Lisa McPherson Files - Statement of Glen Edward Steilo

This is the statement of Glen Edward Steilo, a Scientologist who was appointed as "Custodian of Records" in the Lisa McPherson case.






DATE:		July 24, 1997

TIME:		Began: 2:15 p.m.
		Ended: 5:15 p.m.

PLACE:		Criminal Justice Center
		Office of the State Attorney
		Room 1000
		Clearwater, Florida

		Registered Merit Reporter
		Notary Public
		State of Florida at Large


	 TAMPA AIRPORT MARRIOTT - (813) 224-9500
	ST. PETERSBURG/ CLEARWATER - (813) 821-3320


3		Office of the State Attorney
		Criminal Justice Complex, Room 1000
4		Clearwater, Florida 33760
			Attorney for State of Florida
6		Zuckerman, Spaeder, Taylor & Evans, LLP
		SunTrust Financial Centre, Suite 2525
7		401 East Jackson Street
		Tampa, Florida 33602
8				-and-
9		Icot Center, Suite 108
		13630 58th Street North
10		Clearwater, Florida 33760
			Attorney for the Witness
		WAYNE C. ANDREWS, Detective Sergeant
13		City of Clearwater Police Department






19				I N D E X

21		BY MR. McGARRY			  3
		BY MR. CROW			113




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1		The deponent herein,


3  	being	first duly sworn to tell the truth, the

4  	whole truth, and nothing but the truth, was

5  	examined and testified as follows:


7   BY MR. McGARRY:	

8   	Q. All right. State your name, please.

9   	A. My name is Glen Edward Steilo.

10  	Q. And your date of birth?	     

11  	A. X, 1950.

12		MR. McGARRY: Okay. Before we get started,

13	do you or your lawyers want to put anything on the

14	record in reference to him being here pursuant to a

15	subpoena?

16		MR. FUGATE: Right. I was just going to get

17	the subpoena out.

18		He is here pursuant to the subpoena. You've

19	got the style, if you've got it there, to read into the

20	record.	And he's prepared to testify under that

21	subpoena about the issues. And we've given him a copy

22	of the letter to read, which is Mr. Crow's letter of

23	July 16th, 1997. And he's obviously had a copy of the

24	State Attorney's Investigation Subpoena 40-86-61, I

25	think that's the same, and 62 to refer to. And I'll

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1		give it to him.


3		Q. All right. Well, this will be considerably

4	shorter if you've got the results of the items that I've

5	subpoenaed. And I take it you do not?

6		A. No, I don't.

7		Q. Okay. So then this will be longer then that

8 	route.

9		Let me get some background from you and then

10	we'll -- I'll let you make kind of -- I'm sure you have a

11	statement as to what you've done in reference to this case.

12	And then from there I'll have some additional questions, as

13	will the -- as will the Detective and Mr. Crow, I'm sure.

14		How long have you been with the Church?

15		A. I've been a Scientologist since 1974.

16		Q. All right. And how long have you been in

17 	Clearwater?

18		A. I've been in Clearwater twice. First time from

19	1981 until 1985, and recently since December 15th, 1996,

20	until the present.

21		Q. All right. Let's back up and cover when you first

22	became a Scientologist. What -- what city was that?

23		A. It was actually Fort Hood, Texas. The

24	Church of Scientology there in Austin, Texas, is where I

25	became a Scientologist.

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1		Q. All right. And were you what they call Staff in

2	Texas or did you -- were you just a public member?

3		A. Parishioner.

4		Q. Okay. And did you ever become a Staff member when

5	you were in Texas?

6		A. No.

7		Q. Okay. Was there a time that you became Staff and

8	eventually moved to Clearwater?

9		A. Yes. Actually, I became a Staff member of the

10	Church of Scientologist in Munich, Germany. That was in,

11	let's see, the 1st of April, 1977.

12		Q. Okay. So you went from Texas to Munich?

13		A. To Germany, actually. More correctly to

14	Idar-Oberstein, Germany.

15		MR. WEINBERG: Just so it's clear, he was in

16	the Service. He went to the Citadel. And there

17	might --

18		Q. The reason you went to Germany was for the

19	Service, not the Church?

20		A. Yes, exactly.

21		Q. So you came back here. And did you come back from

22	Germany to Texas?

23		A. No. What I did was, precisely, left from Texas to

24	Germany. I performed a year of military duty in

25	Idar-Oberstein, and then I left the Service to join the

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1	Church Staff in Munich. And I	worked for Munich -- I worked

2	in Munich from -- let's see, it was April, 1977, until

3	August of 1981. And that's when I came -- from August,

4	1981, I came directly here to Clearwater.

5		Q. Were you still a member of the Service at that

6	time or had you been discharged?

7		A. No. I'd been discharged in 1977.

8		Q. All right. So the purpose of you moving to

9	Clearwater was for -- to continue working with the Church as

10	a Staff member?

11		A. Yes.

12		Q. What was your position when you first came here in

13 	'81?

14		A. When I first came here I was, let's see, in charge

15	of the Church's public relations and legal matters. 

16		Q. And that was in '81?

17		A. 1981.

18		Q. All right. And that lasted how long?

19		A. That lasted until -- let's see. It was about six

20	months. In other words, I was supervising those two areas.

21	And then in six months I moved into solely legal matters.

22		Q. Okay. And when you say "solely legal matters,"

23	what -- give us an idea what you're talking about.

24		A. Well, more specifically, I started working in

25	something called Rudiments. That's the Church's term for

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1	requirements of law that the Church has to meet;

2	specifically, tax filings, payments.

3		Q. Okay. What is your educational background?

4		A. Bachelor of Science, mathematics.

5		Q. All right. Do you have any legal training?

6		A. Only under the Church's attorneys. Strictly

7	hands-on type training.

8		Q. And that occurred when?

9		A. Well, that's occurred since 1981 until the

10 	present.

11		Q. Okay. How long did that period last, from '81

12	until when?

13		A. 1985.

14		Q. '85. Then you left Clearwater?

15		A. Yes.

16		Q. And where did you go?

17		A. Los Angeles, California.

18		Q. And why did you go there?

19		A. To work in what we call the -- the

20	Church of Scientology International and in the

21	Office of Special Affairs there.

22		Q. All right. Was that a transfer that you requested

23	or something that the Church suggested you do?

24		A. I actually requested it.

25		Q. All right. And how long did that last?

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1		A. That was from, let's see, 1985 until 1996.

2		Q. All right. So you weren't here during the period.

3	of time that Lisa McPherson was involved with the Church

4	then, right?

5		A. No.

6		Q. That was when you were in L.A.?

7		A. That's right:

8		Q. So let me write that date down so I can use it in

9	reference. You got back here in what month? ,

10		A. December 15th, 1996.

11			(The witness and his counsel confer.)


13		Q. All right. Why were you. transferred back to

14 	Clearwater?

15		A. Well, on that particular date I came here with the

16	Church attorney regarding this matter.

17		Q. This matter?

18		A. The McPherson matter.

19		Q. And what attorney was that?

20		A. Elliott Abelson.

21		Q. So you came specifically back to Clearwater in

22	reference to this case?

23		A. Yes, sir.

24		Q. What -- in your conversations with Mr. Abelson,

25	what were your duties going to be? What was the purpose for

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1	you coming --

2   			MR. FUGATE: We're going to impose an

3		objection because that's going into --

4			MR. McGARRY: I'll rephrase it.

5			MR. CROW: Don't rephrase.

6			What's your objection?

7			MR. FUGATE: Well, the objection is that

8		you're getting into -- he was assigned to work on legal

9		matters with counsel for the Church . And in fact,

10		currently he's on the team that works with

11		Mr. Weinberg, Laura Vaughn, myself, and we don't want

12		him getting into any of those sorts of conversations.

13		What he did -- if you want to ask him what he did --

14			MR. CROW: Go ahead and ask the question. If

15		he refuses to answer, then we'll take it from there.


17		Q. All right. What is it you came from L.A. to do?

18		A. Well, to do what Mr. Abelson needed for me to do,

19	literally. He was going -- he -- he came here because of

20	the McPherson matter. He was going to look into the legal

21	matters of the case. And actually, all I did was follow his

22	directions at that time.

23		Q. How long was he here?

24		A. He was here until about -- and I'm not too clear

25	on this. It was about February, I believe, January or

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1 	February.

2		Q. All right. Who were the lawyers here locally that

3	you worked with for the Church? Not these lawyers, the

4	lawyers with the Church.

5		A. At that particular time there was no one. I was

6	working for Elliott Abelson. 	

7		Q. He's the only one?

8		A. Yes.

9		Q. 'here weren't any other local.-attorneys other than

10	these two that were working with the Church?

11		A. There were other counsel, but I wasn't working

12	with them.

13		Q. Who were they?

14		A. There was Mr. Robert Johnson and I believe

15	Mr. Paul Johnson. No others that I'm aware of.

16 			MR. CROW: Is Mr. Abelson licensed to

17		practice law --

18 			THE WITNESS: Yes.

19 			MR. McGARRY: -- in Florida? That is the

20		question.

21 			MR. CROW: In Florida?

22 			THE WITNESS: In Florida, I don't know.

23 			MR. CROW: Is he licensed in California?

24 			THE WITNESS: Yes.

25 			MR. CROW: Okay. It was your understanding

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1		that your conversations with him were privileged at the

2		time?

3  			THE WITNESS: Oh, yes.
4			MR. CROW: Okay.


6		Q. All right. Why don't you give us -- so you

7	weren't -- so you have been the Custodian of Records for the

8	Church right now since you got here, is that what you're

9	telling us? 	

10		A. No, since April 23rd: April 23rd.

11		Q. Okay. Who was the custodian for service of

12	subpoenas in Clearwater prior to you?

13		A. I don't know.

14			MR. WEINBERG: If you know.

15		A. I don't know.

16		Q. So you don't know whose job you took over?

17		A. I don't think I took over anyone's job. I think

18	that -- I think our counsel were answering the subpoenas.

19		Q. You're not aware of -- of a Custodian of Records

20	for the Church prior to you?

21		A. No.

22		Q. Is there anybody else in the Church that accepts

23	subpoenas for the Church other than you?

24		A. The counsel. Our counsel.

25		Q. Well --

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1		A. That would be Mr. --

2		Q. These people have only been involved in the case

3	since Lisa McPherson died. I'm talking generally, the

4	Church, who did they designate as the accepter for service

5	for any --

6			MR. WEINBERG: That's a different issue than

7		who's a Custodian of Records.

8		Q. Who was their Custodian of Records prior you to

9	guys	accepting service?

10		A. I don't know. I don't.

11			MR. CROW: Well, are you a

12		Custodian of Records?

13			THE WITNESS: Yes.

14			MR. CROW: What does that mean?

15			THE WITNESS: That means specifically in

16		regard to this case to search for and obtain different

17		documents with regards to this matter and safeguard

18		them.

19			MR. CROW: On a daily basis, do you have any

20		control over the records in the Church? I mean, do you

21		maintain them?

22			THE WITNESS: These, yes.

23			MR. CROW: I'm talking about the records

24		generally.


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1			MR. CROW: So did you personally seize these

2		records?

3			MR. WEINBERG: Seize?

4			MR. CROW: Or get them, whatever term you

5		like.

6			THE WITNESS: Yes, I got them.

7			MR. FUGATE: So -- so we don't waste a lot of

8		time and there's not any misunderstandings here, and if

9		you want -- if you want to ask him, fine.

10			We basically, after some discussions, decided

11		there had to be somebody designated that you guys could

12		talk to as a Custodian of Records, who would actually

13		take custody of the records and also would do a

14		documented, that is, a written documented search for

15		the records that were being subpoenaed. And

16		unfortunately, I guess poor Mr. Steilo, he was selected

17		as the person. And he can go through with you all what

18		he did from that point on to get the records.

19			The short answer to where you're going, I

20		think, is that he doesn't -- he's not a

21		Custodian of Records, records don't flow through him in

22		the normal course of Church business, to my knowledge.

23		He's designated for this case for the specific purpose

24		of you folks having somebody that you can talk to and

25		ask questions about how the search is conducted, where

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1		it's conducted, who was contacted, and what he got as a

2		result of it.

3			MR. WEINBERG: And what he didn't get. There

4		is -- Doug, there is no position in most corporations

5		of Custodian of Records. There's presidents and

6		there's secretaries and there's vice-presidents, but

7		there's no such thing --

8			MR. CROW: I don't want a lecture on

9		corporation --

10			MR. WEINBERG: I understand.

11			There's no such thing. No one gets hired to

12		be a Custodian of Records.

13			You have served a subpoena on the corporation

14		asking for the production of documents, and -- and just

15		as you've done in many other cases. And corporations

16		decide who it designates, and it can designate anybody

17		to be the custodian. And we had -- the Church has

18		designated Mr. Steilo for purposes of this subpoena to

19		be the Custodian of Records, which -- and he can tell

20		what he did, you know, what he's still doing.

21			MR. McGARRY: I think it would be important

22		for us to find out though who the records custodian is.


24		Q. Is there a records custodian in the Church, can

25	you answer that, prior to you?

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1		A. There's -- no, sir, I don't believe there's one

2	individual that, as Sandy and Lee were describing, that all

3	the files or records flow through. The -- the Church is

4	organized into different departments and, well,. files and

5	records can be obtained or searched for in different -- you

6	know, in those different departments. And there are

7	individuals who are responsible for those records in those

8	departments, but ...

9		Q. What did you do between December and April?

10		A. December and April?

11			MR. WEINBERG: With regard to what, Mark?

12			MR. McGARRY: This case. The whole purpose

13		of him being here --

14			MR. WEINBERG: We would object to that.

15		You're asking him for privileged information, work

16		product. He's already told you he worked with the

17		lawyers. We're not going to allow him to describe to

18		you what he did in working with us because that's

19		privileged. If you ask him what he did with regard to

20		production of documents --

21			MR. McGARRY: That's what I did. I asked him

22		what he did between December and April.

23			MR. WEINBERG: I'm saying we're objecting to

24		that question, you're calling for privileged

25		information and work product. What he did, he was

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1		working with us. You can't ask me what I did

2		between -- between December and April as to this case.

3			MR. CROW: We're not -- we're not necessarily

4		asking you, but you designated him as a witness and

5		we're asking him. If he doesn't want to answer, he

6		doesn't want to answer.

7			MR. WEINBERG: That's an objection. I'm

8		instructing him not to answer that. If the question is

9		what did he do with regard to the collection and

10		production of documents, he's here to answer those

11		questions.

12			MR. CROW: Okay. Well, let's start out with,

13		what did you do between December and April?

14			MR. WEINBERG: Objection, privileged, work

15		product. Instruct you not to answer.

16			MR. CROW: Okay. Is everything you did

17		between December and April privileged?

18			MR. WEINBERG: Objection, work product,

19		privileged. Instruct you not to answer.

20			And, you know, what --

21			MR. CROW: How can that --

22			MR. WEINBERG: Look, that's my objection.

23		Ask him a specific question as to what he was called

24		here to testify about. He was called here, as the

25		subpoena says, as records custodian with regard to

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1		production of documents.

2			MR. CROW: You designated him a custodian.

3		That's what you told us his function was.

4			MR. WEINBERG: That's what he is.

5			MR. CROW: I want to know what he was doing

6		in -- in regards to the McPherson matter --

7			MR. WEINBERG: And I told you that is

8		privileged, work product.

9			MR. CROW: I just asked him if everything he

10		did was privileged and that --

11			MR. WEINBERG: That calls for a legal

12		conclusion. And he's not going to answer that

13		question, Doug.

14			MR. CROW: Okay. You're refusing to answer

15		that question?

16			MR. WEINBERG: I'm instructing him not to

17		answer the question.

18			MR. CROW: He still has to say yes or no,

19		he's following your advice.

20			MR. WEINBERG:		Okay.

21			THE WITNESS: Yes, I'm following

22		Mr. Weinberg's advice.

23			MR. CROW: Okay. And so you won't answer the

24		question of whether everything you did between December

25		and April is privileged?

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1			THE WITNESS: I was working for them, and if

2		that was privileged --

3			MR. CROW: Did you have any other functions

4		other than working for the lawyers?


6			MR. CROW: Okay.


8		Q. What were those?

9		A. To ensure that Church legal matters, Church

10	internal matters were done concurrent with laws.

11		Q. The laws of the Church?

12		A. Laws of -- no, no. The State of Florida,

13	United States. For instance, I'm a specialist in

14	immigration law. And we have to ensure that everyone who

15	comes to the United States has a proper Visa, so I supervise

16	an individual who ensures that that occurs.

17		Q. All right. Let's go through it this way: Did you

18	have an explanation for us that you were going to give us as

19	to why these subpoenas weren't complied with?

20			MR. WEINBERG: Excuse me. They are complied

21		with. You've asked us to produce documents and we've

22		produced --

23			MR. CROW: Why don't you let him answer the

24		question.

25			MR. WEINBERG:	I'm objecting to the question,

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1		to the form of the question.

2			MR. CROW: No, you're answering the question

3		for him. If it's --

4			MR. WEINBERG: No. Mark, we're not here to

5		argue with you.

6			MR. CROW: It sounds like you are.

7			MR. WEINBERG: Mark has said we're not

8		complying with the subpoenas. We are complying with

9		the subpoenas. We have produced what we have found.

10		He's here to explain to you what the process is.

11			MR. CROW: He's capable of saying that.

12			MR. WEINBERG: But I object to the question.


14		Q. Do you have an explanation, a set explanation that

15	you came here to sit down and tell us about why there are

16	certain documents that we think exist that do not exist? Do

17	you have an explanation for that?

18		A. Yes.

19			MR. McGARRY:	Is that worded properly?

20		Q. Let's just start with that, and then we'll move

21	from there.

22		A. Well, when I became the Custodian of Records, I

23	was -- I caused a search to be done in various locations in

24	the United States where we thought logically those records

25	would be. That's Dallas, Texas, Los Angeles, California,

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1	and Clearwater, Florida. And I -- well, I selected

2	individuals within the Church, in the various departments

3	where those records would logically be located and where --

4	and then we made a determination, well, then if they're not

5	logically there, where could they possibly have gone. And

6	we selected individuals based on their positions within the

7	Church in their departments.

8		   And with Miss Vaughn I wrote instructions to these

9	individuals and I --

10			MR. WEINBERG:	For the record, that's

11		Laura Vaughn of Zuckerman, Spaeder, Taylor & Evans.

12		A. We wrote instructions to each individual and then

13	I delivered those instructions to those individuals. And I

14	told them in no uncertain terms that this was a -very serious

15	matter. There's a briefing -- in the written briefing

16	itself there's a description -- a brief description of the

17	McPherson matter. And they were given a certain time to get

18	back with me, to cause a search. And we have copies of it

19	here. You can -- you can have it.

