CHAIR: I think so. Does anyone else have any questions?

MR TOKLEY: no, your Honour.

<EXAMINATION BY MS GALLAGHER:

MS GALLAGHER: Q. Just in reference to tab 70, the letter that you wrote - I beg your pardon, my name is Gallagher and I represent [BCB]. A. Yep.

Q. If tab 70 could be called up, please. Can I just clarify, Mr Jackson, the second paragraph there where you indicate:

I investigated the matter further with the other elder in the Narrogin congregation, Brother Max Horley ...

you say:

... and spoke to the sister involved and her husband and also other brothers and sister in the congregation. We gave counsel to both the husband and the wife about going to the elders and setting the matter straight with Jehovah ...

Could I clarify with you who you are talking about when you say, first of all, "I spoke to the sister", was that [BCB] - is that who you were referring to? A. So are we talking about the sister involved and her husband?

Q. Yes. Is that [BCB] and [BCC]?

A. I'd say so, yes.

Q. And then when you talk about, "We gave counsel to both the husband and wife about going to the elders and setting the matter straight with Jehovah", which husband and wife are you talking about there. Are you talking about Mr and Mrs Neill or [BCB] and [BCC]?

A. I would say - I was unsure she was married then, but I would say it would be to [BCD] [sic] and her husband.

Q. What did they have to set straight with Jehovah?

A. Well, it wasn't that, I think it was keeping in mind that scriptural principle of James, was really just going to the elders to try and get help from the elders, because I think it had been spread - I'm not saying by them but by somebody, I can't remember who it was- where other people started to know about it.

Q. Was there an element then of her being chastised for spreading something that could --

A. No.

Q. -- affect the congregation?

A. No.

Q. The reputation of Jehovah?

A. No, even the word "counsel" - again, I wouldn't use that word again.

Q. But you did,and you said --

A. Yes.

Q. You've given evidence that you didn't keep any notes about conversations?

A. Yes.

Q. That's right, isn't it?

A. Yes.

Q. So this is our best record, do you agree with that?

A. Yes.

Q. And it's dated around the time, obviously, 1992, around the time --

A. Yes.

Q. -- that you spoke with [BCB] and [BCC]?

A. Yes.

Q. What do you think you might have meant, then - just before leaving this topic, what do you mean by "setting the matter straight with Jehovah"? A. Well, just going to see what is - how they could be helped or encouraged.

Q. And you didn't mention going to the police for help and encouragement in reporting the matter?

A. No, that's correct.

Q. The next sentence is:

Then showed that after we have done this, that if we have repented Jehovah would forgive us.

An element there that these two - if it was reference to [BCB] and [BCC] - that they were, the two of them actually, being chastised?

A. Yes. I would say, though, that referring it, too, with [BCD] [sic], it was more to Bill Neill than to her, that he needed to turn around and change.

Q. So you would deny that there was any element of [BCB] and [BCC], her husband, in any way being chastised for telling others about this conduct?

A. I don't think we would have chastised them, but we would have encouraged them to try and settle the matter within - you know, talking to the elder back there, who was Max Horley, and try to do what we were doing here, as two of us.

Q. If you go to the second page of tab 70, the top right-hand reference is 0505. Could I just clarify: you note in the middle of that paragraph - well, before I ask that question, this paragraph really is very sympathetic to Mr Neill, or Brother Neill, isn't it?

A. Yes.

Q. Indicating, from the previous page, that he has accepted counsel and you were impressed by his humility throughout the ordeal.

A. Yes. Yeah.

Q. So he was treated, it seems from this letter, with kindness and sympathy; correct?

A. Yes, yes, because we try to do that as well as to the guilty, to help them, yeah.

Q. You indicate in that paragraph, if I could take you to the sentence:

Now that it is all in the open and discipline has been applied and accepted he feels much better about his relationship with Jehovah.

Do you accept that everybody, including members of the Jehovah's Witnesses, is subject to the discipline of the State?

