------------------------------------------------------------------- F.A.C.T.Net, Inc. (Fight Against Coercive Tactics Network, Incorporated) a non-profit computer bulletin board and electronic library 601 16th St. #C-217 Golden, Colorado 80401 USA BBS 303 530-1942 FAX 303 530-2950 Office 303 473-0111 This document is part of an electronic lending library and preservational electronic archive. F.A.C.T.Net does not sell documents, it only lends them according to the terms of your library cardholder agreement with F.A.C.T.Net, Inc. ===================================================================== SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES LARRY WOLLERSHEIM, ) GRc,.F. NE.' Plaintiff, ) ) vs. ) No. C332027 ) CHURCH OF SCIENTOLOGY OF CALIFORNIA, ) a corporation; CHURCH OF SCIENTOLOGY ) OF FLORIDA, a corporation; L. RON ) HUBBARD, an individual; CHURCH OF ) SCIENTOLOGY, a corporation; DOES ) 1 through 200, inclusive, ) ) Defendants. ) ) VOLUME 2 DEPOSITION OF ELEANORE FRANCES WOLLERSHEIM, taken by the defendants on Friday, March 30, 1984, at 10:15 a.m., at 1122 Wilshire Boulevard, Los Angeles, CA 90017, before Kery Gillet, CSR No. 3352, notary public for the State of California, pursuant to stipulation. KEDY GILLET, CQ,%D NO. 3~5~ (A Shorthand Reporting Sen/ice) 818 Oneonta Drive IIIIIIIIII II II ~ 213 ~56-4684 INDEX: 2 EXAMINATION BY: PAGE 3 Mr. Kropp 67,1' Ms Schlosser 92 5 6 7 8 EXHIBITS: 9 [No exhibits were marked. ] 10 11 ~12 13 1~ ~ 15 15 17 ~ 18 ORIGINAL TRANSCRIPT OF PROCEEDINGS HELD BY COURT REPORTER 79 I 20 r 21 22 ~ 23 2~ ~25 KERY GILLET. CSR No. 3352 ~:~.1~ IIIIIIIIII ~ s~o~,~ ~o.,~ s~,~ IIII 45 ~ ,,. ~ I APPEARANCES: M 2 3 FOR THE PLAINTIFF: GREENE, O'REILLY, AGNEW & BROILLET BY: LETA SCHLOSSER, ATTORNEY AT LAW I 5 1122 Wilshire Boulevard Los Angeles, CA 90017 I 7 FOR THE DEFENDANTS: 8 ~ TAYLOR, ROTH & NUNT 9 BY: ROBERT KROPP, JR., ATTORNEY AT LA~q 617 South Olive Street, Suite 1100 i 10 Los Angeles, CA 90014 (213) 623-8000 THE WITNESS: ~3 ELEANORE FRANCES WOLLERSHEIM ;5 I ALSO PRESENT: LEE HOLZINGER I .~7 LAWRENCE WOLLERSHEIM, SR. 18 I2O I 22 23 2Z KERY GI LLET. CSR No. 3~52 67 I EXAMINATION (CONTINUED) 2 BY MR. KROPP: 3 Q Mrs. Wollersheim, in the interest -- I'm sorry. ~ Eleanore, in the interest of time, I'm not going to go 5 over all of the discussion we had at the beginning of 6 the deposition where I explained the deposition procedure. 7 Let me just indicate that you're still under oath as you 8 were yesterday; and the same procedures apply. 9 If there's any problem with the way the depositi, 10 goes or my questions go, again, just ask me; and we'll 11 try and clarify it. Okay? 12 A FSne. ;3 Q Have you taken any medication today before the 1~ deposition? ;5 A I've taken my blood-pressure pill at 9:00. 16 Q Okay. Which medication is the blood-pressure 17 pill? 18 A The Diaside. 19 Q Do you know what the dosage is of that medication 20 A No, I do not. 21 Q Are you taking any other medication today? 22 A Not at all. 23 Q Do you know if your son was ever a member of 2~ the armed forces? 25 A No, he wasn't. 68 ~ Q Do you know whether your son ever received 2 a 4F draft classification? 3 MS SCHLOSSER: Objection. Foundation. If he received ~ any draft classification that she's aware of. 5 Q BY MR. KROPP: You don't know what draft c]assifica- 6 tion, if any, he had? 7 A No, I don't. 8 Q Did you ever discuss with your son at any time 9 his view, his opinion, of the draft? ~0 A Yes, I did. ~ Q Do you remember roughly what period of time ~2 that discussion took place in? 13 A No, I don't. ;~ Q Do you know if a discussion took place while ;5 he was attending the university? / A No, I don't. Q Do you remember the essence of the discussion ;8 you had with your son about the draft? I ;9 A Yes, ! do. i 20 Q And what was that? 21 A I -- I 22 MS SCHLOSSER: Object to the use of the word "the 23 draft." I don't know whether you're talking about military I 2~ service or just the specific aspect of military service 25 I that drafts young men. I KERY G[ LLET, CSR No. 3352 Illlllllllt~ s.o.~ ~ .....i~ s .....~ IIII I ~ 69 ; MR. KROPP: Let's see what the answer to the question ~ 2 is; and we'll clarify it if need be. ~ 3 THE WITNESS: He objected to going in. He didn't ~ feel that he wanted to kill. ~ 5 Q BY MR. KROPP: And when he mentioned that to 6 you, did you have any reaction to it? ~ 7 A I had a reaction because my husband was in the 8 service and told him he could have chosen some other - 9 - or talked and chosen something else where he didn't ~0 have to go in and kill. l~ Q Did your son discuss with you any plans or strategy 12 for keeping out of the a~med forces? ~3 MS SCHLOSSER: Objection. You are alluding to facts ;~ that are not on the record. ~5 MR. KROPP: I'm asking a foundational question. 