20		Q. Okay. I'd like to know the names of the

21	individuals, the departments they were in and the cities

22	that they live in.

23			MR. WEINBERG: We can give you -- it's pretty

24		voluminous. We'll give you copies of all of the memos

25		that were circulated and the responses back from the

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1		people.

2			MR. McGARRY: All right.

3			MR. WEINBERG: We have that copy here?

4			MR. FUGATE: Yes.

5		Q. So you're going to provide us with the information

6	that you did as far as the requests that you made and the

7	various departments where the recordkeeping was?

8		A. Yes, sir.

9		Q. Now, would you consider yourself knowledgeable in

10 	the areas of recordkeeping in Clearwater, even though you've

11 	only been here six months?

12		A. To this task, yes.

13		Q. Okay. So you can explain to us all the various

14	folders and all the various files and the buildings that

15	they're kept in, the purpose they keep them, the routing as

16	far as the paperwork is concerned?

17		A. Yes, I -- I think to the best of my ability, yes.

18		Q. Well, I would think that would be the crux of

19	our -- our investigation here, is that you followed the

20	paper trail all these documents went on. Did you do that?

21		A. Let's see. What I did was, I told the individuals

22	themselves to do their searches. In other words, I didn't

23	do the search myself. Or, well, you can take a look at what

24	they -- what I instructed them to do and how they did it and

25	their answers right here.

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1		Q. You did this by memorandum form?

2		A. Yes.

3		Q. Not face-to-face?

4		A. In most cases, no, because, you know, Dallas,

5	Texas, and Los Angeles, I couldn't.

6		Q. All right. So it is your belief -- let's go

7	through this. It's your belief that some of these

8	documents, these caretaker notes, somehow ended up in Dallas

9	or L.A.?

10		A. I couldn't say that. It's my belief that -- yes,

11	you could say that, it could have, it's a possibility.

12		Q. This is kind of frustrating, because it's hard for

13	me to follow the paths of paper.

14		   Why would they possibly end up in L.A. and Dallas

15	when their reference is Lisa McPherson's care? And it's my

16	understanding, talking to caretakers, they were referenced

17	to Mr. Kartuzinski and, after him, various file folders.

18	Are you telling me now those various file folders,

19	including pieces of paper that somehow got separated from

20	those file folders, ended up in L.A. or Dallas, Texas?

21  			MR. WEINBERG:	Why don't you explain to

22		Mr. McGarry what you have -- what you have learned as

23		to the transfer of some of the documents to L.A.

24		A. Meaning -- well, when this incident occurred --

25	let me see if I can answer your question this way: When the

		KANABAY COURT REPORTERS - (813) 821-3320


1	incident occurred, her -- her, what do you call it, her PC

2	folders, her -- you know, the folders that -- her religious

3	folders, confessional form, I guess we call them, those were

4	transferred to Los Angeles to, actually, the property of the

5	Church.	And that's one example of -- of a transfer of

6	information. I know that -- let's see.	There were various

7	executives -- not executives. I just had indications

8	that -- that reports had gone out there.

9		   So I figured -- again, I was looking for any way

10	or anywhere these things could possibly have gone. I knew

11	she was a parishioner of the Church in Dallas, I knew she

12	was communicating to people in Dallas, I knew she was

13	communicating to friends in the local area. You know what I	    

14	mean? And --

15		Q. Let's get down --

16		A. It's been a year or two after the incident. So I

17	wasn't quite sure where they could have gone. I knew or I'd

18	been told that, well, he wants to document the search and

19	make it as -- as -- as clear as possible we've done

20	everything we could. So that's what my interest in doing

21	all of that was.

22		Q. All right. Let's -- let's get down to basics,

23	okay, Mr. Steilo? Did you follow this paper trail? Did you

24	follow the paper trail person by person where these

25	documents went to? Did you do that?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. Did I personally, no.

2		Q. Did somebody?

3		A. Yes.

4		Q. Who?

5		A. In Dallas, Texas, a person by the name --

6		Q. Let's start in Clearwater, from the writer's

7	hand --

8		A. In Clearwater?

9		Q. -- where the documents went. Did you follow that

10	paper trail?

11			MR. WEINBERG: Excuse me for a second. What

12		is the question, what document --

13			MR. McGARRY:	I'm asking him who followed the

14		paper trail of the missing documents, the missing

15		documents of caretakers' notes.	My question is --

16			MR. CROW: Why don't you see if he

17		understands the question before you object.

18			MR. WEINBERG: Let me just make a statement.

19			MR. CROW: We aren't here for you to make a

20		statement.

21			MR. WEINBERG: He is here as a records

22		custodian to tell you what he did to attempt to locate

23		documents.

24			MR. McGARRY: And I'm asking him questions in

25		reference to his search.

		KANABAY COURT REPORTERS - (813) 821-3320


1 			MR. WEINBERG: Fine.

2			MR. McGARRY: It's as clear as it can be.

3			MR. WEINBERG: That's what he's trying to

4  		answer.

5			MR. McGARRY: Let him answer.

6			MR. WEINBERG: Let me tell you, he's been

7 		trying --

8			MR. McGARRY: He hasn't, because you

9		interrupted.	   

10			MR. WEINBERG: No, you're not giving him an

11		opportunity.

12			MR. CROW: We're not stopping him.

13			MR. WEINBERG: I'm telling you, let him

14		explain what he did first.

15			MR. McGARRY: I am. And my question is, he

16		didn't do it, and he's going to tell me who did it.


18		Q. Who was the person that followed the paper, trail

19	from the writer's hand?

20			MR. WEINBERG:	The individuals themselves?

21		Q. Who followed the paper trail from the persons that

22	wrote these papers, the reports, all these caretakers,

23	there's 20 of them, who followed the paper trail from when

24	it left their hand and can you tell me where that paper

25 	routed?

		KANABAY COURT REPORTERS - (813) 821-3320


1		   We have a lot of them, so you know what route they

2	went through, at least you know some of them.

3		A. Right.,

4		Q. Who followed it up?

5		A. I guess it would be the attorneys or the

6	individuals themselves.

7		   You're talking -- let me -- let me -- let me say

8	something here. You're talking about the individuals, the

9	caretakers themselves?

10		Q. Right.

11		A. They were represented by Church counsel.

12		Q. Yeah.

13		A. And those -- those individuals made statements or

14	told their counsel what was missing and they gave -- those

15	individuals gave what they had to their counsel, right?

16		   Now, what I did was, I went and -- let's just

17	say -- in some of these individual cases they didn't know

18	where -- where the reports had gone after they gave them to

19	somebody or something. And what I was looking for was the

20	most logical places where they would be.

21		Q. Okay.

22		A. Okay?

23		Q. Let me stop you. Let me ask you some questions

24	here along the same lines. .

25		   Did you ever talk to -- did you ever talk to

		KANABAY COURT REPORTERS - (813) 821-3320


1	Arthur Baxter personally?

2		A. Personally, yes.

3		Q. You did?

4		A. Yes.

5		Q. About this case?

6		A. No.

7  		Q. Not about this case?

8  		A. No. No.

9  		Q. Did you ever talk to Paul Kellerhaus?

10 		A. Yes.

11 		Q. Okay. About this case?

12 		A. Yes.

13 		Q. About these documents?

14 		A. Yes.

15 		Q. Okay. There's a good start there.

16		A. Okay.

17		Q. How about Marcus Quirine, did you talk to him?

18		A. No.

19		Q. You didn't talk to him?

20		A. No.

21		Q. How about Paul Greenwood, did you talk to him?

22		A. No.

23		Q. Janice Johnson?

24		A. No.

25		Q. Okay. How-about any of these caretakers right

		KANABAY COURT REPORTERS - (813) 821-3320


1	here that I have listed on this cover letter that you looked

2	at, I've got them broken down individually here, but they're

3	the same ones in the subpoena, Sam Ghiora, Teresa Cezare,

4	Alice Vangrondelle, Rita Boykin, Patrizia Strecencer,

5	Valerie Demange, Sylvia DelaVega, Heather Petzoid,

6	Barbro Wennberg, Emma Schamehorn, Joan Stevens, did you talk

7	to any of those individuals?

8		A. Yes.

9		Q. Okay. Which ones?

10 		A. Let's see. Alice Vangrondelle. Emma Schamehorn.

11	Joan Stevens. Let me just think. And Barbro Wennberg.

12		Q. And the subject of those conversations was what?

13		A. The -- the dispatches that I had written to them

14	and the records search.

15		Q. Okay. This wasn't in a face-to-face oral

16	conversation, this was a dispatch by them, did	you mean?

17		A. Oh, no, no. This was face-to-face. I did both.

18	I handed them the dispatch and I also spoke to them

19	face-to-face, just as we're doing here.

20		Q. Church policy, written correspondence is much

21	preferred over oral correspondence, is that kind of a

22	Hubbard philosophy?

23		A. Well, yes.

24		Q. And I assume that your conversations with these

25	people that you've mentioned on this list right here, they

		KANABAY COURT REPORTERS - (813) 821-3320


1	pertain to the subject matter of their written records? Did

2	you cover that area?

3		A. Yes.

4		Q. Okay. And did you ask them in the course of that

5	conversation what they did with their written records that

6	they had taken in their -- in their watches with

7	Lisa McPherson during their two-week period there?

8		A. Let me see. Let me just think now.

9		   Yes, I did.

10		Q. Well, I would think it would be important to

11	follow up where they said they put the records.

12		   Either they gave it to security guard, correct?

13		A. Right.

14		Q. Or they put it in the basket around the corner,

15 	correct?

16		A. Correct.

17		Q. And did you find out that's where those records

18	went, one of those two places?

19		A. Yes, that's what --

20		Q. You did?

21		A. Yeah.

22		Q. So you know which one, which security guard, which

23	basket. Give me -- I'm trying to dig this out of you now.

24		A. You see, I wasn't there. And what they told me --

25		Q. I know, but --

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. Let's just take Miss Wennberg. She said, Yeah,

2	look, I've already -- I've -- I've searched for these

3	things, I don't know where they've gone. And I said, Okay,

4	well, where do you think they've gone? I have no idea.

5		Q. Okay. Mr. Steilo, you understand the way this was

6	working here. These people, once they divested themselves,

7	which is immediately after they wrote the memorandum or

8	wrote the -- the log of what they observed on

9	Lisa McPherson's watch, once that left their hand, none of

10	these people ever saw their -- their paper again. They

11	didn't keep copies. I think one might have indicated they

12	kept a copy.

13			MR. WEINBERG:	You're telling him this is

14		what they said in their testimony?

15			MR. McGARRY: Yes. I assume --

16			MR. WEINBERG: Excuse me for a second. If

17		you're asking what his understanding of the facts are,

18		that would come from us. All right? So --

19			MR. McGARRY: I assume what they're telling

20		me is what they're telling him, Sandy, if you just let

21		me finish.

22			MR. WEINBERG: Okay.

23		Q. Did they tell you that?

24		A. Yes, actually.

25		Q. They did?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. They didn't -- they didn't say anything, I

2	believe, to be inconsistent. But I don't know -- I don't

3	really know, you know, what they --

4		Q. My question is, did anybody say they kept the

5	records themselves?

6		A. No.

7		Q. They gave the records up to somebody?

8		A. Yes.

9		Q. That's what I'm asking you.

10		A. Yes.

11		Q. All of them did, right?

12		A. Yes.

13		Q. They gave the records to somebody?

14		A. Yes.

15		Q. A security guard?

16		A. Yes.

17		Q. A runner?

18		A. Yes.

19		Q. You know who Lacy Spencer is?

20		A. Yes.

21		Q. She's a runner for Alain Kartuzinski at the time,

22 	correct?

23		A. Yes.

24		Q. Did you interview her?

25		A. Okay, no.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. And there's a basket around the corner too for

2	communication purposes at the Church? As a matter of fact,

3	there's baskets all over the Church, but there was one --

4		A. Exactly.

5		Q. Okay. But you determined there was one around the

6	corner in the laundry room from where Lisa was staying that

7	was used as a receptacle for some of these documents? Did

8	you find that out?

9		A. Yes.

10		Q. So now we know that either Lacy or the security

11	people transferred these memorandums to somebody. Did you

12	find out who that person was?

13		A. No.

14		Q. You don't know where they went?

15		A. No.

16		Q. You have no idea in the Church's routing of these

17	documents where they were routed to go, what the purpose of

18	them was, who was --

19		A. I know what they told me or what I've seen, but --

20		Q. That's what I'm asking you, Mr. Steilo. Can

21	you --

22 			MR. WEINBERG: He's not a fact witness. I

23		mean, you're asking --

24			MR. McGARRY: Sandy, I'm trying to get --

25			MR. CROW: We can ask him facts.

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. McGARRY: Did he do it? He can say he

2		did do it or he doesn't know.

3			MR. WEINBERG: Fine. What he's trying to do

4		is explain to you the process he went.through to locate

5		documents. What you're asking him is to re-create what

6		happened a year ago. He's not here for that purpose.

7			MR. CROW: We're asking him the questions we

8		want to ask about what he's supposed to do, and you

9		don't dictate what questions we're going to ask.

10			MR. WEINBERG: No, I'm going to dictate in

11		the sense if you're asking him to repeat what he's been

12		told by his lawyers, what people have said --

13			MR. McGARRY: I'm not asking what lawyers

14		have told him.

15			MR. WEINBERG: That's where his information

16		comes from.

17			MR. CROW: If you have set this up so you've

18		got a custodian you're trying to insulate, I'll tell

19		you we've got documents, sworn testimony they were

20		created, we subpoenaed them, we got indications from

21		you they were privileged and we weren't going to get

22		them, and now we're told that they're not available,

23		I'm going --

24			MR. WEINBERG: Doug, you can sit here and

25		make every accusation you want to make.

		KANABAY COURT REPORTERS - (813) 821-3320


1  			MR. CROW: I'm not finished. I'm not

2 		finished.

3			MR. WEINBERG: Fine. Finish. I'll have a

4		statement to make.

5  			MR. CROW: Fine. One at a time.

6  			MR. WEINBERG: Fine.

7  			MR. CROW: And if you're trying to insulate

8		the destruction or loss of records by -- by

9		communications, if you've given us a witness, you say

10		he can explain everything about the documents, and then

11		every time we ask a question you say no, that's

12		privileged because he learned from us, well, you

13		shouldn't have listed him as a custodian then.

14			MR. WEINBERG: Okay. Now can I -- can I

15		speak to that? Just so we don't have an argument about

16		this.

17			A custodian --

18			MR. CROW: Sounds like we already have an

19		argument.

20			MR. WEINBERG: A Custodian of Records is not

21		a person that comes in and repeats what -- what every

22		fact witness would say. A Custodian of Records is a

23		person that has custody of documents and has taken the

24		responsibility of trying to find them. Which at this

25		point in this deposition he'll be able to explain what

		KANABAY COURT REPORTERS - (813) 821-3320


1		he did, what exists, what doesn't, that they've been

2		able to determine.

3			There are numerous people, most of which you

4		have already subpoenaed, that are people that can

5		answer the questions that you're talking about. You

6		bring in Mr. -- bring in Mr. Kellerhaus and ask him the

7		question you didn't ask him before. Ask him what did

8		he do with the documents when he had them. You bring

9		in people from -- from the Office of Special Affairs

10		that Mr. Kellerhaus has said that indicated that he --

11		he may have given documents to. You bring them in, you

12		ask those questions. But you don't ask this witness,

13		who wasn't there, those questions.

14			He was here -- he was here to -- to respond

15		to your subpoena and to produce what documents he could

16		locate, which is what he's doing. But you haven't

17		given him an opportunity to -- to even explain what the

18		process was, what they went through.

19			MR. McGARRY: That's what I did before. I

20		asked him specific questions, sandy.

21			MR. WEINBERG: But he hasn't been able to --

22			MR. CROW: First of all, you've been doing

23		the talking rather than him, okay?

24			MR. McGARRY: That's not my fault, Sandy,

25		because you haven't --

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. CROW: Secondly, you purported this

2		person had done a search --

3			MR. WEINBERG: He has.

4			MR. CROW: Our idea of a search is obviously

5		quite different from yours. We're not satisfied if

6		someone said, okay, send me the records and that's it.

7		We want to know, did you check with this person, how

8		many people, did you ask about the existence of

9		records, how many people, did you ask where they were,

10		and that's exactly what Mark's doing.

11			MR. WEINBERG: What you haven't allowed him

12		to do, he sent memos to how many people, to dozens of

13		people, including these that you're asking him about.

14			MR. McGARRY: I'm asking him about those.

15			MR. WEINBERG: He got responses back from

16		people. That's what's documented here. What you're

17		asking, who did he have -- I mean, if the requirement

18		is that he has to have a personal conversation --

19			MR. CROW: No, but we have the right to

20		distinguish between the two.

21			MR. WEINBERG: I understand.

22			MR. CROW: And we're going to ask the

23		questions that way, and we will ask the questions.

24			MR. WEINBERG: That's fine. But he's not

25		being obstructive and we're not being obstructive.

		KANABAY COURT REPORTERS - (813) 821-3320


1		You're making it sound somehow that -- that we're

2		trying to mislead you. He's not trying to mislead,

3		he's trying to explain to you what he did.

4			MR. CROW: I'm making it sound like you're

5		doing all the talking and not letting him answer.

6			MR. WEINBERG: You're doing a lot of talking

7		too.

8			MR. McGARRY: May I continue?

9			MR. WEINBERG: Yes.	__


11		say he's not being obstructive, but everyone involved

12		in the Church knows people don't keep their reports and

13		he's sitting there saying they kept their reports.

14			MR. WEINBERG: If you want to testify now,

15		get under oath.

16			MR. FUGATE: Wait a minute. Let me see --


18			MR. FUGATE: Let me see if we can get back on

19		track a second.

20			I don't know what questions you want to ask.

21		We've got an idea what they are. What we're trying to

22		do is to provide a witness to get you to witnesses you

23		may want to talk to.

24			MR. McGARRY: I thought this was the guy.

25			MR. FUGATE: What I'm telling you, we're

		KANABAY COURT REPORTERS - (813) 821-3320


1		giving you the guy that has conducted. the, documented

2		search to get you to where all the things were. We

3		picked somebody because we don't know all the Church

4		terminology, we don't know how they keep their records.