A. How do you mean, sorry?

Q. Well, the church had disciplined him.

A. Yes.

Q. But do you accept that - I think when being asked questions by counsel assisting, your reference to "several occasions" on the previous page may, indeed, have been a reference to something you don't recall now, but the kissing with the tongue. Now, "several", of course, indicates that it was more than once, more than three times. It's hard to calculate how many - do you agree with that proposition?

A. Yes, yes.

Q. So that, as a child, this girl, [BCB] - of course she was a young woman when you interviewed her, but she appears to have been subject to several, multiple even, indecent assaults - do you agree with that proposition?

A. Yes.

Q. Do you understand what an indecent assault is?

A. Well, from my recollection - I don't know what the law is, but I'd say that it deals with things such as this type of thing that happened to [BCD] [sic].

Q. Yes, sorry,the invasion of somebody's space - in fact,their person - coupled --

A. Yes.

Q. So that's the assault, coupled with an act of indecency, which of course would be the insertion of the tongue in the mouth.

A. Mmm.

Q. Do you understand, do you have an appreciation that if this matter had been reported to the police before this young woman was confronted with her abuser, as occurred - you accept that; correct?

A. Yes.

Q. Do you accept, or are you aware of this: if Mr Neill had been charged with multiple acts of indecent assault, just say - do you have an appreciation that he probably would have received bail to stay away from [BCB]? A. At that time. no.

A. At that time, no.

Q. Do you understand also that he and anyone associated with him would have had to have stayed away from her?

A. Yes.

Q. Do you have an appreciation that that's what would have happened?

A. Yes.

Q. Likely have happened?

A. Yes, and our publications have certainly stressed that over these years.

Q. Do you have an appreciation, also, that if the matter had gone to hearing,[BCB] would not have had to face her abuser, even then, because there are facilities available for victims of sexual assaults to give evidence from remote locations.

A. Yes, that I do know now. Then, no, I did not know.

Q. So you'd agree, given the care with which the State deals with these sorts of allegations, that greater care should have been given by members of the faith; do you agree with that, in how you treated [BCB]?

A. Yeah, sure. Yes, I do believe that is the situation and I feel that, you know, we really did - while I was there for those six days, we did try to help her, encourage her.

Q. Can I interject there, I beg your pardon. You didn't did you? You didn't encourage her to go to the police, did you?

A. Well, that's true, yeah, I didn't do that. But I'm saying that we still tried to help her.

THE CHAIR: Q. Mr Jackson, it's plain from her evidence that she was very severely affected by these events - do you agree?

A. I would say yes.

Q. It's also plain that the process that you engaged in inflicted further trauma on her - do you understand that?

A. I understand it, but at the time I don't think I appreciated it to that degree.

Q. There is no reference in this letter of any concern for her or her welfare or what Jehovah's Witnesses might do to help her, is there?

A. I thought there were some publications that we quoted and scriptures that we would have used to help her - in the letter, I thought.

Q. But it's clear that she needed psychiatric help?

A. Well, we - if she felt that and we felt that, then we certainly - well, she would have questioned us on it and we certainly would have recommended it.

Q. Did it occur to you at the time that she may need help from medical professionals?

A. I'd say no.

Q. Well, you know now that she has done,and does need it. Is Jehovah's Witness prepared to help her to receive it?

A. I would say they certainly would, yeah. They would be conscious of spending time with her and they would also recommend her seeking medical help.

Q. Would they be prepared to pay for it?

A. Well, I don't think I could answer that question.

Q. Why not?

A. Well, you'd have to - they'd have to write to the branch or the Governing Body just to seek out that.

Q. It's not an automatic matter, is it - if someone is damaged by the actions of an elder?

A. Not that I'm aware of, sorry.

Q. Do you think the church should provide funds to help her with her medical care?

A. I guess it would be something for them to consider, but --

Q. No, what about you: do you think the church should? A. Well, I think we give a lot of assistance to them. I think it's an area that I really haven't thought about and I wouldn't like to say. I think financial assistance is a big thing that maybe, you know, they could be thinking about, but I wouldn't make that statement that they would do it or wouldn't do it.

Q. What would you recommend if you were asked your opinion as to whether they should give her financial support for medical care?

A. I think it could be considered.

MS GALLAGHER: Thank you, your Honour.

<EXAMINATION BY MR COYNE:

MR COYNE: Q. Mr Jackson, I just want to clarify --

THE CHAIR: You need to identify yourself, because people are watching this on the screen.

MR COYNE: Certainly.

Q. My name is Mr Coyne and I appear for you, amongst others. Ms Gallagher was just asking you questions about tab 70, which was your letter. If that could be brought up again, please. At paragraph 2 you were asked in relation to where you have written:

We gave counsel to both the husband and the wife about going to the elders and setting the matter straight with Jehovah.

You were asked whether that referred to [BCB] and [BCC], being her husband, or it referred to the Neills; correct? A. Yes.

Q. After you have said that, it quotes James 5:13-15. Is that in relation to what you've just said before, though? A. Yes, it encourages ones who have been damaged in some way just to go and try to talk to the elders so the elders can help them and encourage them.

Q. Yesterday you were asked questions about how [BCB] would have been aware of the process of how complaints were dealt with; correct?

A. Yes.

Q. When a member of the congregation is approaching baptism, are they given a book to study?

A. Yes, it's entitled "Organised for the Ministry"

I think.

Q. That book contains various questions relating to the baptism?

A. Yes.

Q. And that is a book that those people are expected to be conversant with?

A. Yes.

Q. And that is a book that they are expected to also consult throughout their lives in relation to matters relating to their faith?

A. Correct, yes.

Q. If we could bring up tab 109, please. Are you able to identify that? Is that the book?

A. Yes, "Organized to do Jehovah's Will".

Q. And that is the book that people get when they are approaching baptism?

A. Yes.

Q. If we go to Ringtail 88, please, and you see that heading "Handling Cases of Serious Wrongdoing"? A. Yes.

Q. So this is something that would be contained in the book that each and every Jehovah's Witness should have when they are approaching baptism?

A. That's correct.

Q. And should be aware of?

A. Should be, yes.

Q. Moving on from that document, you were also asked yesterday various questions about the procedures by which an investigation took place and you were shown various sections from the book of elders?

A. Correct.

Q. One of your responses was that you would refer to the book of elders, but you would also look to letters and publications; correct?

A. Correct.

Q. You've said that again today. If we could go to tab 124, please. Is that one of the letters to which you refer?

A. It is, yes.

Q. That one is dated 1 October 2012?

A. Correct.

Q. It's addressed to "All Bodies of Elders"?

A. Yes.

Q. And it says there in the first paragraph:

This letter updates the letters to All Bodies of Elders regarding child abuse dated August 1, 1995; March 14, 1997; July 20, 1998; April 1, 2004; June 5, 2006; and May 24, 2010.

Correct?

A. Yes, correct.

Q. It also asks that all those previous letters be removed from the congregation permanent files?

A. Yes.

Q. So as of 1 October 2012, this really was the document that you would refer to for matters after that date; is that right?

A. Correct, yes.

Q. And the contents of that letter related to "Legal concerns regarding accusations of child abuse"? A. Yes.

Q. "Congregational concerns regarding accusations of child sexual abuse" - that's the second point under the "Table of Contents", right at the top?

A. Yes.

Q. I'm sorry, it's right at the top of the document. Do you see that?

A. Yes, "Congregational concerns regarding accusations of child sexual abuse", yes.

Q. "Helping victims of child sexual abuse"?

A. Yes.

Q. And "Restrictions and privileges"?

A. Yes.

Q. So when you were talking about referring to letters, was that --

A. That's correct.

Q. -- this document, amongst others?

A. Yes.

Q. You spoke about also referring to publications. When you say that, were you referring to articles that would have appeared in the Watchtower and the Awake! magazine? A. Yes, there have been articles, really, way back in 1970, in the 1980s and 1990s and in 2000.