5		We've gotten documentation of what he's done in the

6		search.

7			MR. McGARRY: So you know where we're

8		going --

9			MR. FUGATE: I can't re-create --,

10			MR. McGARRY: -- I'm going to ask very.

11		pointed questions about his investigation.

12			MR. WEINBERG: Fine.

13			MR. McGARRY: If it wasn't thorough, that may

14		come out. If it was thorough, hopefully that will come

15		out for you guys.

16			MR. WEINBERG: It was thorough.

17			MR. McGARRY: Why can't I ask these

18		questions?

19			MR. WEINBERG: You can.

20			MR. McGARRY: You don't like them.

21			MR. WEINBERG: No. If you'd give him an

22		opportunity to respond to your questions, to explain

23		what he did --

24			MR. McGARRY: Sandy, I have not cut him off

25		once, you have.

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. WEINBERG. Okay. Go ahead. It's what

2		you've asked him.	      

3			MR. McGARRY: You don't like it.

4			MR. WEINBERG: Because you're asking him for

5		information that I believe to be privileged.

6			MR. McGARRY: That's all he has. He

7		didn't -- he wasn't here when Lisa died. All he gets

8		is information from these other people. That's all I

9		can ask him, correct?

10			MR. WEINBERG: Look, why don't you try again

11		and -- and hopefully it will work out, okay?


13		Q. Mr. Steilo, where were we, Lacy Spencer?

14		A. Yes.

15		Q. Did you interview her?

16		A. No.

17		Q. Okay. Did you become aware during your

18	investigation of this paper trail that she was a runner?

19		A. Yes..

20		Q. Okay. Did you become aware that she allegedly

21	handled many of these documents from these women that were

22	looking after Lisa McPherson?

23		A. Yes.

24		Q. Okay. So you gained that information?

25		A. Yes.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. Who did you gain that information from?

2		A. I think I got that from -- actually, from a

3	report. Let's see. It was from -- I'm just trying to think

4	now. It was -- where did I get that information? It's

5	unclear. Actually, it's unclear.

6		Q. Okay. Did you send her a memo and ask her about

7	her involvement in the paper trail of these documents?

8		A. No, not her.	I could explain why.

9		Q. Do you know where she took those documents when

10	she picked them up from the caretakers and/or the basket

11	that was located outside of Lisa McPherson's room?

12		A. Yes.

13		Q. Where was that?

14		A. They went to the -- the Senior CS Office.

15		Q. And who is that?

16		A. That at the particular time was Alain Kartuzinski.

17		Q. Did you talk to Mr. Kartuzinski about that?

18		A. No.

19		Q. Did you send him a memorandum about what he did

20	with the documents after he read them?

21		A. Not him personally, no. It went to the people who

22	actually are in that office now and who would logically

23	still have those records if they existed.

24		Q. So that was maybe his assistant or somebody that

25	worked as a secretary?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. A replacement.

2			MR. CROW: Did you eliminate the possibility

3		he might be in personal possession of some of the

4		documents?

5			THE WITNESS: I assumed that had already been

6		done.

7			MR. CROW: So you did not?

8			THE WITNESS: I did not, no.

9			MR. CROW: Okay.

10			MR. FUGATE: Can I conference with him.

11			(The witness and his counsel confer.)

12			THE WITNESS: Well, it's -- just in relation

13		to that, I knew that his counsel, his representation,

14		had -- had seen these subpoenas, they know what you're

15		looking for. And I would assume that that had already

16		been taken care of.

17			MR. CROW: I don't believe he was subpoenaed.

18		Did we subpoena him?

19			MR. McGARRY: No.

20			MR. FUGATE: For the record, he knows that

21		they were given, each of the lawyers that represent the

22		people were given copies of subpoenas since they're

23		represented by counsel at our request, which was to

24		produce anything to him of a document nature and --

25		well, you can ask him whether there were any- documents

		KANABAY COURT REPORTERS - (813) 821-3320


1		produced or not.

2			MR. CROW: I don't follow you. Maybe --

3			MR. FUGATE: The State Attorney subpoenas you

4		guys sent, each and every one of them have been

5		reproduced and given to the lawyers for the

6		individuals, so he's not contacting the individuals.


8		Q. Are you done with your answer?

9		A. Yes.

10 		Q. All right. Did you follow-up on where these

11	memorandums and these documents and these notes went from

12	Alain Kartuzinski's office?

13		A. Yes, sir. Yes.

14		Q. Where did they go?

15		A. Well, I'm not sure. Okay, what I did, when I

16	contacted the individuals that work in the office, I had

17	them look in every place that -- in that office --

18		Q. Let me cut you short because you were kind of

19	heading off.

20		When I say where did they go, we're referring to

21	these missing ones. Obviously we don't know where they went

22	or you didn't know where they went?

23		A. I did not, no.

24		Q. Where did the bulk of them go which I've been

25 	provided?

		KANABAY COURT REPORTERS - (813) 821-3320


1 			MR. WEINBERG: Where did they come from?

2		Q. Where did they go from Mr. Kartuzinski, these

3	documents right here that are on the Internet now? These,

4	have you seen these? These are the ones --

5    			MR. WEINBERG: They're produced.

6		Q. -- that have been produced.

7      		A. Yes, those are the ones we produced.

8			MR. WEINBERG: Do you know where they were

9		located?

10		A. I don't -- I don't understand the question.

11		Q. The question is, Mr. Kartuzinski read all those

12	documents, that they were provided to him by either the

13	security guard or Lacy Spencer, correct?

14		A. I don't know --

15			MR. WEINBERG:	He read them?

16		A. -- that he read that them, but he obviously --

17	well, I don't even know if he got them.

18		Q. You don't know if

19		A. They're addressed to him.

20		Q. My question is: He's testified, Kartuzinski, he

21	was getting these, they were going to him first; is that

22	correct?

23		A. Yeah. Well, this one was. This one says

24	Senior CS.

25		Q. Right. A lot of them do.

		KANABAY COURT REPORTERS - (813) 821-3320


1		   My question is simple enough. We have these.

2		A. Uh-huh.

3		Q. Where did these go after him?

4		A. I don't know.

5		Q. You did not follow up on where -- where these

6	records -- how they ended up getting to us, I mean the

7	normal course? You would think that you'd check where the

8	normal course of these records went so you could find the

9	lost ones.

10			MR. WEINBERG: Are you asking him where they

11		were located, is that what you're asking?

12		Q. I want to know if somebody knows in that building

13	where Alain Kartuzinski's mail goes when he puts it in his

14	basket. And these were going, apparently, out of there to,

15	I assume, Lisa's folders. Now, I don't know which folder,

16	Ethics, PC.

17		A. That's true. I don't know what he did with them,

18	no. All I know is we have them.

19		Q. Yeah.

20		A. And that's what I'm supposed to produce.

21		Q. Do we know how we got these? Do you know that?

22		A. No.

23		Q. Who knows that? Who knows the answer to that?

24		A. I don't know.

25		Q. Do the lawyers know that?

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. WEINBERG:	Excuse me for a second.

2			(The witness and his counsel confer.)

3			MR. WEINBERG:	I'll represent for the record

4		that I believe that those documents were located, the

5		bulk of those reports were located in Los Angeles. If

6		I could just -- let me just read the -- were located in

7		the PC folder of --

8			MR. CROW: Lisa McPherson?

9			MR. WEINBERG:	-- Lisa McPherson in

10		Los Angeles.

11			MR. CROW: By whom?

12			MR. WEINBERG:	At the -- at the time of the

13		first subpoena that was served early in the --early in

14		the case. Before Mr. Steilo became the records

15		custodian, we caused a -- you know, we went to our

16		client and caused our client to make a search for

17		documents.

18			MR. CROW: Your client's an entity.

19			MR. WEINBERG: Our client is a -- is a

20		corporation or a series of corporations. We caused it

21		to make a search for documents and --

22			MR. McGARRY: This is in February?

23			MR. WEINBERG: This is whatever the month is.

24			MR. McGARRY: That subpoena went out in

25		February.

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. WEINBERG: February or March.

2			And the bulk of these documents were located,

3		I believe, in the PC folder of Lisa McPherson that --

4		that had been sent out to L.A. at that point -- period

5		before.	And there are witnesses that you have

6		interviewed that -- that, if you ask the question, can

7		give you the specific answer as to approximately when

8		the PC folder was sent out.

9			MR. McGARRY: This may --

10			MR. WEINBERG: But what I'm trying to say, we

11		are not trying to argue with you. He is not here

12		because -- he's not a fact witness. If -- if what you

13		want is a witness to say what -- when did the PC folder

14		get sent to L.A., there are people, most of which you

15		have interviewed, that can -- that can testify as to

16		when approximately the PC folder was sent to L.A. It

17		was a long time ago.

18			MR. McGARRY: I'm beginning to think you are

19		the person that should be subpoenaed, Sandy.

20			MR. WEINBERG: I'm not a witness. No, I'm

21		not a witness.

22			MR. CROW: Who did the search to find those

23		initial documents? We thought he did both of them.

24		Obviously, he didn't.

25			Who did the search to find the --

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. WEINBERG: What he has done --

2			MR. CROW: Who did the search to find the

3		first records? Obviously that's somebody we need to

4		subpoena.

5			MR. WEINBERG: We can provide a name. I

6		don't have the answer to the question as to who

7		actually --

8			MR. CROW: He doesn't know either?

9			MR. WEINBERG: Apparently not. But he has

10		done a second search, okay? He has done a second

11		search, a comprehensive search, that he can explain to

12		you, in three different locations, asking for not just

13		these documents, but every document that you have

14		requested up to now, a comprehensive search, which is

15		what you --

16			MR. CROW: Let me understand --

17			MR. McGARRY: This is getting out of control.

18		Let me go ahead. Let me finish up. I had a lot of

19		questions. If he doesn't know the answer, fine. Let's

20		just plug on, because it's getting late.

21			Can we go ahead?

22			MR. WEINBERG: 	Yeah.

23			Let me just ask him a question just to

24		clarify something.

25			(The witness and his counsel confer.)

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. Well, a lot of these -- and some of these things

2	were actually collected by myself earlier, okay, at the

3	behest of -- of Mr. Abelson. And then when Sandy and Lee

4	came on-board, Laura Vaughn, I was also working for them in

5	collecting documents in answer to the subpoenas.

6		Q. Back in February?

7		A. Yes.

8		Q. Okay. Well, that's what I'm asking.

9		A. Okay.

10		Q. You did that then?

11		A. Yes.

12		Q. And was that these documents here that I just

13	showed you?

14		A. Yes. Some of them, yes.

15		Q. These are caretakers' notes.

16		A. Yes.

17		Q. We can categorize them. These are all caretakers'

18	notes.

19		A. Right.

20		Q. Are those the ones you found?

21		A. I believe so, yes. I'm sorry, I'm a bit vague

22	because --

23.		Q. Are there others?

24		A. What's that? I'm sorry.

25		Q. These caretakers' notes, these are the ones you

		KANABAY COURT REPORTERS - (813) 821-3320


1	found?

2		A. Yes.

3		Q. All of them?

4		A. Yes.	Let's just say that.

5		Q. And you found those when --

6 	    		MR. FUGATE: Wait a minute.

7	    		THE WITNESS: I'm being confused.

8 		    	MR. FUGATE: I know you are.

9	    		(The witness and his counsel confer.)

10		A. Okay. In relation to those, to those specific

11	reports, they did come from Los Angeles.

12		Q. All right. Did you investigate who sent them to

13	Los Angeles?

14		A. No.

15		Q. Do you know who did send them to L.A.?

16		A. No.

17		Q. Do you know why they were sent to L.A.?

18		A. They were part of the person's PC folder.

19		Q. Okay.

20		A. And those folders belong to the Church of

21	Scientology International, so it's logical --

22		Q. Are you well-versed in the protocol for documents

23	in the Church? You must be, obviously, you're assigned to

24	this case.

25		A. Yes. Yes.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. Would you say you're -- would you say you're an

2	expert in Church protocol for documents and routing? Would

3	you say there's anybody --

4		A. I would say yes.

5		Q. Would you say there's anybody out there in

6	Clearwater that knows more than you --

7		A. No.

8		Q. -- about how the Church functions in routing

9	paper?

10		A. No.

11		Q. You're the guy?

12		A. Yeah.

13		Q. Okay. Do you know why -- are all people's

14	documents, PC folders sent to L.A. from Clearwater?

15		A. I don't know.

16		Q. You don't know the answer to that?

17		A. No.

18		Q. Who does?

19		A. I don't know.

20		Q. Okay. You don't know why they were sent to L.A.?

21		A. No.

22		Q. Do you know who had them in L.A.?

23		A. Yes.

24		Q. Who?

25		A. Mr. Ken Long.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. Who is he?

2		A. He is a Staff member of the Church of Scientology

3 	International.

4		Q. Okay.

5		A. Office of Special Affairs.

6		Q. Do you know why he had them?

7		A. Well, he's a deputy that works in CSI.

8		Q. What is CSI?

9		A. Church of Scientology International.

10		Q. Okay.

1l		A. Why he had them, because he's -- well, I don't

12	know, actually, I never asked him. I know the folders go

13	there and I know he had them.

14		Q. What folders go there, everybody's folder?

15		A. McPherson's.

16		Q. Everybody's folders?

17		A. No.

18		Q. Just McPherson's?.

19		A. Yes.

20		Q. So he showed some interest in this folder.

21	Did he order this folder?

22		A. I don't know that he showed interest, but he got

23	it. I know he had it.

24		Q. Okay. Did you ask him whether or not there might

25	have been some documents that were placed, misplaced or put

		KANABAY COURT REPORTERS - (813) 821-3320


1	in another folder in L.A., did you talk to him, and maybe

2	that's why we don't have all of them?

3		A. Yes. What we did was we looked in the -- what was

4	called Senior Aide Sealed Files.

5		Q. Where were those?

6		A. In Church of Soientology International.

7		Q. In L.A.?

8		A. Yes, in Los Angeles.

9		   We looked in what is called the Celebrity Center

10	International and the personnel and ethics files there. We

11	looked in -- well, we had somebody look in the PC folder for

12	any reports with regards to this matter.

13		Q. Well, there shouldn't be anything left in the PC

14	folder.

15		A. I'm sorry?

16		Q. I guess there would be for auditing and all that,

17	right?

18		A. Sure. She's been a Scientologist for a long time.

19		Q. Right.

20		   Okay. Are there still folders located outside of

21	Clearwater in reference to Lisa McPherson?

22		A. Yes, sir.

23		Q. Okay. And what folders are those?

24		A. Those would be the PC folders.

25		Q. The PC?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. Those, yeah. Those are the only ones.

2		Q. And that would have to do with her auditing over

3	the years?

4		A. Yes.

5		Q. Okay. Now, is there a difference between PC

6	folder, a pre-Clear folder and an ethics folder?

7		A. Yes.

8		Q. Would you explain the difference to me, please?

9		A. Yes. An ethics folder is -- it's a -- it's a

10	folder for reports. Let's say an individual does something

11	good or does something bad. And there's a distinction

12	between the two, but there's no particular attention on

13	either one of them, except that if an individual does

14	something good, he gets a good report, if he does something

15	bad, there's a bad report. These are collected together and

16	put together in ethics folder.

17		Q. All right.

18		A. For instance, an ethics officer works with an

19	individual on something we call conditions of existence,

20	ethics conditions. There would be reports of those in there

21 	too.

22		Q. Okay. Did you find out where -- and I might have

23	already	covered this,	but do you know what folder -- why are

24	these documents here from these caretakers? They're not --

25	they're	not doing any	-- all they're doing is writing down

		KANABAY COURT REPORTERS - (813) 821-3320


1	observations, they're not having any dialogue, they're not

2	doing any auditing. Why do these documents go to a PC

3 	folder?

4		A. I don't know. .

5		Q. You don't know that answer?

6		A. I don't know, no.

7		Q. But they ended up in a PC folder, right?

8		A. Yes. Best of my knowledge, they did.

9		Q. And that started in Clearwater, correct?

10		A. That's correct, yeah.

11		Q. Now, where is that PC folder kept in Clearwater?

12		A. It's not: I just described, it's in --

13		Q. Back up.

14		A. Okay.

15		Q. Before it got to shipped to L.A., what building

16	did this folder start out in in Clearwater? Where does it

17	live?

18		A. Would be the Fort Harrison.

19		Q. All right. Specifically?

20		A. The Senior CS Office, it looks from this.

21		Q. Okay. I'm not being specific enough. So each --

22			MR. WEINBERG:	That's actually an office.

23		The Senior CS has an actual office.

24		A. That is an office.

25		Q. This isn't Kartuzinski's private office, this is

		KANABAY COURT REPORTERS - (813) 821-3320


1	in his domain?

2			MR. FUGATE: Section.

3		A. Exactly, yes.

4		Q. All right. And everybody's PC folders are within

5	that domain?

6		A. Not all of them, no.

7		Q. Where might the other ones be?

8		A. Well, we had different areas called Hubbard

9	Guidance Centers. I mean, we have hundreds of people there

10	during any given week and the Hubbard Guidance Center, you

11	know, contains and controls them. There's a group of

12	individuals who run that of -- I think it is approximately

13	40 or 50 individuals right now.

14		Q. All right.

15		A. They occupy about a floor of the building.

16		Q. So you did not ask -- did you ask somebody with

17	Kartuzinski's office where these documents went once he read

18	them? Does somebody know the answer to that?

19		A. I didn't ask them, no.

20		Q. Was there a memorandum sent to anybody asking them

21	that?

22		A. No. What I asked them was to collect together any

23	documents they have in their office in the present. And,

24	you know, to locate any and every document they could. find

25	in relation to McPherson.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. The ethics folders, are they contained within the

2	same place, Kartuzinski's office?

3		A. No. No.

4		Q. Where they located?

5		A. They're in the Coachman Building.

6		Q. They're in the Coachman Building?

7		A. Yes.

8		Q. All right. And somebody has a personal folder

9 	too?

10		A. Personnel folder.

11		Q. Personnel folder?

12		A. That's if the individual's a Staff member.

13		Q. She's not a Staff member?

14		A. No.

15		Q. She had an old one though from when she was Staff

16	in Texas, correct?

17		A. Correct. Correct.

18		Q. They also have a central file folder?

19		A. In Texas?

20		Q. Well, I don't know where it is. Is there such a

21	thing as a central file folder?

22		A. Oh, yes. Yes.

23		Q. Where is that?

24		A. Well, the one in FSO is here, actually, in this

25	room, but it is in a place called CF, and that's located in

		KANABAY COURT REPORTERS - (813) 821-3320


1	the Coachman Building, or would have been -- it was located

2 	there.

3		Q. All right. I don't know if you read these

4	subpoenas or not, but there are some other specific

5	documents that we have been told existed at one time that

6	now don't exist, and they are documents that were written --

7	summaries written by Janice Johnson, Paul Greenwood and

8	Laura Arrunnada. Are you aware of that?

9		A. I think you're referring -- yes, yes.

10		Q. Those three people are the three people that took

11	her in the van to the hospital?

12		A. That's right.

13		Q. Okay. Have you been made aware or are you privy

14	to information that they were asked to write a summary of --

15	of the events that occurred on that day by a security guard?

16			MR. WEINBERG: You're asking if he has

17		firsthand information?

18			MR. McGARRY: I don't know how he's got it,

19		I'm asking if he has that information. I just want to

20		know who has that information --

21			MR. WEINBERG: If it came from us --

22			THE WITNESS: I did get it from them.

23			MR. McGARRY: All I want to know, if it's in

24		his brain. I just want to know if he's got it.

25			MR. WEINBERG: We've explained to him the

		KANABAY COURT REPORTERS - (813) 821-3320


1		issue, there are a number of witnesses --

2			MR. McGARRY:	My question is a preview if he

3		acted on that.

4			MR. WEINBERG:	Did you act on knowledge that

5		there was supposedly handwritten reports and/or signed

6		reports on about September 15th following her death

7		from certain specific --

8		Q. No, specifically the three people that I

9 	mentioned.

10		A. Those three people, I heard that a summary was

11	made by Mr. Marcus Quirine.

12		Q. Correct.

13		A. And I obtained a copy of that.

14		Q. Okay. I've seen that copy. That copy has been

15	provided to us, as matter of fact.

16		A. Yes, sir.

17		Q. You're aware of that?

18		A. Yes, sir.

19		Q. And --

20		A. And that has the summaries of the individuals

21	you're mentioning.

22		Q. Yes, it does.

23			MR. CROW:	It has a summary of the

24		individuals?

25			MR. McGARRY: His summary of the summary.

		KANABAY COURT REPORTERS - (813) 821-3320


1      			THE WITNESS: Yeah.

2      			MR. CROW: It doesn't have their notes?

3      			THE WITNESS: Not that I'm aware of.

4      			MR. CROW: I thought it was unclear the way

5		you said it on the record.

6      			THE WITNESS: okay.


8		Q. Now, did you follow-up on where the transmission

9	got lost in those documents? We're missing those documents.

10		A. You're missing those documents, yes.

11		Q. Did you follow up on that?

12		A. Well, yes, that was

13		Q. Tell me what you did.

14		A. That was part of the search here.

15		Q. Okay. Tell me what you did.

16		A. Probably in relation to Alice Vangrondelle. These

17	reports by the individuals, I couldn't figure out where else

18	those reports could have gone except for the ethics files.

19		Q. Did you find out who the security guard was that

20	requested that they write these, did you find that out?

21		A. I didn't know a security guard requested they

22	write them. But let me -- let me say, I did talk to the

23	Security Chief at that time, Mr. Paul Kellerhaus.

24		Q. Right. And he indicated he didn't ask them,

25 	correct?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. I don't -- no, I just asked him --

2		Q. Did you ask him?

3		A. -- where the hell I could look for these

4	documents. And he said he didn't know where they went.

5		Q. Wait a minute. We've got to cover this kind of

6 	carefully.

7		A. Okay.

8		Q. He said to you he didn't know where they went,

9	meaning he asked for them to write them?.

10		A. No, no, I don't know. See, all I was trying to do

11	is find any and all documents in relation to McPherson. I

12	didn't talk to him about --

13		Q. Those three?

14		A. -- those three, no. I'm looking for any and all

15	documentation.

16		Q. But you didn't ask him about those three? .

17		A. No.

18		Q. You're aware that I subpoenaed those three, right?

19		A. Yes.

20		Q. Because you've seen the subpoena?

21		A. Right.

22		Q. Okay. But you didn't ask him about those three?

23		A. No.

24		Q. Did you ask him about the -- did you ask -- one of

25	them is in Mexico. Did you ask the two people that are

		KANABAY COURT REPORTERS - (813) 821-3320


1	locally whether or not they wrote them and what was in them?

2		A. The two people locally?

3		Q. Which would be Janice Johnson and Paul Greenwood,

4	they're the authors of the documents I'm seeking.

5		A. Oh, yes. No. No, sir.

6		Q. You did not speak to them?

7		A. No.

8		Q. And you never found the security guard that

9 	allegedly asked them to-write it down? 

10		A. No.

11		Q. And did you talk to Marcus Quirine in reference to

12 	him accepting those documents and doing a summary from those

13	documents?

14		A. No, I didn't.

15		Q. You didn't speak to him either?

16		A. No.

17		Q. Well, I'm at a loss at what else you did as to

18	locate those particular documents. What areas are we --

19	what am I missing here that you did?

20		A. Well, what -- whatever Mr. Quirine did with these,

21	they must exist in some form in some file in the Church.

22	And what I did was, I looked in those logical places where

23	those things could be.

24		Q. Which was where?

25		A. Specifically, the ethics files, okay?

		KANABAY COURT REPORTERS - (813) 821-3320


1	Specifically, the Church ethics files.

2		   In other words, these individuals were writing

3	reports about an individual. They could be what is known as

4	a Knowledge Report. They could have been -- gone to the

5	Senior CS Office, to Mr. Kartuzinski. That's why I wanted

6	to look in those areas and that's why I had the staff look

7	in that area for those -- those particles. Then there was

8	the PC folder, okay, so they could have been in the PC

9	folder.	That's why we had a search done through the PC

10	folder.

11		Q. Pursuant to your investigation and location of 

12	those particular documents, did you establish why those

13	documents were requested to be written? I mean, we don't

14	know who asked --

15		A. No, sir, I didn't.

16		Q. You don't know why?

17		A. No, I don't know.

18		Q. Do you know whether it was -- it was a fear of

19	infectious disease or because it was for pending litigation

20	that might come in the future or whether it was --

21			MR. WEINBERG: I don't want you to speculate,

22		Glen.

23			THE WITNESS: I don't want to speculate

24		either.

25		Q. You don't know why they were asked to be

		KANABAY COURT REPORTERS - (813) 821-3320


1 	generated?

2		A. I don't, no.

3			MR. WEINBERG: Just so the --

4		Q. Okay.

5			MR. WEINBERG: Just so the record is clear,

6		he's deposed the witness that caused them to be

7		generated who's already told him what happened.

8			MR. CROW: That is not correct.

9			MR. McGARRY: That's wrong, Sandy.

10			MR. WEINBERG: Marcus Quirine.

11			MR. McGARRY: Quirine did not generate those

12		documents.

13			MR. WEINBERG: No, he caused them to be

14		generated.

15			MR. McGARRY: No, sir, he didn't.

16			MR. WEINBERG: Maybe I'm --

17			MR. McGARRY: You're mistaken. There is a

18		security guard, of which I don't know who, that caused

19		them to be created. I don't know who did it.

20			MR. WEINBERG: All right. That's news to me.

21		All right.

22			MR. McGARRY: Well, do you know who caused

23		those to be generated?

24			MR. WEINBERG: I have no idea. I was under

25		the impression Mr. Quirine had told you that he

		KANABAY COURT REPORTERS - (813) 821-3320


1		interviewed a bunch of people that night.

2			MR. McGARRY: Yes, he did. I'm not talking

3		about that.

4			MR. WEINBERG: That night some of those

5		people say that they wrote out notes.

6			MR. McGARRY: A lot of them did. And he made

7		a summary of them. I'm talking about the security

8		guard that asked these three people down in the

9		basement, the security guard in the 	parking gage, to

10		write these three documents out.

11			MR. WEINBERG: Do you have the name of the

12		security guard?

13			MR. McGARRY: No, I don't know who did it.

14			MR. WEINBERG: All right.

15			MR. McGARRY: Paul Kellerhaus didn't --

16			MR. WEINBERG: 	Okay.

17			MR. McGARRY: That's what I'm asking him.

18		I'm asking him because I thought that's what he was

19		doing.

20			MR. WEINBERG:	He's looking for documents,

21		he's not here to testify about what happened two years

22		ago.

23			MR. McGARRY:	Sandy, how do you look for

24		documents that happened two years ago?

25			MR. WEINBERG:	How does that happen? The

		KANABAY COURT REPORTERS - (813) 821-3320


1		person circulates memos to as many people as we can

2		think of this is what we're looking for, any document

3		that would exist, and -- and it includes these

4		documents.

5			MR. McGARRY: That's your way.	I'm going to

6		go ahead and ask my way, all right? It's my dime.

7			MR. WEINBERG: All right.


9		Q. So you had ---you had a conversation with

10	Paul Kellerhaus, correct?

11		A. Very brief, yes.

12		Q. And the subject of the conversation was what?

13		A. His -- his computer, actually. I was interested

14	in his computer, to see if there were any reports on his

15 	computer.

16		Q. And he didn't have any in the computer?

17		A. Well, he wasn't sure. He said that as far as he

18	knew, they weren't there anymore.

19		Q. Okay.

20		A. So what we did was, we hired an expert to come in

21	and do a search of the computers, including Mr. Kellerhaus'.

22		Q. I have the results of that.

23		   Did you talk to him about the reports, though,

24	that were asked to be created by a security guard down in

25	the basement?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. No. No, sir.

2		Q. You didn't ask that question?

3		A. No, sir, not at all.

4		Q. Did you ask him any questions about any meetings

5	that he had with Brian Anderson in reference to reading

6	these reports and being present when they were created?

7		A. No.

8		Q. So you didn't ask him that?

9		A. No

10		Q. Did you ask him whether or not he was familiar

11	with the path of paper that was being created by the

12	security system that was in place outside of Lisa's door?

13		A. No.

14		Q. Okay.

15		A. No.

16		Q. So you didn't follow up on that?

17		A. No.

18		Q. Are you aware there are some circumstances and

19	events that occurred, that actual security guards delivered

20	some of this paperwork, some of these memorandums to various

21	places in the Church? Did you find that out?

22		A. Yes.

23		Q. And who did you find that out from?

24		A. From counsel.

25		Q. Okay. But you didn't find it out from the

		KANABAY COURT REPORTERS - (813) 821-3320


1	security people?

2		A. No. No.

3		Q. Okay. In your -- in your investigation, did you

4	ever find out whether or not there was a

5	Committee of Evidence that was done in reference to this

6	case?

7		A. I found that there was none.

8		Q. There was not?

9		A. No, that's --

10		Q. As to any members that were involved in this case

11	and their involvement with Lisa McPherson?

12		A. Yeah, that's what I found.

13		Q. So you're telling me today that there has not been

14	a Committee of Evidence that has been done --

15		A. As far as I can tell, no.

16		Q. You didn't let me finish.

17		A. Oh, okay.

18		Q. -- on Mr. Kartuzinski?

19			MR. WEINBERG:	With regard to Lisa McPherson?

20			MR. McGARRY:	With regard to Lisa McPherson,

21		the way this was handled.

22		A. I would say as far as I know, and I can explain

23	this in a second, no, there hasn't been. I looked through

24	his ethics file personally, personally, and I saw nothing in

25 	there.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. Is that where that document would be maintained?

2		A. Yes, sir.

3		Q. So somebody does a summary of the

4	Committee of Evidence and that document goes in his personal

5	file?

6		A. His ethics file.

7		Q. Any other file that that document would go to?

8		A. Not that I'm aware of, no. Not a

9	Committee of Evidence. 

10		Q. So that's the only file it goes to and it's the

11	person who's actually being investigated --

12		A. Yes.

13		Q. -- for violation of a Church policy?

14		A. Yes.

15		Q. It goes in their file?

16		A. Yes.

17		Q. It doesn't go in a central file where the

18	Committee would keep a record of all Committee of Evidence

19	cases they've had, or Justice Committee?

20		A. It always goes to his ethics file. When the

21	Committee of Evidence is finished, their record goes to his

22	ethics file.

23		Q. And there is none?

24		A. I didn't see any, no, sir.

25		Q. Do you know who the Justice Chief at that period

		KANABAY COURT REPORTERS - (813) 821-3320


1	of time was?

2		A. At Flag? You mean here in Clearwater?

3		Q. Here in Flag, yes.

4	      		MR. WEINBERG: Period of time we're talking

5	about is what?

6			MR. McGARRY: Lisa McPherson time.

7		A. No, no.

8			MR. McGARRY: Or three months after,

9	specifically.

10		A. Yeah. No, sir.

11		Q. All right. In the event, if there was ever an

12	Introspective Rundown done -- and my information tells me

13	that there was not one -- would there be a record of that?

14		A. I don't know.

15		Q. I'm asking you because you're the -- you're the

16	guy that knows.

17		A. No, sir, I -- I don't know, because an

18	introspective -- I've never participated in one, I've never

19	seen one. If it would be in the person's PC folder, that's

20	the only place where I could think it would be.

21		Q. All right. How about a Purification Rundown,

22	something like that?

23		A. Yes.

24		Q. Do they keep records of that?

25		A. Yes.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. And where would they put those records?

2		A. In the -- I guess in the person's PC folder.

3		Q. Okay. How about a Security Check, Sec Check for

4	short, are you familiar with that term?

5		A. Oh, yes.

6     		Q. You are?

7     		A. Oh, yes.

8		Q. And if that was done, would that be in somebody's

9	folder too?

10    			MR. WEINBERG: Which folder are we talking

11		about?

12    			MR. McGARRY: I don't know.

13    			MR. WEINBERG: PC folder?

14    			MR. McGARRY: Any folder.

15		A. Any folder? It would be --

16    			MR. WEINBERG:	I'm not arguing, I just want

17		you to be clear as to the question.

18		Q. If a Sec Check would be done, would there be a

19	document created? And if it was created, what folder would

20	it go to?

21		A. There would be a document created and, as far as I

22	know, it would go in the PC folder.

23		Q. Are you aware of one being done in this case,

24	Lisa McPherson's case, ever?

25		A. Let me think here. No. No.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. You specifically looked for it?

2		A. I didn't specifically look for it -- for that, but

3	when I did go through the folders, I.would have noticed

4 	that.

5		Q. Okay.

6		A. So I would say -- I would say no.

7		Q. Let's talk about destruction of records. Are any

8	records ever destroyed, due to time, gamy, old, moldy, death

9	of an individual?

10		A. Yes.

11		Q. Explain to me those circumstances.

12		A. They're varied. Records are maintained by Church

13	staff members, let's say on a personal level, since we're

14	dealing with individuals here, until they're told to get rid

15	of them or until they feel they have no more use for them.

16		   For instance, in my office, if I kept records that

17	I wanted to keep, not normal records, but let's just say

18	special reports, commendations, I put them in a folder. And

19	it would be to my own discretion as to whether I kept them

20	or got rid of them.

21		Q. Let's take, for instance, the big folders, we're

22	talking ethics, PC --

23		A. Okay. We're talking --

24		Q. The big stuff.

25		A. They would go to the warehouse. They wouldn't be

		KANABAY COURT REPORTERS - (813) 821-3320


1 	destroyed.

2		Q. Ever?

3		A. No.

4		Q. You indicated earlier in my questions that you

5	never talked to Lacy Spencer, did you?

6		A. No.

7		Q. The runner.

8		A. That's right, yeah.

9		Q. She's the runner. She's a young girl.

10		A. No.

11		Q. She's worked specifically for Mr. Kartuzinski.

12		A. No.

13		Q. The reason why I asked that, because she told me,

14	when I interviewed her, she accidentally destroyed some

15	documents in reference to this case.

16		A. Okay. .

17		Q. And you're not aware of that?

18		A. No, sir. No.

19		Q. Have you ever been involved in a watch before?

20		A. Yes, but not on a person.

21		Q. Okay.

22		A. You know, sea watch.

23		Q. All right. Maritime?

24		A. Maritime watch.

25		Q. Right.

		KANABAY COURT REPORTERS - (813) 821-3320


1		   Well, this was a watch, correct?

2		A. I believe so, yes. Yes.

3		Q. All right. And the purpose of, this watch was to

4	get this person stabilized so she could go through a

5	procedure, correct?

6		A. I believe so, yes.	  

7		Q. All right. And that procedure would be an

8	Introspective Rundown, correct?

9			MR. WEINBERG:	If you know.

10		A. I don't know, actually.

11		Q. You didn't find that out?

12		A. No. I don't know if a watch is an

13	Introspective Rundown, no.

14		Q. All right. What -- let's go through your

15	training. What level are you on that side of the fence? I

16	know you're Staff, right? Have you gone through teachings,

17	Hubbard teachings?

18		A. Oh, yes.

19		Q. What courses have you completed?

20		A. There are lots.

21		Q. What level are you?

22		A. I'm a Grade IV.

23		Q. Okay.

24		A. Grade IV Release. That is just below what is

25	commonly known as a Clear.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. Right.

2		A. For reference, if you're familiar with these

3 	terms.

4		Q. I'm somewhat familiar.

5		   So you --

6		A. That's mostly what we call processing, or I

7	received auditing. That's not training.

8		Q. I know there are two sides.

9		A. That's right.

10 		Q. And you're on the -- I'm talking about the

11	personal side that you're receiving, I'm not talking about

12	the level of training you've had to give out.

13		A. Okay. Good.

14		Q. All right. So kind of following up there, so

15	you're a Level IV, so you kind of -- you kind of know what

16	terms are, like Introspective Rundown, Sec Check, you know

17	what a Purification Rundown is and all that, right?

18		A. Yes. More the Purification Rundown and Sec Check

19	than Introspective Rundown.

20		Q. Why don't you explain to us -- what's your

21	definition of a Sec Check? How does that work?

22		A. Well, it's a series of questions you ask the

23	individual about to locate his charge. For instance, you

24	may have -- I don't know, the individual may have stolen

25	some money and doesn't want to talk about it, okay? The

		KANABAY COURT REPORTERS - (813) 821-3320


1	idea is to get him to talk about it. And then if you get

2	him to talk about it enough, then he'll realize, gee, it's

3	okay to talk about it, maybe I can take responsibility for

4	this, pay the money back.

5		Q. All right. Are certain things in the Church hand

6	routed personally by the authors of the documents rather

7	than through the messenger system or through the basket

8	system because they're more important than others, in your

9	knowledge as an expert in the area?

10		A. Yes, there's such thing as rush hand route

11 	document.

12		Q. Explain to me the difference between that and the

13	normal route.