Q. When you say "articles", you mean articles relating to child sexual abuse?

A. Yes, yes.

Q. Are those publications available to everyone within the congregation?

A. Yes.

MR COYNE: Nothing further.

THE CHAIR: Yes, Mr Stewart.

<EXAMINATION BY MR STEWART:

MR STEWART: Q. If you go to tab 109, please, the first page, this is the "Organized to do Jehovah's Will" document that you referred to?

A. Correct.

Q. Your involvement with [BCB]'s case was in 1992; right?

A. Yes.

15265 D J JACKSON (Mr Stewart) Transcript produced by DTI Q.

If you go to page 2 of tab 109, you'll see this document came into effect in 2005?

A. Correct.

Q. I take it you then wouldn't have expected [BCB] to have had this document in 1991-92?

A. No, but we did have a document prior to that.

Q. What was that?

A. I think it was entitled "Organised for the Ministry" or "to do the Ministry".

Q. You don't know, offhand, just what that said about the processes?

A. I can't remember. I can't remember the release or just what it says - the release date, I should say.

MR STEWART: Thank you, your Honour.

THE CHAIR: Yes, thank you, Mr Jackson, you're excused.

THE WITNESS: Thank you very much.

MR STEWART: The next witness is Mr Bello. Would this be a convenient time, your Honour?

THE CHAIR: All right. We'll take the morning adjournment.

<THE WITNESS WITHDREW

SHORT ADJOURNMENT

THE CHAIR: Yes, Mr Stewart.

MR STEWART: Your Honour, the next witness is Mr Joe Bello. His statement should be behind tab 9.

THE CHAIR: Mr Bello, it's necessary for you to be sworn. Will you take an oath on the Bible or an affirmation?

MR BELLO: Whichever. I don't mind.

THE CHAIR: Well, it's a matter for you.

MR BELLO: Yeah, the Bible will be fine.

THE CHAIR: Sorry.

THE WITNESS: Yes, that's fine.

THE CHAIR: What's fine?

THE WITNESS: The Bible.

<JOSEPH BELLO, sworn:

[11.46am]

<EXAMINATION BY MR STEWART:

MR STEWART: Q. Mr Bello, will you state your full name?

A. Joseph Bello.

Q. Do you have before you a copy of your statement dated 10 July 2015? A. Yes, I do.

A. Yes, I do.

Q. Are there any amendments or corrections you wish to make to the statement?

A. Not that I know of. As long as it says I submitted it, that's fine.

THE CHAIR: Mr Bello, I wonder if you could come to the closer to the microphone and could you speak a bit louder because that microphone is the resource for a lot of people who aren't actually in this room who may wish to listen to you.

THE WITNESS: Certainly.

THE CHAIR: Maybe just twist it up a bit, that might help. Yes, Mr Stewart.

MR STEWART: Q. Do you confirm that your statement is true and correct, Mr Bello?

A. Yes.

MR STEWART: I tender the statement.

THE CHAIR: That will become exhibit 29-005.

EXHIBIT #29-005 STATEMENT OF JOSEPH BELLO DATED 10/07/2015 MR STEWART: Q.

Mr Bello, you were baptised as a Jehovah's Witness in 1973; is that right? A. Yes.

Q. You were appointed as an elder in 1991?

A. Yes.

Q. Since then you have served in that capacity in the [REDACTED] congregation?

A. Yes.

Q. How big is that congregation?

A. About 90 publishers, or so, at the moment.

Q. In paragraph 2 of your statement, and perhaps if we can scroll down, you deal with the subject of reporting or how elders respond to complaints of child sexual abuse. You'll see what you say at the foot of that page and over the next page. You say there that you report immediately to the branch office, which then advises of any requirements of mandatory disclosure to relevant authorities; is that right?