14		A. Well --

15		Q. Because these things say "rush." A lot of these

16	things say "rush" on them.

17		A. That's right.

18		Q. And that means --

19		A. That would have gone through a basket system.

20	Even rush hand route would have been handled by a

21	Communications staff member. It's rare an individual

22	himself will take a dispatch, you know, however it's marked

23	and walk up to somebody and say, here, this is for you. You

24	usually have a runner of sorts to do that. In fact, that's

25	very common.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. So the runner hand delivering the dispatch is the

2	rush route?

3		A. Right.

4		Q. All right. The regular route is a basket, but

5	that's picked up by a runner too?

6		A. Yes.

7		Q. But just not immediately?

8		A. Exactly. For instance -- well, they're actually

9	all picked up by the runner, it's how they're handled. If

10	you have regular communication, it goes in another basket.

11	If you have a rush, you have a hand route basket -- or

12	communication, they go in the person's desk in front of

13	them.

14		Q. All right. So that brings me to the question that

15	if it says "rush" on it, it ends up on their disk?

16		A. Yes.

17		Q. "CSN rush" goes to, presumably, Mr. Kartuzinski,

18 	correct?

19		A. Presumably, yes, sir.

20		Q. On his desk, hand delivered?

21		A. (The witness nods affirmatively.)

22		Q. Are you aware that some of these documents

23	suggested that mode of transportation as opposed to-the

24	regular basket mode?

25		A. I'd have to look at them. I think so. I mean, if

		KANABAY COURT REPORTERS - (813) 821-3320


1	you want me to confirm that. But if that's what they said

2	on them, that's what happened to them, I believe.

3		Q. All right. What if it said -- what if it said

4	hand routed because it's case beta? Can you explain to me

5	what that means?

6			MR. WEINBERG:	Because it's what?

7			MR. McGARRY:	Case beta.

8		A. Case data.

9		Q. Is it data or beta?

10		A. It must have been data.

11		Q. Case data, what does "case data" mean?

12		A. It pertains to the person's case as a spiritual

13	being. In other words, it's not -- it pertains to their

14 	case.

15		Q. All right. Are these documents that I just showed

16	you, that you had in front of you right there, is that case

17	data? Do you know the answer to that?

18		A. I don't know the answer to that. I don't.

19		Q. What is case data again?

20		A. That would pertain to an auditing session, you

21	know, where you had an auditor, do you follow me, an

22	individual who sits there and tells you to do certain things

23	and you respond in a certain way to them, in rough.

24		Q. If -- if I was a runner and I was at a pre-Clear

25	state of training and I handled somebody's case data, isn't

		KANABAY COURT REPORTERS - (813) 821-3320


1	there something prohibiting me, stopping me from doing that

2	because I might read it or look at it?

3		A. It would be sealed in some way, usually. It would

4	be covered, you know, in a package. We have runners

5	commonly, and I know when they go between buildings

6	sometimes with case materials, they're put in a locked case.

7		Q. Well, did you find out if any of Lisa McPherson's

8	memorandums that these caretakers did, were they in that

9	fashion? Were they sealed in that fashion, if that's case

10	data?

11			MR. WEINBERG: If you know.

12		Q. If you know.

13		A. I don't know, no.

14		Q. Did you ask anybody?

15		A. No, I did not.

16		Q. You did not ask?

17		A. No, sir.

18		Q. Okay. So it's your understanding that after these

19	documents were read by Mr. Kartuzinski, who happens to be

20	Lisa's supervisor, right, Case Supervisor --

21		A. That's what I understand.

22		Q. -- at the time?

23		A. Yes, sir.

24		Q. To the best of your knowledge?

25		A. Yes.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. So that they would go to her PC folder?

2		A. I don't know. I actually don't know. I -- those

3	reports that we got --

4		Q. Who do I ask to find that out? That is kind of a

5	critical question for me in my document search here.

6		A. Those --

7		Q. Who knows that?

8		A. Those documents came from her PC folder.

9		Q. Right.

10		A. Okay.

11		Q. So my inference is that because these came from

12	her PC folder, he put them there?

13		A. It would seem so, but I don't know if he

14	personally --

15		Q. You didn't investigate that?

16		A. No. No. I don't know if he personally put them

17	in there.

18		Q. You're aware of Mr. Quirine's meeting on

19	December 5th when he gathered all the caretakers together,

20 	right?

21		A. Yes, sir.

22		Q. Did you personally investigate that aspect of

23	these documents?

24		A. Yes, sir.

25		Q. In what respect?

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1		A. In respect to conducting the records searches I've

2	tried to explain.

3		Q. Okay. And that was the L.A., Dallas, Clearwater?

4		A. Yes, exactly. In other words, those records, if

5	there are any left, they must exist somewhere. And I have

6	searched everywhere I think they possibly can  be, quite

7 	thoroughly.

8		Q. Did you ask Brian Anderson whether he read any of

9	these documents? 	      

10		A. Whether he read them, no, sir.

11		Q. Did you ever talk to Brian Anderson about this

12 	case?

13		A. Yes.

14		Q. Okay. And what did you talk to him about the case

15 	about?

16		A. In response to these reports or my dispatch to him

17	as to what to do, I made sure that he understood this is

18	what I was looking for. If he had any question. No, he

19	didn't. He went away and he searched his area for any

20	reports regarding McPherson. And the only thing he give me

21	was -- was a file of newspaper clippings and said that's all

22	he had, other than what had been given before.

23		Q. Who's Dr. Steve Harlan?

24			MR. WEINBERG: Steve?

25			MR. McGARRY: Harlan, H-a-r-l-a-n.

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1		A. Steve Harlan? I don't know.

2		Q. You don't know who he is?

3		A. No, sir.

4			MR. WEINBERG: Is there a document with his

5		name on it?

6			MR. McGARRY: No. Quirine said he was in

7		charge of all the PC folders.

8		Q. Do you know that?

9		A. I'll take a look here. Let's, take a look at

10 	these.

11		Q. You've never spoken to Steve Harlan?

12		A. No, sir.

13		   He's in charge of PC folders?

14		Q. Yes.

15		A. Well, the person who is in charge of -- of the

16	search for PC folders is Becky Ellenberg.

17		Q. How long has she been doing that, do you know?

18		A. No, sir.

19			(The witness and his counsel confer.)

20		Q. Did you every speak to Alfonso Barcenas?

21		A. Yes.

22		Q. In reference to Lisa McPherson?

23		A. No.

24		Q. You didn't talk to him about the subject of the

25	reports, did you?

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1		A. No, sir.

2		Q. What does the term "folder error summary" mean?

3		A. It is done by a specialist in the Church who looks

4	through a folder and looks for errors, and then he makes a

5	summary of those errors. It's for use by the CS.

6		  	MR. WEINBERG: Talking about a PC folder?

7		  	THE WITNESS: PC folder.

8		Q. If somebody were to say that these folders were

9	being FES'd, what does that mean to you?

10		A. That meant that -- I've forgotten the term. The

11	person who's going to do the FES is doing it.

12		Q. Was that done in this case?

13		A. I don't know.

14		Q. Did you ask anybody that question?

15		A. No.

16		Q. Were you aware that Vangrondelle's summaries ended

17	up in some other location than where they were supposed to

18	be? Did you become aware of that?

19		A. Oh, yes, sir. Yes.

20		Q. Why don't you explain how that went.

21		A. Well, we conducted our search. And in the process

22	of doing the search, I believe it was counsel told me to,

23	you know -- we'd really like to find Vangrondelle's

24	folder -- her report. It was a report she did. So then I

25	said, ah-ha, an Ethics Report, where could it be? Ethics

		KANABAY COURT REPORTERS - (813) 821-3320


1	file.

2 		Q. Is it an Ethics Report? I mean, this is the same

3	notes that everybody else does.

4	   	A. Yes, sir.

5	     	Q. That's what we're calling that, an Ethics Report?

6		A. Well, let me actually see the report, how she

7	headed it. She wrote a report. And it wasn't where you'd

8	normally find it. I think it's in the box over there.

9		   	THE WITNESS: Can I see that?

10			MR. FUGATE:	You need the box.

11			(Pause.)

12			THE WITNESS: It's not here, no.

13			MR. WEINBERG: Do you have a copy of it,

14		Mark?

15			MR. McGARRY: Yes.

16		A. Okay. It's a Knowledge Report.

17		Q. Is that what we're calling these things?

18		A. Let me see those. No, I don't think so. This

19	is -- this is a different kind of report. This is a

20	report -- in other words, the individual has found something

21	that he thinks is wrong and writes a report on it.

22		Q. Where did you find that report?

23		A. In a -- in an ethics file. Actually, in

24	Leslie Woodcraft's ethics file.

25		Q. How did that end up there, just by accident?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. Well, no. It should have been there. But it was

2	in the wrong place in the folder entirely.

3		Q. Why would it go to Leslie Woodcraft's ethics file?

4		A. Well, that was a good question. Usually -- it was

5	just a hunch that I'd find it there. Usually when you write

6	a Knowledge Report, it is on a specific individual, okay? I

7	think that says -- has FSL or something on the top of it.

8		Q. Yes.

9		A. She was that person at the time, so it's logical

10	that it would go there.

11			MR. WEINBERG: You mean Miss Woodcraft was at

12		that time?

13			THE WITNESS: Yeah, she was that post. In

14		other words, she was writing on some non-optimum

15		condition with relation to this individual

16			MR. CROW: Are you saying you knew at the

17		time you were looking for it this was entitled

18		Knowledge Report and had that designation?

19			THE WITNESS: No, sir, I didn't know.

20			MR. CROW: Since you didn't know it had that

21		designation on top of it, how -- maybe you can explain

22		again how it would be in her ethics folder.

23			THE WITNESS: It was a hunch. I knew a

24		search had been done,  I knew it was a report. From the

25		description that Leslie -- Alice had given me, I

		KANABAY COURT REPORTERS - (813) 821-3320


1		thought, well, it's probably in the ethics file.

2			MR. CROW: To get a description of the

3		contents of the report is helpful in deciding where it

4		might be?

5			THE WITNESS: In this case, yes.

6			MR. CROW: And possibly in other cases?

7			THE WITNESS: Yes. Oh, yes.

8			MR. CROW: And why did you do that in this

9		case, where you talked to her and got the contents of

10		the report, and not do it in every case?

11			THE WITNESS: I don't understand.

12			MR. CROW: Well, in looking for her report

13		you went and talked to her, debriefed her about details

14		about the report so you can decide what other places it

15		might be. And from looking at this, you haven't done

16		that with the other people whose records we've

17		subpoenaed. So why did you do that in her instance and

18		not do it in the other instances?

19			THE WITNESS: Well, I did do it in some other

20		instances.

21			MR. CROW: Some of other instances and not

22		all of them?

23			THE WITNESS: Not all of them.

24			MR. CROW: Why did you not do it in all of

25		them?

		KANABAY COURT REPORTERS - (813) 821-3320


1			THE WITNESS:	Because I was given to

2		understand that there wasn't any more from those

3		individuals. They already -- they already testified

4		there wasn't any more or they didn't know where they

5		would have gone.

6			MR. CROW: Well, this person didn't know

7		where it had gone to either, but you got details that

8		helped you guess where it was.


10			MR. CROW: Okay.

11			THE WITNESS: Yes.

12			MR. CROW: Why didn't do you that with the

13		other people that we subpoenaed records for?

14			THE WITNESS: Well, that's what I had relied

15		on with these individuals here.

16			MR. CROW: Okay. I understand that you had,

17		I'm asking why is there a difference in the way you

18		handled it?

19			THE WITNESS: Well --

20			MR. CROW: Is there a reason?

21			THE WITNESS: Okay. I think I understand

22		now.

23			Yeah, I was -- I was asked to make absolutely

24		sure, you know, by counsel that it couldn't be found,

25		you see.

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. CROW: Okay. Should I imply you were not

2		asked to make absolutely sure as to these other

3		records --

4			THE WITNESS: No, sir.

5			MR. CROW: -- since you didn't interview the

6		people?

7			THE WITNESS: No. No. When I actually --

8		when I conducted the searches, I had talked with some

9		of the individuals: where I logically thought they would

10		be and had, you know, asked them detailed questions

11		about what they did, you know, in their searches.

12			MR. CROW: You still haven't explained why

13		you handled it differently.

14			MR. WEINBERG: That's if he handled it

15		differently.

16			THE WITNESS: Well, it -- yeah.

17			MR. CROW: I think he already told me he did.

18			THE WITNESS: Not exactly, no. That's why I

19		say, I've talked to some other of the individuals here.

20			MR. CROW: I'm asking about the ones you did

21		not talk to. You acknowledged there were people you

22		did not talk to.

23			THE WITNESS: Exactly. I did not --

24			MR. CROW: In fact, most of the people on the

25		list you didn't talk to.

		KANABAY COURT REPORTERS - (813) 821-3320


1			THE WITNESS: Right, sir.

2			MR. CROW: So most of those people, you

3		didn't talk to them to get whatever details, like

4		details you got from this one lady, that might enable

5		you to determine what file it might have gone to?

6			THE WITNESS: Right. 'Because I didn't think

7		that was necessary.

8			MR. CROW: And I'm asking you why?

9			THE WITNESS: Because it was obvious to me

10		that from, you know, the -- the -- the places I'd

11		located or looked, it was clear that there wasn't going

12		to be any more.

13			Let me explain. I worked in the ethics file

14		area before. I know that reports written by

15		individuals on other individuals have a tendency to get

16		misplaced. So when I went in there, I looked through

17		everything that I could think that it would be. The

18		individual that was doing the search for me, I wasn't

19		convinced that she could actually conduct a thorough

20		search. That's the difference.

21			MR. CROW: I don't think you've answered the

22		question, but I don't think if I ask it again I'll get

23		any different answer, so 

24			THE WITNESS: 	Okay.


		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. Mr. Steilo, I'm referring to Sandy's letter here

2	that we got on July 15th. And it says, The Church has

3	produced all of the reports which were generated prior to

4	Lisa's death that the Church has been able to locate in its

5	document review and production efforts.

6		   He's referring to your efforts, right?

7		A. Yes, sir.

8		Q. My next question is, he's got this worded prior to

9	Lisa McPherson's death.

10		A. I'm sorry, I was paying attention to something

11 	else.

12		Q. My next question in reference to that same

13	sentence is, he puts in here that these documents were

14	generated prior to Lisa McPherson's death.

15		   Are there documents available for -- in reference

16	to her existence and her problems there at the Church that

17	were created after her death?

18		A. Not that I'm aware of, no.

19			MR. WEINBERG: That we haven't turned over,

20		is that what you're asking?

21			MR. McGARRY: Well, either way.

22			MR. WEINBERG: What's the question?

23			MR. McGARRY: The question is simple and

24		plain, Sandy.

25			MR. WEINBERG: We have turned over documents

		KANABAY COURT REPORTERS - (813) 821-3320


1		after her death. You got Marcus Quirine's report, for

2		example. You just need to clarify the question.

3			MR. McGARRY: Well, that's my question.

4		Those are the documents. If there's more documents

5		than that -- why do I have to be specific? If there

6		are documents that were created after her death, then

7		he can say no, you've got Quirine's. And is there

8		something else? I don't know. That's what I'm asking.

9			MR. WEINBERG: That question is a little

10		clearer than the one you asked before.	 

11			THE WITNESS: No, sir, I'm not aware of any.

12			MR. WEINBERG: All right. So the record is

13		clear, there are -- there is one memo that was created

14		on December 5th, 1995, that exists, this is separate

15		from the Marcus Quirine memo, that exists that we have

16		not produced that was prepared for counsel in L.A.  And

17		there are --

18			MR. McGARRY: Who prepared that memo?

19			MR. WEINBERG: A woman named Annie Mora,

20		who's in the office of Special Affairs. That's just a

21		summary document.

22			And there is -- there are two -- and there

23		are handwritten summaries done by Paul Greenwood at the

24		time of his police interviews. In other words, he was

25		interviewed and y'all have the transcripts of those

		KANABAY COURT REPORTERS - (813) 821-3320


1		interviews, and he did some summaries for counsel

2		summarizing what he had been asked by the police and

3		what he had said. And I believe --

4			MR. CROW: Counsel for the Church or his

5		personal counsel?

6			MR. WEINBERG: Counsel Bob Johnson. This is

7		way before -- this is back in 1996, in the early --

8			MR. CROW: Those were not provided.

9			MR. WEINBERG: Well, they_ were not provided.

10		And I don't believe they've been asked for either, but

11		they were not provided. This is not what you've asked

12		for, which is a -- which is a --

13			MR. CROW: We initially subpoenaed, I think,

14		all of Greenwood's documents.

15			MR. FUGATE: No, I think they're -- I

16		think --

17			MR. WEINBERG: You just have to look.

18			MR. FUGATE: Look at it. I think it's -- the

19		period of time, it doesn't include interviews of the

20		police.

21			MR. WEINBERG: By the police, which is --

22		which is in 1996.

23			MR. FUGATE: Without waiving any privilege,

24		obviously these are notes they made to give back to

25		counsel of what was asked of him, which is the

		KANABAY COURT REPORTERS - (813) 821-3320


1		interviews that you have. And I think there's a --

2			MR. CROW: So you did not -- what I'm trying

3		to get at, you didn't refuse to provide them because

4		they're privileged, you refused because you don't think

5		they're subpoenaed?

6			MR. WEINBERG: A, I don't think they're

7		subpoenaed. But, B, if they were subpoenaed, they are

8		privileged.

9			MR. CROW: Obviously, we may not agree with

10		that.

11			MR. FUGATE: That's why we're identifying

12		them.

13			MR. WEINBERG: That's why we're identifying

14		them.

15			Okay. Those are the three documents that --

16			MR. CROW: I guess I would have expected them

17		to be identified at the time of the subpoena, that's

18		why.

19			MR. WEINBERG: No one asked for a privilege

20		log ever.

21			MR. CROW: Well, we don't have to in

22		State Court, Sandy.

23			MR. WEINBERG: I'm just telling you, we

24		have -- we told -- we have told you, we've told Mark

25		from Day 1 that as to events that occurred after the

		KANABAY COURT REPORTERS - (813) 821-3320


1		death, other than the Marcus Quirine thing, which we

2		made an exception as to, we were asserting a work

3		product privilege. However --

4			MR. CROW: You initially asserted work

5		product --

6			MR. WEINBERG: Can I just finish? Can I

7		finish, please?

8			MR. CROW: Make it quick.

9			MR. WEINBERG: If you're not interested,

10		you're not interested.