A. Yes.

Q. If you are not advised by the branch office to report to a secular authority, such as the police, then I take it that you don't do so?

A. I wouldn't unless somebody brought it to my attention that there was some legal requirement.

Q. So if there's a legal requirement to report and that is brought to your attention, you'll report?

A. If there's a legal requirement, we always try to do what the law says, definitely.

Q. And if there's not a legal requirement, then you don't report?

A. Not unless we were advised to do so.

Q. And by "advised to do so", you mean advised by the branch?

A. Yes

A. Yes.

Q. So are there no circumstances, then, in which you would report a matter to the police if you hadn't been advised by the branch to do so?

A. Look, I don't know what situation would come up and how it would come up.

If I had a question about it, I'd ask the branch.

Q. If we look at paragraph 2.2, the matter is then handled internally, is it, if a complaint is made of child sexual abuse, in the manner you set out in paragraph 2.2; in other words, two elders are directed to investigate the complaint; if substantiated a judicial committee of three elders is appointed, and so on. Also, in 2.4, "Where a person has been found guilty of child sexual abuse", that's guilty by the judicial committee, is it, that you're referring to?

A. Yes.

Q. Then:

... the elders privately counsel him as to appropriate behaviour with children, such as not spending time with them without another adult present, not inviting them to his home, not engaging in displays of affection with children and so on.

If we go to paragraph 4.1, you see there you say:

The case involving [BCB] is the only one concerning child sexual abuse in which I have been involved.

A. Yes.

Q. Since you wrote the statement, have you thought of any others you have been involved in, Mr Bello?

A. No.

Q. Our records suggest that there are two others that you were involved in. You're going to be shown their names. The idea is that you don't read the names out, nor will I. It will be an aid to your memory. When you see those names, does that help you remember two other cases? A. One name here I recall as something that happened before the [REDACTED] congregation was formed or I was part of it. I don't even know the person. The other case was a situation of someone who hadn't been attending for a long, long time and it was handled by the police and I had no involvement.

Q. So, dealing with the first case, which I understand you to say was before the [REDACTED] congregation was formed, was that a case of child sexual abuse?

A. From what I've been told, yes. I don't know anything much about it.

Q. And you didn't have any involvement in it at all, you say?

A. No, none at all.

Q. The second case was someone who had been in the congregation but had been away from the congregation for some time; is that right?

A. Yes, that's right, and events happened and I heard about them after they'd been dealt with by the police and everything, so I wasn't involved at all.

Q. Events happened outside of the congregation?

A. Mmm.

Q. In the case of [BCB], in your paragraph 5, which is on the screen - and if we can scroll down to the substantive part of the paragraph, further down the next page, 5.1 you say:

Sometime in 2012, I can't remember the exact date, [BCB] asked the elders to visit her to discuss an issue. I and David Wood visited her and her husband ... at her home.

Then you carry on in that paragraph to set out your involvement. Now, you then reported that involvement to the branch office; is that right? A. I didn't do it personally. Brother David Wood and another elder phoned the branch.

Q. What was reported to you as to what the response was from the branch?

A. I can't remember exactly, but the gist of it was to provide whatever help we can, to get whatever information [BCB] can provide us, and to provide that to the branch.

Q. Can I show you tab 71. Do you recognise this letter, Mr Bello?

A. Yes, I do.

Q. It's 18 December 2012 and it's from you to the service desk.

A. Mmm-hmm.

Q. Can you explain the circumstances in which this letter came about, where you're writing to the service desk about [BCB]'s case in 2012?

A. When we went to see [BCB], she provided us with details of what had happened and then, after contacting the branch, we asked [BCB] if she would be happy to put that into some written form that we could send to the branch. And after a couple of weeks she provided that to us and we wrote a covering letter, this covering letter, and sent that on with what was provided to us, to the branch.