11			MR. McGARRY: I'm interested. Finish. But I

12		want to follow up on that.

13			MR. WEINBERG: I'm trying to make it clear in

14		the letter we are not withholding -- we are not

15		withholding any caretaker reports. I mean, based on

16		the document review that has been coordinated by

17		Mr. Steilo, there are no reports prior to her death

18		that we are -- that, based on what my client's told me,

19		that we are withholding. We are not withholding any --

20		any handwritten summary or report by Laura Arrunnada or

21		Paul Greenwood or Janice Johnson following the -- you

22		know, on December the 5th following the death.

23			We are not withholding, based on the document

24		review that has been done by --

25			MR. FUGATE: December the 6th, for clarity

		KANABAY COURT REPORTERS - (813) 821-3320

*** Page 93 missing.


1		sake.

2			MR. WEINBERG: -- document review done by

3		Mr. Steilo, any of the -- of the handwritten summaries

4		that have been described to you, as I understand it, by

5		the various witnesses who talked to Marcus Quirine. As

6		far as has been represented to us from our document

7		review, none of those documents can be located. They

8		haven't been located. And they are not being withheld

9		under any privilege or anything like that, okay?

10			We -- we have identified three documents

11		that -- that we would assert a privilege to, and I'm

12		willing to talk to you about the Annie Mora document.

13		Frankly, it's just -- it was a different set of

14		circumstances than Marcus Quirine, because it was with

15		regard, as we understand it, direct communication

16		with -- for purpose of briefing counsel in L.A. with

17		regard to what the events were.

18			MR. McGARRY: Well, in all fairness, Sandy, I

19		have to say that a lot of this got stirred up because

20		of the fact that originally you and Laura were

21		indicating to me that the very documents that I was

22		trying to obtain from Paul, from Laura and from Janice,

23		Dr. Johnson, were being claimed as a privilege.

24			MR. WEINBERG: Well, I think you

25		misunderstood.

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. McGARRY: No. No, I'm not mistaken in

2		that. It was told to me on numerous occasions that

3		those documents, and I believe you memorialized that in

4		one of your letters, that would be privileged

5		information. Now, if I took that wrongly, I don't see

6		how, because you told me that on numerous occasions.

7			MR. WEINBERG: I guess -- I guess we've got

8		to look at it.

9			I believe that if there were -- were reports

10		like that that had been done, there would have been a

11		privilege that attached to it. But I'm telling you

12		that -- that we have not located any reports like that.

13		And, therefore, we're not withholding them based on

14		privilege.

15			If they existed, I believe that we would

16		assert a work product privilege,

17		work product/attorney-client privilege as I understand

18		the circumstances that such reports would have been

19		generated under. But there's nothing to litigate about

20		because we're not withholding them.

21			MR. McGARRY: You're mincing words with me a

22		little bit, Sandy.

23			MR. WEINBERG: Trying not to.

24			MR. McGARRY: My statement is, when I

25		referred to you in conversations about those three

		KANABAY COURT REPORTERS - (813) 821-3320


1		reports that were created by those three individuals in

2		the van ride to the hospital, you indicated to me, as

3		did Laura, and I can remember exactly where this took

4		place, in our investigation room when the three of

5		us -- actually, Lee was there also, and all of you

6		indicated that, well, that was in anticipation of a

7		lawsuit materials and that we would be claiming a

8		privilege on that.

9			MR. WEINBERG: That's correct.

10			MR. McGARRY: And that is why I'm not getting

11		them.

12			MR. WEINBERG: No. No.

13			MR. McGARRY: Based on that information --

14		based on that information, Sandy, if you'll let me

15		finish -

16			MR. WEINBERG: Okay. I'm sorry.

17			MR. McGARRY: -- based on that information,

18		that is what caused the	dander in here to get a little

19		stirred up, because now we have information that

20		there's documents out there, they existed, and you're

21		claiming a privilege. So our litigation at that time

22		was focused towards, well, let's do some research and

23		see if they can claim work product privilege based on

24		the circumstances you told me you were retaining those

25		documents under.

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. WEINBERG: Now, Lee was at the meeting

2		too. I'm sorry if that was how you came away from the

3		meeting, because that was not what I intended to

4		articulate to you.

5			MR. McGARRY: It was more than you, it was

6		Laura too.

7			MR. WEINBERG: Can I finish now?

8			MR. McGARRY: The argument was between the -

9		two of you and both of you told me that.

10			MR. WEINBERG: Now can I finish?, Okay?

11			When we had the conversation with you, I --

12		you know, as we sit here today I can't remember exactly

13		when the conversation was. But all I can tell you is,

14		is that what I believe that I indicated was that under

15		the circumstances as we understood what those witnesses

16		were telling you or other witnesses were telling you,

17		that if -- if those reports existed, we would claim a

18		privilege to them.

19			But what I'm telling you now is, is that

20		since I have been in this case, I have never seen a

21		report like that. And now that Mr. Steilo has

22		completed his company-wide, corporation-wide search,

23		he -- he is here to tell you that he is satisfied from

24		a comprehensive search there are no such documents out

25		there and we are not withholding them. Okay?

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. FUGATE: Well, let me add to that,

2		because one of the reasons we're here is to try to not

3		have knock-down dragouts over things that we don't need

4		to. If we do, we do.

5			The -- in the early conversations what was

6		being said was, we have divided what you're looking for

7		into two categories. We don't disagree anything that

8		was written pre-death you have a right to. We're

9		giving you what we've got. We're continuing to turn

10		everything upside down to find whatever else we can.

11		We did find some more and we provided them to you.

12			We also told you that in regard to those

13		requests, we were looking for those, but if we found

14		them, we were going to claim a privilege. And you said

15		we may not agree with that. And we did say, we

16		understand that, you may be able to litigate it, and

17		we're prepared to litigate our side of the equation as

18		well.

19			And at one of the meetings that we had we

20		indicated that we had gone -- we were going to L.A. to

21		ask L.A. to conduct a search for those very documents.

22		And we went to L.A., came back, and I had a meeting and

23		I said, we've looked for those documents and we can't

24		find those documents. And that's the status as I

25		recall the record. And I kept notes of that. And we

		KANABAY COURT REPORTERS - (813) 821-3320


1		did claim that if we found them, we would claim a

2		privilege, but we recognized that you guys were going

3		to litigate it.

4			MR. McGARRY: You guys gave us a cover letter

5		that said there are no non-privileged documents in this

6		area. And I'll find that letter. Don't have it with

7		me. But we'll agree to disagree on the content of that

8		conversation.	  

9			MR. FUGATE: I'm just trying to tell you the

10		best of my recollection and that's what it is.

11			MR. McGARRY: All right.	We disagree on

12		that.

13			Back to Mr. Steilo?

14			MR. WEINBERG: It's Steilo, by the way.

15			MR. McGARRY: Steilo, excuse me.


17		Q. Did you look in her accommodations account folder?

18		A. Yes.

19		Q. And did you find anything in there?

20		A. Yes.

21		Q. What?

22		A. Well, records of her donations for accommodations.

23		Q. Okay. Is there -- was there also records in there

24	about how she was paying for her stay at the Church during

25	that period that she was being -- she was under the watch?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. Yes.

2		Q. There was?

3		A. Yes.

4		Q. Okay.

5		A. I mean -- yeah.

6		Q. There was?

7		A. (The witness nods affirmatively.)

8		Q. Okay. And those -- those documents reflect what

9	she was being charged for .the period of. time she was staying

10.	at the hotel?

11		A. I believe so, yes.

12		Q. Okay. Do you know how that got paid for?

13		A. No.

14		Q. Did you -- since you're familiar with the

15	recordkeeping at the Flag Building there, is there a log --

16	explain to me how security keeps their logs.

17			MR. WEINBERG: Now or then or any time?

18		Q. If it's changed, you can let me know that also.

19	But certainly then. And if it's changed, now.

20		A. They -- they have a .computer. And whenever they

21	have an incident of significant nature, and I don't know

22	what determines that, but I have seen incidents reported in

23	a computer log.

24		Q. Okay. Is that forever kept?

25		A. I don't know.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. You don't know whether it's purged after a certain

2	period of time?

3		A. As far as I know, it's not purged, no. I do know

4	that the -- what's his name? Someone in security

5	communicated to Mr. Abbott, when he did his search, that the

6	computer had crashed at one time in nineteen ninety

7		Q. Mr. Abbott?

8			MR. WEINBERG: That's the computer expert.

9		Q. I've got his document.

10		A. It was early in 1996, I actually can't be sure of

11	the date.

12		Q. How do these security guys know when they're on

13	their shift? Do they have a log or 'something or some kind

14	of schedule they keep? And who's in charge of that?

15		A. There is a Watch Chief. I'm not aware of the

16	schedule or who keeps the log.

17		Q. Who was in charge in '95 of security, Baxter or

18 	Kellerhaus.

19		A. This incident was Baxter.

20		Q. Baxter?

21		A. Yes.

22		Q. Is an Internal Investigation different than a

23	Committee of Evidence?

24		A. Yes.

25		Q. Explain the difference to me, please.

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. Committee of Evidence is a formally convened group

2	of individuals who look into, with authority, matters of

3	concern. And that's laid out in what is called a -- a

4	Bill of Particulars.

5		All right.

6		A. An investigation could be done by anybody, anybody 

7	interested. For instance, someone might notice that the

8	quality of food is poor and start an investigation. Could

9	be anyone, really.

10		Q. Is there a record kept of that?

11		A. Sometimes.

12		Q. Was there an Internal Investigation done in

13	reference to the death of Lisa McPherson?

14			MR. WEINBERG:	If you know.

15		A. I don't know. I don't know.

16		Q. Did you find out? Did you check?

17		A. Well, in the records I didn't see any.

18		Q. Who would I ask?

19		A. The individuals who could have conducted that

20	investigation.

21		Q. Which would be who?

22		A. At that particular time -- do I know? Again, it

23	could have been any one of these individuals.

24		Q. Brian Anderson?

25		A. He could have, yes.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. Who's over Brian Anderson?

2			MR. WEINBERG: At the time, you're talking

3		about?

4			MR. McGARRY: '95. .

5		A. I don't know. Don't know.

6		Q. Don't know? I .

7		A. No.

8		Q. Who is now?

9		A. Ben Shaw.

10		Q. Ben Shaw?

11		A. Yes.

12		Q. What's his title?

13		A. He is the Commanding officer of the

14	Office of Special Affairs.

15		Q. And he's a local guy?

16		A. Yes.

17			MR. WEINBERG: Which is what Brian Anderson

18	was back in 1995.

19		Q. And Brian Anderson's title now is what?

20		A. He's the Public Relations Officer, Vice-President

21	of the Church.

22		Q. So is that a promotion for him?

23		A. No. I wouldn't think it's a promotion, but I

24	don't know in relation to, you know, his old position, his

25	present now, I don't know if it's -- you know, I've known

		KANABAY COURT REPORTERS - (813) 821-3320


1	Brian for years. He's worked in public relations before.

2 		Q. What is Alain Kartuzinski's position right now?

3		A. Right now, I don't know.

4		Q. You don't know what he does?

5		A. No, sir. No.

6		Q. It's not the same as he. was, is it?

7		A. No, he's not. No.

8		Q. How do people get changed from one job to another?

9		A. That -- that varies, actually, They can-be

10	demoted, they can be promoted, obviously. There's also

11	another condition of when -- let's say -- I mean, the Church

12	is constantly growing, we have a problem with this. And we

13	try to recruit new qualified personnel to fit in a position.

14		   Now, qualified is a variable term. We usually

15	send the individuals off for training. .So someone could

16	come in and take a position and then the person who is there

17	before could be sent for training. And then the person who

18	replaced him did so well, then that's his position, and the

19	guy who-went to training could go to another position, if

20	you follow me.

21		Q. All right. You don't -- is there any record of

22	his being transferred from, one position to another that --

23			MR. WEINBERG: Talking about Alain?

24		A. Talking about Alain Kartuzinski, no. In the

25	ethics file I did see something, he was holding the post of

		KANABAY COURT REPORTERS - (813) 821-3320


1	Senior CS temporarily.

2		Q. All right. Who stamped all these things with FSO

3  	numbers?

4		A. Counsel, I believe.

5			MR. McGARRY: These are your numbers?

6			MR. WEINBERG: That's -- that's our Bates

7		stamp numbers.

8			MR. McGARRY: This is?

9			MR. WEINBERG: Yes. And.-we have the.,

10		originals. If you ever want to look at the originals,

11		we have them in our office with the Bates stamp on

12		them. And that's just a photocopy of the original

13		that --

14			MR. McGARRY: You actually have. the originals

15		of these?

16			MR. WEINBERG: 	Yeah.

17			MR. CROW: How would we make an appointment

18		to do that? Can you all bring them here sometime?

19			MR. WEINBERG:	Actually --

20			MR. FUGATE:	There are more records than what

21		you have subpoenaed that are there. And if you want to

22		come over, a lot of them I don't think are going to

23		be --

24			MR. CROW: More records?

25			MR. WEINBERG: In other words, we have turned

		KANABAY COURT REPORTERS - (813) 821-3320


1		over more records than you've subpoenaed in civil

2		cases, because you haven't subpoenaed every -- there

3		has been more stuff that's been subpoenaed. But we --

4		the stuff we thought was -- you'd be interested in, we

5		actually told Mark to give us some additional subpoenas

6		and we turned over stuff.

7			MR. CROW: We're talking about the caretaker

8		documents.

9			MR. WEINBERG:	I understand

10			Where are they? Are they in here, Glen?

11			THE WITNESS: Some of them are.

12			MR. WEINBERG: Well, just make an appointment

13		and you can come over.

14			But I mean, for example -- actually, where is

15		that? Here is an example. We have it-divided like

16		this. So there's a -- that particular -- in response

17 		to that particular subpoena we turned over those

18		documents, which have the original, you see.

19			MR. CROW: Want to try to go through these

20		today or do it another time?

21			MR. McGARRY: Another time.

22			MR. CROW: We will --

23			MR. WEINBERG: Any time you want to make an

24		appointment, Wayne or anyone can come down or we can

25		bring them over here and you can look at them.

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. CROW: Okay. Well arrange something.

2			MR. WEINBERG: Okay.

3			MR. FUGATE: Just for the record and

4		convenience, what we did, in anticipating that you

5		might want to go through that, each folder in here is a

6		break out- with a subpoena in front of it of what --

7		what you had asked for in the originals, if you want to

8		look at the originals.


10		Q. Have you ever spoken to Bennetta Slaughter

11		A. Yes, sir.

12		Q. And why was that?

13 		A. Well, when we initially came here, my purpose in

14 	working for Elliott Abelson was to gather some information,

15	and Benetta was her employer, and I went to her and spoke

16	with her.

17		Q. You spoke with her about Lisa?

18		A. Yes.

19		Q. And what was the context of that conversation?

20		A. Well, it was, you know, how did she seem before

21	she went to the Fort Harrison, what do you know about this.

22		Q. Okay. Your conversation with her didn't really

23	focus on recordkeeping?

24		A. No.

25		Q. It was just some background?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. Yes.

2		Q. So you're --

3		A. I was trying to create a chronology, if you will,

4	of -- of events so that we could clearly see -- and when I

5	say "we," it's really Elliott could clearly see what -- what

6	happened.

7		Q. So you're more than just a document retriever,

8	you're actually involved in this investigation with the

9	Church --

10		A. Well --

11		Q. -- internally?,

12			MR. WEINBERG: He's been -- he is our client

13		contact. We work with Glen Steilo directly and he

14		works basically under. our supervision with regards to

15		the defense of the Church in this investigation. So he

16		is -- the reason I've been sensitive to a lot of

17		questions you've asked is that since he wasn't here

18		back in December of 1995, 99 percent of the knowledge

19		that he's learned about the facts have come from us.

20		So we work with him-every day.

21			MR. McGARRY: You see the frustration we

22		have. We're not getting the answers that we're looking

23		for because he didn't have --

24			MR. WEINBERG: No, if, you want documents, he

25		does have the answers. He looked, he coordinated --

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. McGARRY: He could not answer a single

2		question in reference to the path that those documents

3		took, Sandy.

4			MR. WEINBERG: That's not what a records

5		custodian does.

6			MR. McGARRY: How do you find them unless you

7		follow up on them?

8			MR. WEINBERG: You don't need to yell at me.

9		You go to Paul Kellerhaus. You say, Paul,

10		who did you give the documents to? Then you go to the

11		next person.

12			MR. McGARRY: I asked and he answered

13		negatively.

14			MR. WEINBERG: But you haven't gone to the

15		next person. If you go back to his interview,

16		you'll -- you'll see who he said, and then you'll go to

17		the next person. You haven't asked Brian Anderson --

18			MR. CROW: He's telling you things he didn't

19		tell us..

20			MR. WEINBERG: No. We've had this

21		conversation before.

22			MR. CROW: Let's go ahead and talk to the

23		witness.


25		Q. I've got some questions I want to -- we've been

		KANABAY COURT REPORTERS - (813) 821-3320


1	asking questions and occasionally bickering back and forth

2	over what you did. I would like to give you the

3	opportunity, if you want to, to start in your own organized

4	way of describing exactly what you did in reference to

5	honoring subpoenas and searching for the documents that we

6	subpoenaed. Give me an overview of that. And if you have

7	documents to supply to us, then go ahead. 

8	Let me ask that open-ended question and you take

9	the ball and run with it.

10		A. Okay, sir. Yes, you can have copies of all this,

11 	probably.

12			MR. WEINBERG: Those are your copies and

13		we'll mark them as exhibits, but why don't you explain

14		them.

15		A. Okay. Well, these represent -- I think I said

16	this before, I identified individuals who would most

17	logically have the files, and then I went off further than

18	that, any eventuality, any possibility, where could the

19	files have gone, you know. So I -- I identified 17

20	individuals here at the -- in Clearwater who would have --

21	their offices. When I say individuals, I mean their

22	offices.

23		And then --

24			MR. CROW: What were those offices?. Are they

25	documented in the records?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. April Bucahnon.

2		Q. When did you have contact with her?

3		A. This was in April and May.

4		Q. '97?

5		A. '97.

6		Q. This is before we subpoenaed the records. So this

7	wasn't in response to our subpoena then, was it?

8		A. No, sir. But this got all the records, I mean.

9		Q. What I'm saying, we subpoenaed some records that

10	were already responded to.

11		A. Yes.

12		Q. Then we issued another subpoena two weeks ago. So

13	when you're doing this, you're not doing this-in response to

14	our subpoena?

15		   In other words, we subpoenaed -- we subpoenaed

16	specific individual caretaker records.

17		A. Right.

18		Q. And we subpoenaed any reports of, I think, three

19	other individuals. I know those are specific things

20	included in the subpoenas.

21		   When you say you talked with her, are you

22	mentioning those individuals' names?

23		A. No, sir. No.

24		Q. okay.

25		A. No.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. You didn't even have our subpoena when you started

2	the search? .

3		A. 'That's right. These --

4			MR. WEINBERG: But you had already -- there

5		were already subpoenas in existence that had called for

6		all of those documents.

7			MR. CROW: I agree with that. They were

8		responded to, and I think --

9			THE WITNESS: It was my understanding they

10		was all encompassing.



13		Q. Tell me, what were you told? Since you didn't

14	have a subpoena to look -- to work from, what were you told?

15		A. We -- we had already -- we had looked for --.we

16	produced documentation to you before. This -- this thing

17	was a second time around.

18		Q. Okay. My question is, what were you told?.

19		A. Any document -- well, any and all financial

20	records, including donations by Lisa McPherson to the Church

21	of Scientology.

22		   Any and all records regarding Lisa McPherson's

23	stay at the Fort Harrison from November 18th to

24	December 5th, 1995,1 including but not limited to scheduling

25	records of those who serviced her in any way and any

		KANABAY COURT REPORTERS - (813) 821-3320


1	documents generated by anyone related to her stay. Any and

2	all documents regarding Lisa McPherson or her stay at the

3	Fort Harrison created after her death. This includes any

4	debriefings, investigative memos or dispatches, ethics

5	actions or other reports on actions taken as a result of her

6 	death.

7		Copies of any personnel files on Lisa McPherson.

8	Copies of any ethics files on. Lisa McPherson or reports on

9	or about Lisa McPherson-which may be contained in mother

10	individual ethics files. All documents related to. any

11	Internal Justice Action taken regarding the death of

12	Lisa McPherson. All documentation maintained in the central

13	file folders of Lisa McPherson.

14		These categories are not intended to limit the

15	search for documents in any way, they're merely intended to

16	highlight the request in the present subpoenas and the

17	Request to Produce records. We're asking for all records

18	related to Lisa McPherson from any time period, not just

19	those records related to the period she was at the

20	Fort Harrison prior to her death.

21		In addition, if you're aware of others who have

22	had any files or records on Lisa McPherson, you must.inform

23	me so that these can be collected as well.

24 			MR. WEINBERG: Just so the record is.clear,

25		we're doing two.things here. We are making sure that

		KANABAY COURT REPORTERS - (813) 821-3320


1		we have responded accurately to your-subpoenas that

2		preexisted that, and we are in the middle of a civil

3		case where we are getting a much more comprehensive

4		Request for Production of Documents that is asking for

5		more documents than you subpoenaed.

6			And so as a result of that, we instructed

7		Mr. Steilo to head up a -- a search for records so that

8		we could comply with -- make sure that we complied with

9		your subpoenas and complied with our -- this

10		Request for Production that we had received in the

11		civil case.

12			MR. CROW: Make sure you already had complied

13		with our subpoenas?

14			MR. WEINBERG: Right. And as a result he --

15		he circulated this memo, which he will have a copy, a

16		number of copies.

17			MR. CROW: I get the idea. I can go ahead

18		and ask him some questions, if you don't mind?

19			MR. WEINBERG:	Okay.


21 		Q. So to make sure that I understand it, and I think

22 	I do, you're doing a -- a broad based, 	comprehensive search

23	for records as opposed to a -- a specific search looking

24	for -- asking about a record drafted by this person or that

25	person or that person?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. Yes, that's right. .

2		Q. And the people in the course of doing these

3	searches are looking for very broad categories of stuff --

4		A. Yes, sir.

5		Q. -- as opposed to specifically identified

6 	documents?

7		   Have you ever gone back -- I understand the point

8	that's been made, that this broad search should have come up

9	with the specific documents as well. But have you ever gone

10	back and specifically tracked the individual documents that

11	are in the subpoenas that brought you here today? In other

12	words, have you gone back and asked for caretaker records of

13	the people listed?

14		A. You mean after your subpoenas, these two

15	subpoenas, recent subpoenas?

16		Q. Other than this search that you're talking about,

17	the general search that you're identifying. with the

18	documents in front of you, have you --

19		A. I'm a bit confused as to time. In other words,

20	when specifically?

21		Q. Any time.

22		A. Well, yes, I have traced individual documents.

23		Q. Okay. Was that a result of the subpoenas?

24		A. Let's see. No -- well, Alice Vangrondelle's.

25		Q. I asked you about that. That's why I was asking

		KANABAY COURT REPORTERS - (813) 821-3320


1	you, in that one you went out, got some information that was

2	crucial to get. And you, after talking and finding the

3	substance of it, you went and -- I think it might, be here.

4		A. Right.

5		Q. You didn't do that with a number of other

6	individuals.

7		   Have you ever done that before or since, what you

8	did with Miss Vangrondelle? Did you do that with any of the

9	other people that are involved in the subpoenaed records

10 	today?

11		A. No, sir, not since that time.

12		Q. Okay. Or before that time?

13		A. Before that time, yes, I have. .

14		Q. You talked with all those individuals?

15		A. Not with all of them, no, sir. Just some of them.

16	I identified them.

17		Q. The one you identified earlier in the statement?

18		A. Yes. And the ones I'm about to identify.

19		   I mean, there are some individuals here,

20	realizing, of course, the individuals I'm talking about here

21	were not the ones that generated the reports as you're

22	talking about, but again, if reports were generated and they

23	can't be located now, or that's the apparency, then where

24	would they be. They would logically be in certain areas,

25	okay? And that's what I was doing.

		KANABAY COURT REPORTERS - (813) 821-3320


1		   For instance, we started with the Senior INR's

2	Office. Should I go on?

3		Q. Sure.	       

4		A. Then we went to the Senior CS Office. That was

5	Mr. Kartuzinski's office. And I spoke personally to the

6	receptionist, we call her Communicator, actually like a

7	secretary. .

8		Q. What is her name?

9		A. I don't know, actually. Let's see.	  

10		Q. Do you know what time period she was there?

11		A. Sue Willis. 

12		Q. Do you know what time period she had worked there?

13		A. She was not there, no, sir, at that time.

14			MR. WEINBERG: No. He's asking what time

15	period has she been there as --

16		A. I don't know.

17		Q. You don't know if she was there during

18	Lisa McPherson?

19		A. I know she wasn't there during that time.

20		Q. Okay.

21			MR. WEINBERG:	That was Lacy Spencer. That

22	was the one that Mark had asked about.

23		Q. Okay. Go ahead.

24		A. So I-had her read this in front of me. I asked

25	her if there was any questions. I told her how important

		KANABAY COURT REPORTERS - (813) 821-3320


1	this was and it was very important that she literally turn

2	her office upside down. And that if there was any archives

3	or any other folders that were maintained by the other

4	incumbents of the office, for instance, Kartuzinski, she was

5	to get those and give,them to me.

6		   Then I went to --

7		Q. And did she give you records?

8		A. No, sir, she didn't find it.

9		Q. She didn't find any records at, all?

10		A. No.

11		Q. Not only ones we subpoenaed, but any of the ones

12	on your list?

13		A. Nothing. Her office was clean, in other words.

14		   Then I went to the Security Chief, who is now

15	Paul Kellerhaus, and I went over each one of these items,

16	these seven general categories.

17		Q. Again, Mr. Kellerhaus was not Security Chief at

18	the time of the Lisa --

19		A. No, sir, he wasn't. Again, it was in relation to

20	his particular office, his computer.

21		Q. I understand. I understand.

22		A. And the people who -- well, anyway, that area.

23		   So we went over specifically the computer. That's

24	when I became aware that he had a -- a computer problem. We

25	went over each one of these. And he writes to me he went

		KANABAY COURT REPORTERS - (813) 821-3320


1	through all of the areas on this and his computers, he

2	checked cabinets, desks, as well as all of his computer and

3	found no documents. But I think at this time -- I don't

4	know if this time he already knew we were going to do the

5	computer search.

6		Q. He couldn't find any documents in any of the

7 	categories?

8		A. Yes, sir. No, he did not.

9		Q. Okay. Go ahead.

10		A. He did not.

11		   Then I went to Mr. Anderson, who's now the

12	Public Relations Officer, and I told him to search his area.

13	Again, I handed this to him personally. And he went

14	through -- he went over every one of: these categories with

15	me and he asked me questions about it. And I told him this

16	was not limited to his time of public relations, but also as

17	the commanding officer at OSA at the time.

18		   So he conducted a search. He didn't find,

19	anything. He --

20		Q. Do you know if he personally did the search or he

21	had other subordinates do it?

22		A. No, sir, he personally did the search.

23 		Q. Who told you that?

24		A. I actually watched him for part of it. I'm in the

25	same office and I watched him.go through his folders --

		KANABAY COURT REPORTERS - (813) 821-3320


1	files, file cabinets against the wall. He went into another

2	place where we keep archives of files and he thought that

3	something might be there.

4		   And he didn't find anything, except he handed me a

5	folder which was of newspaper clippings, mostly kept since

6	December of 1996.

7		   Let's see. Who else did I go to? Okay, I went to

8	the Bureau of Routing and Personnel in the Flag. This

9	person maintains personnel files. Now, Lisa McPherson

10	wasn't a Staff member of the Church of Scientology FSO, and

11	this person's function is to maintain files and reports on

12	Staff members. However, I figured that being reports as

13	they are, if they were misplaced, they could have gone into

14	various personnel files. You follow me?

15		   So I told her I had -- again, I brought this to

16	her personally.

17			MR. WEINBERG: "This" being this memo?

18			THE WITNESS: Yes.

19		A. By the way, her name is Joan Stevens.

20		   And I told her that I'm looking for files in

21	relation -- we went over each one of these -- these things.

22	She told me that she didn't have any personally, she had

23	nothing in her personal area. And I told her to look in the

24	personnel files of -- of individuals who were concerned in

25	this. And I -- I named a number of them off.

		KANABAY COURT REPORTERS - (813) 821-3320


1	Barbro Wennberg, Leslie Woodcraft.

2		Q. Barbro Wennberg?

3		A. Yes.

4		Q. What	was her involvement?

5			MR. McGARRY: Wennbro.

6			THE WITNESS: Wennbro, yes.

7			MR. WEINBERG: No, its s Barbro .Wennberg.

8			MR. McGARRY: Okay.

9			THE WITNESS: She's been, questioned by your

10	office.

11			MR. McGARRY: Yeah, that's true.

12		A. I told her to look in those personnel files.

13		Q. Do you have the list of all the people you

14	specifically mentioned?

15		A. No, sir. It was verbal. .

16		Q. Do you remember which ones you asked her about?

17		A. Yes, sir. It was -- let's see. It was all the

18	ACO personnel. Heather, Leslie, Barbro, herself, Spencer,

19	Lacy Spencer, Alain, Johnson. Somebody else. Let me see a

20	list.

21		Q. See what list?

22			MR. WEINBERG: The list of women?

23		A. This list, yes, sir.

24		   Let's see. Rita Boykin. Sylvia DelaVega. Emma.

25	I think that's it.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. Okay. So you didn't ask to look in the personnel

2	files of everybody who had been --

3		A. Yeah, Greenwood was one of them. Laura's file

4	wasn't there, but we discussed it.

5		Q. Did you have a list you were working from or do

6	you just remember all the names?

7		A. It was -- it was remembering the names, sir.

8		Q. Okay. Are you sure you remembered every name of

9	every caretaker? .

10		A. No, I didn't. I didn't -- I actually didn't ask

11	on Cezare. I did ask on Vangrondelle.

12		Q. Well, what about -- we've got Sam Ghiora?

13		A. No.

14		Q. Teresa Cezare?

15		A. No, I didn't.

16		Q. Vangrondelle you did.

17		   Rita Boykin? .

18		A. Yes, I did

19.		   Patrizia, no.

20		Q. Valerie Demange?

21		A. No, I don't think so.

22		Q. Sylvia?

23		A. Sylvia DelaVega, yes. Heather, yes. Barbro, yes.

24	Emma, yes. Joan, yes. She could look in her own file.

25		Q. She could look at her own file?

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. WEINBERG:	She was the one doing the

2		search. .

3		Q. Okay. Do you know -- did you ask her to look in

4	the file?

5		A. Yes, sir.

6		Q. Okay.

7		A. She said that --

8		Q. Now, did she.look through every piece of paper in

9	every file or did she look at file folders or do you know?

10		A. I don't know, actually.

11		Q. What did she tell you?

12		A. I told her to look through every one of the

13	folders, and again we went over these items, and find

14	anything in those folders in relationship. She told me she

15	had looked into them and she didn't find anything.

16		Q. The ones you asked her. about?

17		A. Yes, sir. I've searched my area and no documents

18	relating to Lisa McPherson at all.

19		   Then I went to the Addresso Officer in the FSO.

20	The Addresso officer is an individual who keeps records,

21	it's a computer record on the parishioners of the Church.

22	This is more information as to their home,. their telephone

23	number, address, whether they speak English, a foreign

24	language, et cetera, et cetera. And he produced some

25	records here with regards to names. It's mostly unknown

		KANABAY COURT REPORTERS - (813) 821-3320


1	though. She was listed as deceased. It did have her old

2 	address.

3			MR. FUGATE: Lisa McPherson you mean?

4			THE WITNESS: Lisa McPherson.

5		A. But that was it. It is a print -- this is a

6	printout of all data .I have in the computer. Give to FSO.

7		   Then we went --

8		Q. Now, the -- let me make sure what's in front.of

9	you. In front of you are the written communications ns with

10	these people, you to them and them back to you, that you

11	asked to do the search?

12		A. Yes.

13		Q. Okay. Is .that all the communications you had with

14	them concerning the search?

15		A. No. There was verbal communications.

16		Q. Let me rephrase the question. That was unclear.

17		   Are these all the written conversations between

18	you and them concerning the search?

19 		A. Yes. Yes, sir.

20		Q. Have any communications been excluded in the 

21	packet that you're supplying?

22		A. No, sir, they're complete.

23		Q. Does this include the records that you found? I

24	know the one attachment had the records that you were

25	looking through. Do these include all the records they

		KANABAY COURT REPORTERS - (813) 821-3320


1	found relating to any categories that you asked them to

2	search for?

3		A. They're not all here, but they've all been -

4	provided to you.

5		Q. I'm not sure we subpoenaed all those things,

6	but --

7		A. You did. You -- you subpoenaed the personnel

8	files, her ethics files, her correspondence files.

9		Q. I'm talking about in your initial list.

10		A. Yes, sir. Yes.

11			MR. WEINBERG:, Well, there are some things

12		that he described we haven't provided, like newspaper

13		articles that Brian Anderson, you know, found. That --

14		that wasn't called for and that's not in that pile.

15		Q. Okay. Go ahead.

16		A. Then we went to the accounts files IC. This is in

17	Flag Crew. This is the organization in -- here in

18	Clearwater that maintains records of her donations for

19	accommodations. For instance, if she was going to stay in

20	the Fort Harrison Hotel, money would be given to this

21	individual, there would be an account file there.

22		   And what he did was, he printed off everything

23	that he had given, actually given to us previously,

24	and I believe you have all of these things also. And he

25	says here, I don't have the folder of Lisa. It's possible

		KANABAY COURT REPORTERS - (813) 821-3320


1	that Judy Vantana has taken it. So I get a copy of the

2	statements and copy of every invoice. In other words, he

3	didn't have the file there, but what she did was she printed

4	out everything that was on the computer.

5		Q. Okay. Did you ever locate the file?

6		A. No , sir.

7			MR. WEINBERG:	I think we turned it over

8		previously. I think that's part of the documents that

9		has been turned over previously. ._

10			MR. McGARRY: We have that.

11			Don't we have that, Wayne?


13		at 210?

14			MR. FUGATE: One of the reasons we asked to

15		postpone this until next week was because Laura Vaughn

16		has been doing this and she's got a better handle on

17		exactly what the document descriptions are, but I think

18		you have that.

19			MR. WEINBERG: We don't have it front of us

20		here, but I believe --


22		what he's referring to, I can-tell you whether we have

23		it.

24			THE WITNESS: What I can tell you is the file

25		was not there.

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. CROW: I don't think we have any original

2		files.

3			MR. WEINBERG: We do. What has happened, we

4		have in our possession the originals of the documents

5		copied which we've produced. .

6			MR. CROW: So you've got that file?

7			MR. WEINBERG: I'm pretty sure we have that

8		file.

9			MR. CROW: So it's not missing?.

10			THE WITNESS: No, sir, it's not missing.

11			MR. CROW: That's all I wanted to know.


13		Q. Okay: Go ahead. Do you need this?

14		A. No, I don't. I'm just waiting for him.

15		Q. Go ahead.

16		A. So then we went -- I went to the Folder Admin in

17	Division IV, which is where she would be receiving any kind

18	of -- of counseling, you know, auditing. And I went over

19	this.,	I handed this also to -- I forgot the individual's,

20	name, but we read through it. And I told her to.

21	specifically look -- I told her that the ethics -- the

22	personnel -- excuse me, the PC folders, I believe, were not

23	here, but she should look in all normal places for the PC

24	folders. She should also look in the folder warehouse,

25	because sometimes, you know, reports get separated from the

		KANABAY COURT REPORTERS - (813) 821-3320


1	PC folders.

2		Q. Whose PC folders are we talking about?

3		A. Lisa McPherson's.

4		Q. Did you ever check the PC folders or ethics

5	folders of any people about. whom we subpoenaed records?

6		A. The ethics folders, yes. The PC folders, no.

7		Q. Have the ethics folders for each of the persons we

8	subpoenaed records on been searched by you?

9		A. By me personally. I did the search myself.

10		Q. But not the PC folder? ,

11		A. No, sir. No, it's not logical there'd be reports

12	about Lisa McPherson in their folders at all, not at all.

13		Q. Okay.

14		A. He says he -- he attests that he's done this again

15	and that there's no -- nothing's been found.

16		   Let's see. Where did we -- the Captain,

17	FSO's Office, we went to her office. I thought on-the odd

18	chance that something would be laying around in her files

19	So I spoke to her two secretaries and I had her two

20	secretaries go through her office. Okay? She found

21	nothing. I didn't see her physically do it myself, but I

22	know her secretaries were briefed on it and she assured me

23	that she had searched the files.