Q. And, by that time, Mr Neill had been deceased for quite some time?

A. I really don't know when he died. I don't know. I believe he had died already, but I don't know.

Q. At the time that you wrote the letter, did you know that he had died?

A. I really can't remember if [BCB] was able to tell us what had happened or not. Could be, but I can't remember.

Q. What was the purpose, in your understanding, of making this report to the branch about these events that had occurred many years before?

A. We did it on the wording that [BCB] gave us, which is she wanted to make sure the branch had these details in case someone else had had similar experiences with the same brother.

Q. Did you have any expectation as to what the branch might do with this information?

A. No, I didn't know. I presumed that they would have other details from when it was handled and that would help them to work things out.

Q. So they may be able to match the information with --

A. Yes.

Q. -- some other information they already have?

A. Mmm.

Q. Then, if we look at the next tab, 72, two years later, December 2014, you had cause to write again to the branch.

Do you recognise this letter? Perhaps we can scroll down for you. A. I don't remember writing that letter, but I probably read it and signed it.

Q. Well, if you look at the end of the second page you'll see that you're quite right in that regard. Who wrote this letter, do you remember?

A. This would have been written by David Wood and Robert Boardman.

Q. What makes you conclude that?

A. Because I know that they were handling the matter after I wasn't involved in it anymore.

Q. Well, your name is here and you've signed the letter. In what sense were you not involved in it anymore?

A. I wasn't actively trying to help [BCB] or give support at that time.

Q. You'll see on the first page of the letter, if we can go back to paragraph 2, that it is recorded that the alleged perpetrator is Brother Neill, now deceased. So at the time you wrote that letter, you, of course, knew that he was deceased?

A. Yes, at that time.

Q. What was your understanding of the writing of that letter?

A. My understanding --

Q. Sorry, as to its purpose?

A. My understanding was that we had further details provided by [BCB] and, from recollection, there were a lot more details in terms of names, dates, things like that, so it was providing further information as it became available.

Q. If we go over the page to paragraph 6, you'll see it says:

In about July 2014, brother Bello paid a friendly visit to both [BCC] and [BCB] at their home. It was only at this time that [BCB] made mention that she was considering reporting the matter to the Royal Commission on child abuse and seeking Firstly, you were, of course, involved in this matter by visiting [BCB] and her husband and discussing the matter; is that so?

A. Yes.

Q. Perhaps you can tell us just what occurred in relation to the possibility of the matter being reported to the Royal Commission?

A. Well, that matter came up earlier when [BCB]'s husband and I were out in the ministry and then afterwards, when we went back to the car, we sat in the car and we were having an informal conversation about how [BCB] was feeling and coping, et cetera, and her husband said that they were thinking of taking the matter to the Royal Commission and I made - I asked the question, I said, "But what would that accomplish" - sorry, my mouth is dry - "other than dragging Jehovah's name through the mud?" So I guess it might be a reference to that. Then [BCB]'s husband told me what he felt would be accomplished. He said, "A measure of closure and also maybe financial compensation", and I said I could see the point about the closure. I also asked - I didn't know that the Royal Commission was about financial compensation, and he said, "Yes, we've looked into it", and that was it.

Q. So you'll understand how, in you asking the question, "What would that achieve other than dragging Jehovah's name through the mud?", that would be understood as a discouragement to go to the Royal Commission?

A. It might be understood that way, but that's not how it was meant. It was an informal conversation. I asked the question, "What would it accomplish" - yes, I was thinking out aloud, and, thinking back on it, I shouldn't have said the rest of the sentence.

Q. I take it within your faith, Jehovah is considered as a loving God?

A. Definitely.

Q. Would Jehovah, then, not also then not be more concerned about the victim than his own name?

A. Jehovah would be concerned about the victim, but Jehovah is concerned about his own name, too, that's what the scriptures told us.