24		   Then I went to the Accounts officer in the -- in

25	the FSO, actually. This would be the Church, in other

		KANABAY COURT REPORTERS - (813) 821-3320


1	words, separate from accommodations, where people would make

2	donations. And I went over this with the -- with the

3	Treasury Secretary at the time, Matt Persh, and he called in

4	several individuals and we briefed them on this. I don't

5	remember the individuals' names. But here's a printout of

6	her materials here.

7		   Hotel Manager of the Fort Harrison. In other

8	words, the individual who's responsible for assigning rooms

9	to parishioners. He says there are no records his

10	area.

11		Q. There are none kept or none remaining?

12		A. None kept. In other words, there wouldn't be

13	anything. I was concerned that, let's say, for instance,

14	she paid for food or someone paid for food on her behalf and

15	there might be records there, kept in the hotel records, but

16	there weren't. He said they normally wouldn't be there. He

17	said, We do not keep any records as such.

18		   Then we went to the Public MLO's Office. That is

19	Emma Schamehorn.

20		Q. Instead of just giving the abbreviation, why don't

21	you say what that stands for.

22		A. Oh, Medical Liaison Office. In other words, Emma

23	was responsible for helping parishioners of the Church find

24	competent medical care. She's a liaison between the

25	individual and the doctors.

		KANABAY COURT REPORTERS - (813) 821-3320


1		   Okay. And she -- she describes what she found.

2	You can read this. She said -- she said any reports written

3	on her were turned into the CS. I recently declassed the

4	drawer that I kept Admin in and some miscellaneous reports

5	on public were there. We do not keep a file for each public

6	person seen.

7		Q. Okay. She said all the reports on-her were turned

8	over to the CS?

9		A. Yes, sir.

10		Q. Being the Church?

11		A. Yes.

12		Q. Or a specific office in the Church?

13		A. Exactly.

14			MR. WEINBERG: Tell him what the CS is.

15			THE WITNESS: The Case Supervisor. That --

16			MR. McGARRY: Kartuzinski.

17			THE WITNESS: That would be Kartuzinski at

18		this particular -- just to cut it short, I mean, she

19		was one of the individuals in the watch, so that's

20		where it would have gone.

21		A. So the central file folders that the CF Officer --

22	he said he gave the files to us in February, that's down

23	there. You have that now.

24		   That was Flag Land Base. That's everybody here in

25 	Clearwater.

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. That you talked to?	.

2		A. Yes, sir. In other words, here in the area.

3		Q. And you never sent out any of these~communications

4	to the actual individuals?

5		A. No, not the individuals named here, except for

6	Emma.

7		Q. Okay.

8		A. And then I did talk to Alice Vangrondelle, you

9	know, as described before.

10		   Then we went to Dallas, Texas. Lisa was there

11	for -- you know, most of her Scientology career was -- was

12	there in Dallas. She was a Staff member there in Dallas,

13	Texas, too for years. She was married twice there in

14	Dallas, Texas, one to another Staff member of the Church.

15	Many of her friends were there in Dallas, Texas. So I knew

16	there would be lots of records there.

17		   So at -- I don't know if you want me to cover

18	that, because it didn't really answer your subpoenas here.

19	Do you want me to go over that also?

20		Q. Sure. 

21		A. So we went to my contact terminal. I established

22	a contact terminal there in Dallas, Texas, by the name of

23	Diane Canon.

24		Q. By contact terminal, you mean --

25		A. I talked to a few --

		KANABAY COURT REPORTERS - (813) 821-3320


1		Q. What is a contact terminal? You just talked to

2	another person? Is that jargon for -

3		A. Yeah. This -- I assigned -- I told her I'm the

4	Custodian of Records of the church, you have to see that a

5	successful search is done in your specific area by the

6	following individuals.	And I mailed to her all of the --

7	the -- the dispatches, you know, the requests for

8	information. I told her to take those personally to each of

9	the individuals, to read them to them, to have them read

10	them there, to get any questions clarified. In short, do

11	nothing	short of turning the place upside down looking for

12	the records.

13		   She conducted several searches in the area,

14	actually. She told me that Lisa would probably be a

15	parishioner at the old Mission. In other words, this was a

16	Celebrity Center in Dallas. It's a specific Church in

17	Dallas for prominent members of the Church. There are

18	also -- there was also a Mission in Dallas, Texas, and she

19	communicated to me that Lisa might have had something to do

20	with the Mission. So she went off and conducted a search in

21	the Mission.

22		   And we went to -- we sent to her office --

23		Q. What did she do, look for things filed under

24	Lisa McPherson, or did she look through pieces of paper and

25	every record, or what does turning the office over mean?

		KANABAY COURT REPORTERS - (813) 821-3320


1		A. Turning the office meant -- again I can go over

2	these seven -- these seven points to you. This is what

3	she -- she was looking for.	.

4		Q. I understand that. What I'm saying is, how -- in

5	terms of how she looked for it, was indexes she used, how

6	she would decide here the records might be, did you leave

7	that up to her discretion based upon the knowledge of local

8	records or did you say I want every piece of paper in this

9	place looked at or what. directions did you give her? Or did

10	you just give her the general direction, if there's anything

11	here, I want it found, and leave it up to her as to .how it

12	was done?

13		A. Actually, both. But specifically, there are posts

14	in the order, similar. For instance, there's a Senior CS in

15	the Church there, there's a Staff ethics file, a routing and

16	personnel person, an ACL, there's an Executive Director in

17	that organization. -And there were individual dispatches

18	written to them. So she was to take those dispatches to

19	those individuals and make sure they understood them and

20	they read them and they got any questions answered.

21		   And then there was a catch-all there too. I told

22	her -- see, based on my work with Mrs. Vaughn, we were

23	looking for correspondence files. We were previously

24	looking for correspondence files between Lisa and several

25	Staff members there in -- in the Church in Dallas. And I

		KANABAY COURT REPORTERS - (813) 821-3320


1	told -- and she had not found some of those things.
2		   And I told her, I said, Well, this is it, this is
3	your, search. You must find what is there or not find them.
4	In other words, turn the house upside down. Look in every
5	file if you have to to convince yourself that there is
6	nothing there from Lisa McPherson regarding correspondence
7	between your -- herself -- Lisa and her -- her Staff.
8		   In fact, I think -- is that copy in here too? She
9	kept detailed notes of the searches done- for correspondence.
10	She. even conducted a project. She took various volunteers
11	in the Church, both parishioners and Staff members, and they
12	systematically went-through all the correspondence files.
13		Q. We didn't subpoena any correspondence --
14			MR. FUGATE: This is --
15			MR. CROW: The civil case?
16			MR. FUGATE: -- more in response to the civil
17		case.
18			MR. WEINBERG: And we have subsequently
19		turned over, I believe, a lot of that stuff to y'all as
20		a result to the subpoena.
21			MR. CROW: I'm looking for the search for
22		missing records.
23			MR. WEINBERG: That's what they're -- they're
24		not just looking for documents, they're looking for all
25		the documents.

		KANABAY COURT REPORTERS - (813) 821-3320


1			MR. CROW: Despite that, I'm interested in

2		talking to him today about the search for missing

3		records.

4			MR. WEINBERG: It's hard to do that --

5			THE WITNESS:	The missing records I believe

6		you're talking about would have been included in this.

7		That's why we were doing it.


9		Q. They weren't correspondence, they were caretaker

10	notes and reports of the events of the day of her death.

11		A. Right. You're talking about these two.

12		Q: Yeah, the two subpoenas.

13		A. Yeah, that's right.

14		Q. So the correspondence files, how hard they looked

15	for the correspondence files doesn't really relate to how

16	hard they looked for the caretaker notes, is what I'm

17 	suggesting.

18		A. Right.

19		Q. Okay?

20		A. Okay, yeah. Again, this would be -- this would

21	be -- this is the Church of Scientology in Dallas. I don't

22	think you'd find the caretaker reports there

23		Q. Okay. So this --

24		A. Would be unlikely. .

25		Q. This request is kind of irrelevant to the

		KANABAY COURT REPORTERS - (813) 821-3320


1	subpoenas today, it was more the civil case?

2		A. Yes.	

3			MR. FUGATE: Except it included the

4		information --

5			MR. WEINBERG: How can you say that?

6			MR. CROW: I can't say that, I'm asking the

7		witnesses.

8			MR. WEINBERG: Hold on. Hold on.

9			MR. CROW: You don't testify for him.

10			MR. WEINBERG: No. You say is it --

11			MR. CROW: I asked is it irrelevant, he can

12		answer yes.

13			MR. WEINBERG: No, it's not irrelevant.

14			MR. CROW: Let him answer, not you.	     

15			MR. WEINBERG: I want to say something

16		though.

17			MR. CROW: You're not the witness.

18			MR. WEINBERG:	That's right. But you asked

19		us to certify -- bring somebody into say they made a

20		search of the church for documents, and the Church in

21		this case doesn't just include Clearwater and --

22		Clearwater, it was L.A. and Dallas, because those were

23		other places for records, and that's what he's trying

24		to explain to you.

25			MR. CROW: I understand exactly what he's

		KANABAY COURT REPORTERS - (813) 821-3320


1		saying.

2			MR. WEINBERG: It is not irrelevant, Doug.

3			MR. CROW: Well, the searching for

4		correspondence is irrelevant -- not relevant to whether

5		they were looking for the caretaker records. 

6			MR. WEINBERG: That ain't all he said. He

7		said he searched for everything, which included, if you

8		look at the list, the caretaker letters.

9			Go ahead. 

10	BY MR. CROW:. 

11 		Q. Go ahead. What was your answer to my last

12	question?

13		A. Well, it -- yeah, in relation to these -- these

14	subpoenas, these correspond files don't apply.

15		Q. Okay. What about the Church of Dallas area, did

16	you -- did you -- you indicated you were searching for

17	logical areas where those records might be. Is that one of

18	the logical areas where you thought those records might be,

19	the caretaker records?

20		A. Yes, sir.

21		Q. Okay. So you thought they might be there?

22		A. I thought there's the remote possibility they

23	could be there, so that's what we were doing.

24		Q. Okay. Go ahead.

25		A. So she found -- she looked in Lisa McPherson's

		KANABAY COURT REPORTERS - (813) 821-3320


1	correspondence file, it was incomplete. She looked--

2		Q. What does that mean?

3		A. It was incomplete in that the things that I was

4	looking for -- and again I'm tying this into, some of the

5	work we did on the civil case -- was not there in the file.

6		Q. Okay. Incomplete meaning there were missing

7	documents --

8		A. Yes.

9		Q. -- that should have been there, that you expected

10	to be there.that were not there?

11		A. Exactly.

12		Q. What missing documents are you talking about?

13		A. Specifically, there were letters from Lisa to a

14	Staff member there in Dallas regarding her intentions on

15	Thanksgiving weekend, 1995.

16		Q. Okay. How did you know they existed if they

17	weren't in that file?

18		A. Because the -- the person who was answering her

19	communication made reference to letters. For instance,

20	she -- and I found the letter now, so I can talk and say

21	that I did find it.

22		Q. Well, then jump ahead to where you found it.

23	Let's go there. 

24		A. Okay. To make a long story short, they found it

25	in a completely irrelevant area, in a -- in an area of back 

		KANABAY COURT REPORTERS - (813) 821-3320


1	filed particles. Particles meaning letters In other

2	words --	.

3		Q. "Particles" is a --

4		A. Is a common Scientology term for these.

5		Q. Okay.

6		A. An entity, you know. We call them particles.

7		Q. "Entity" being a piece of paper with writing on

8	it?

9		A. Exactly. Exactly.

10		Q. Okay.

11		A. And she had no less than ten people working-on

12	that, on and off, probably three weeks.

13		   Anyway -

14		Q. Is there any particular reason you were

15	specifically concerned with that letter?

16		A. Yes. And I'll talk about the civil case.

17		   There were allegations that Lisa wanted. to leave

18	the Church and that she had -- she was going home and she

19	was going to stay home. I believe those allegations were

20	made by Miss Kelly Davis.

21		   The letters documented that she was not going home

22	to not be a Scientologist. Among other things, she was

23	going home to work with other Scientologists in the Dallas

24	area-to establish what we call an OT Committee, a committee

25	of Scientologists,who form together and formulate plans and

		KANABAY COURT REPORTERS - (813) 821-3320


1	activities for the Church. And this was alluded to.

2		And the Staff member -- in the Dallas Staff

3	member's letter he said, Great, I'm glad you're going to be

4	here, we'll see when you come to Dallas, we'll get everybody

5	together, some words to this effect. And we were all

6	puzzled, well, what does she write to this individual that

7 	would cause him to say these things? Especially it. seemed

8	to be contrary to what, I think, Miss Davis was saying about

9	what she was going to do there. And sure enough, we found

10	the letters that said what she was going to do.

11		Q. Okay. So that's why that correspondence was of

12	particular interest to you?

13		A. Of particular interest to everyone, really, at

14	that time.

15		   Okay. We'll go on reading Dallas. We caused a

16	search in the Senior CS Office, which is an office -- any

17	one of these reports could have made it into her -- the

18	Senior CS Office in Dallas. Some of those reports were

19	addressed to Senior CS. Senior CS is actually a common term

20	in each-Church. There's always one Minister who --

21		Q. How does the Senior CS keep files? Are they

22	chronological? By name? Say somebody writes a letter to

23	the CS, it concerns Lisa McPherson. How is that filed?

24		A. It would depend. If it's about -- if it's

25	concerning a case matter, regarding an auditing session, a

		KANABAY COURT REPORTERS - (813) 821-3320


1	spiritual counseling session, it would go in the person's PC

2	folder.

3		Q. So the PC folder is supposed to be at the office

4 	there in Dallas? She had -- she had a PC --

5		A. It could have been.

6		Q. Does she have a PC folder in Dallas and in

7	Clearwater and Los Angeles, or does she only have one?

8		A. No, there's many PC folders. Now they're in

9	Los Angeles. But at one time -- at one time they did exist

10	in Dallas, Texas.

11		Q. How did you know -- I mean, at the time you were

12	making the search did they exist or were they already in

13	Los Angeles?

14		A. No, at the time I did the search they were already

15	in Los Angeles. Perhaps there would be a folder there,

16	perhaps there could be a misrouted particle, report, perhaps

17	it could be there. Again, you understand we were just

18	looking for everywhere and everything. They found nothing.

19	Person by the name of Cindy Hoenstein.

20		   Then we went to Staff ethics files. She was a

21	Staff member. She was a Staff member under the name of

22	Lisa Skonetski and also McPherson. And that was not there. 

23		   Typically when a Staff member leaves the -- a

24	Church of Scientology as a Staff member, personnel files,

25	their Staff personnel files are sent to the Church of

		KANABAY COURT REPORTERS - (813) 821-3320


1	Scientologist international, what-we call the Senior ACO

2	Office.	So I -- I thought perhaps that the file could be --

3	there could be misfiled particles there. They could have

4	missed it. That's why I asked this person if there was, but

5	there wasn't.

6		   The Bureau of Routing and Personnel, I asked in

7	that area too, Skonetski and McPherson, and we-found

8	nothing.

9		   We went to their Executive Director's Office. It

10	was unlikely -- unlikely there was anything there

11		Q. Let me see if I understand. You felt there might

12	be records relating to the time frame of Lisa McPherson's

13	death concerning Lisa McPherson, they might be back -- they

14	might be filed at the office where she'd been previously a

15	Staff member?

16		A. Yes, sir.

17		Q. Okay. So even though the PC folder was not-there,

18	it was in Los Angeles ---

19		A. Right.

20		Q. -- there might be other files, because she used to

21	work there, it might have been routed to where she used to

22	work?

23		A. Exactly.

24		Q. Okay. So did you check all these other Staff

25	members, did you check in the places where they used to work

		KANABAY COURT REPORTERS - (813) 821-3320


1	to see if any of their reports were misfiled?

2		A. No, I didn't, actually.

3		Q. Okay.

4		A. I didn't think of that, actually.

5		Q. Okay.

6		A. Mainly because the Staff members, most of the

7	Staff members started here and have been here since, well,

8	early '81.

9		Q. Okay. Go ahead.

10		A. I think it would be unlikely.

11		   There was the Bureau of Routing and Personnel,

12	Dallas, Executive Director's Office, the finance area, which

13	was one individual who -- who performed many functions. You

14	know, in a small church sometimes the Treasury Chief is

15	really the Accounts Files IC and also handles all the filing

16	and correspondence. In other words, he's everything wrapped

17	together. So he answered for a number of areas.

18		   Then we went to the Addresso Officer. I spoke to

19	the Addresso Officer personally. He didn't find anything.

20		   Central files Office. He said that he found

21	nothing in relation to this. However, they did turn over a

22	number of files to me. In fact, from CC Dallas I found

23	three central files in total, three central file folders.

24		   What's this? Oh, this is just part of her search.

25	We've already gone over that.

		KANABAY COURT REPORTERS - (813) 821-3320

*** Pages 145-153 missing.


1		with the documents Mr. Steilo has just reviewed

2		regarding his correspondence to and from people with

3		regard to the April/May search for documents in

4		Clearwater and in Dallas and in L.A.

5			MR. CROW: Okay.

6			MR. WEINBERG: We'll just turn that over to

7		you. That's yours.

8			MR. CROW: Okay. And what -- and I know

9		everybody's tired, but I'm genuinely confused and I

10		feel the necessity of going back over the initial

11		search and the initial subpoenas and your involvement

12		in that. Do y'all want to keep going? Do you want to

13		break it off?

14			MR. WEINBERG: Let me tell you what my

15		problem is.

16		Off the record.

17		(Off the record.)

18		(Statement is adjourned at 5:15 p.m.)








		KANABAY COURT REPORTERS - (813) 821-3320





5		I, the undersigned authority, certify that the
	aforesaid deponent personally appeared before me and was
6	duly sworn.

7		WITNESS my hand and offficial seal this ___ day
	of ________________, 1997.
			     (signed & stamped, July 30 1997)
			Notary Public - State of Florida
11			Commission No. CC 643284
			Commission Expires: 4/29/2001

		I, RUTH M. MARTIN, Registered Merit Reporter,
16	certify that I was authorized to and did stenographically
	report the sworn statement of the aforenamed deponent and
17	that the transcript is a true and complete record of my
	stenographic notes.
	I further certify that I am not a relative, employee,
19	attorney, or counsel of any of the parties, nor am I a
	relative or employee of any of the parties' attorney or
20	counsel connected with the action, nor am I financially
	interested in the action.

22	DATED this ____	day of _____________________, 1997.

 			(signed, 30 july 1997)

		KANABAY COURT REPORTERS - (813) 821-3320