Q. Would his name not withstand public knowledge of dreadful things wrongly done by somebody professing to follow him?

A. I don't think that that was my point. My point was simply to ask the question, "What would be accomplished?", and, yes, there was some thinking aloud, and that's all.

Q. Can you understand how, by putting that question in that way, it contributes towards feelings of guilt that [BCB] has in bringing the matter to the Royal Commission? A. I was talking to her husband and, looking back, I probably would have worded that different, but at the time that's how it came out.

Q. If you look at your statement at paragraph 5.13, and that's where you explain the statement as you've explained it now in the witness box, and you say:

I was wrong to say it ...

In other words, ask that question about dragging Jehovah's name through the mud:

... and I would never want to discourage someone going to the authorities with a complaint of child sexual abuse. This is also against the direction we receive as elders from the Branch.

I take it that the direction that you're referring to is that if people want to report to the authorities, they should not be discouraged from doing so? A. That's right.

Q. You don't mean to say that there's a direction from the branch to positively encourage people to go to the authorities?

A. I just mean whatever the letter says. I can't remember the exact wording, but whatever the letter says.

Q. Well, we're looking now at your statement, not at the letter.

A. Yes.

Q. And your statement says:

This goes against the direction we receive as elders from the Branch.

I'm seeking to understand what it is you're saying there. You've agreed that it's a reference to a direction not to discourage people from taking reports, or reporting to the police - right?

A. That is the direction.

Q. And I'm seeking to understand, you're not saying there is any direction to positively encourage people to go to the authorities?

A. I don't believe the letter says that, so I'm not saying that. I'm saying whatever the letter says.

Q. We're not talking about a letter. We're talking about your evidence.

A. Mmm.

Q. There's no direction, to your knowledge, to positively encourage people complaining of sexual abuse to go to the authorities; is that right?

A. The direction is to encourage them to do whatever they feel is best - whether that be to report it or not report it, apart from whatever legal requirements there are, which, of course, we would follow.

Q. Do you know of any case where a victim of a crime has been encouraged to take a matter to the police?

A. No, but then I don't know the opposite, either.

Q. Do you know of any case where an elder has reported a crime that has been reported to him to the police?

A. No, I don't, and I don't know the opposite, either.

Sorry, I don't mean to answer in the wrong way. I'm just saying it's a hypothetical situation. I don't know.

MR STEWART: Those are my questions, your Honour.

THE CHAIR: Q. Can we just look at document 77. Are you familiar with this document?

A. It would appear to be one of our articles in the magazines.

Q. Yes. Are you familiar with it?

A. I can't say that I'm very familiar with it. I'm sure I've read it in the past, but it's not as if I can remember the details, no.

THE CHAIR: Do we have a hard copy of it?

Q. You're welcome to look at it, but it seems to be a discussion of the trauma that a victim of incest might suffer. Do you see that?

A. Yes.

Q. Then on page 30 it seems to be, from the publication which will be the fifth page, I think, what is said a realistic view and the permanent solution. Do you see that?

A. Mmm-hmm.

Q. Now, the realistic view is said to be the way of helping the victim of emotional trauma - do you see that?

A. Mmm-hmm.

Q. And it talks about biblical references and goes on to talk about the permanent solution in biblical terms. Do you see that?

A. Yes.

Q. People who suffer incest can, of course, suffer great trauma, can't they?

A. Yes.

Q. This document seems to be totally focused upon a biblical response, not a medical, if you like, psychiatric or psychological response. Do you understand what I'm saying?

A. Yes, I understand.

Q. Does the doctrine that you're taught exclude or confine in any way the need for a person who suffers trauma to receive conventional help from qualified practitioners? A. Certainly not. That's a personal choice. We don't make a recommendation one way or the other, but sometimes it's pretty obvious that professional help is needed to help the person. All we can do is help the person spiritually.

Q. [BCB] obviously needed professional help.

A. She told me that she had been seeing professional help, yes.

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