16 MS SCHLOSSER: But you're assuming the facts in the 17 foundational question. ~8 MR. KROPP: I'm not assuming anything. ~9 MS SCHLOSSER: That's my objection. 20 You may answer, Mrs. Wollersheim. 21 THE WITNESS: No. I22 Q BY MR. KROPP: Did your son ever discuss with 23 you any activities he intended to undert'ake to help keep I 2~ him from going into the armed forces? 25 IMS SCHLOSSER: Vague and amgibuous as to time. I KERY GILLET. CSR No. 3352 IIIIIIIIII ~ s.o~,~ ~.~o.,.~ a .....~ I I 7O ; MR. KROPP: At any time. I 2 'PHE WITNESS: No. 3 Q Are you aware of whether your son at any time ~ ran naked through an armed forces induction center? I 5 A Yes. 6 MS SCHLOSSER: Objection. It assumes facts not in J 7 evidence. 8 THE WITNESS: Yes. i 9 Q BY MR. KROPP: And what information do you b I ;0 about that? ~l A From Edie Wollersheim. I12 Q What did Edie Wollersheim tell you? 13 A She and Larry planned this to get him out of I 1~ the draft. I 15 Q What was it she told you that they had planned? ~5 A They were going to do everything in their power I ~7 to convince -- 78 MS SCHLOSSER: No. Mrs. Wollersheim, listen to the ~ 19 question carefully. It's asking for specifically what ~ 20 they planned. 21 Q BY MR. KROPP: I'm asking -- ~ 22 A To avoid the draft. 23 Q And what was it that Edie told you she and Larry I 2Z had planned with regard to Larry and the draft? 25 A I don't know. KERY GILLET. CSR No. 3352 I ~ Q Did she mention so you an!.., plan of Larry's to I 2 run naked through an armed forces induction center? 3 MS SCHLOSSER: Objection. Vague and ambiguous as I ~ to time. I 5 THE WITNESS: i don't know. 5 Q BY MR. KROPP: Did Edie discuss with you any 7 plan that Larry had of running naked in front of a mental 8 health facility? ~ 9 MS SCHLOSSER: Objection. Vague and ambiguous as ~ ~0 to time. ll THE WITNESS: No. Q Did Edie or Lakry ever tell you at any time 13 that Larry had in fact, your son Larry, had in fact run ~ ;Z naked through an armed forces induction center? i 75 MS SCHLOSSER: Objection. Vague and ambiguous as ~5 to time. ~ 17 THE WITNESS: No. 18 Q BY MR. KROPP: Did your son or Edie ever tell ~ 19 you that your son had run naked past a mental health insti- ~ 20 tution at any time? 2~ MS SCHLOSSER: Objection. Vague and ambiguous as ~ 22 to time. 23 THE WITNESS: No. ~ 2~ Q BY MR. KROPP: Do you have any information that ~ S your son ever ran naked past a mental health facility I KERY GILLET. CSR No. 3352 I 72 I at any time? I 2 A No. i 3 Q To your knowledge, has your son ever been arrested? ~ MS SCHLOSSER: Objection. Irrelevant. I 5 THE WITNESS: Not that I recall. 6 Q BY MR. KROPP: Do you have any knowledge that I 7 your son has ever been in a mental institution for any 8 period of time? I 9 MS SCHLOSSER: Objection. Vague and ambiguous ase~ I l0 to what you mean by mental institution and what you mean ~l by any length of time. I 12 THE WITNESS: Hospital. ~3 Q BY MR. KROPP: What information do you have I ;~ about your son being in the hospital? I ~5 A Not any information. 15 Q Has your son ever been in the hospital, to your I17 knowledge? ;8 MS SCHLOSSER: Other than for visits? You're talking I ;9 about his own -- i 20 MR. KROPP: Any hospital at any time. 2~ THE WITNESS: Birth. I 22 Q BY MR. KROPP: Has he ever been admitted to 23 the hospital at any time after he was born? I 2~ A Not that I recall. i 25 Q To your knowledge, did your son ever live at 73 anyplace he called a commune? 2 MS SCHLOSSER: Objection. Vague and ambiguous as 3 to "commune." ~ THE WITNESS: In Scientology. I 5 Q BY MR. KROPP: What Scientology commune did 6 your son live on? 7 MS SCHLOSSER: Same objection. 8 THE WITNESS: Groups of people. I 9 Q BY MR. KROPP: Where? ;0 A California. ~l Q When? ~2 A I don't recall'the date. ~3 Q And did your son at any other time ever tell I ;~ you that he had lived in a living arrangement called a i 15 commune? ~5 A No. I~7 Q Do you have any information that your son ever 78 resided at a location called Children of Aquarius? I ~9 A Yes. I 20 Q What was, to your knowledge, Children of Aquarius? 2~ A A home where he made candles. I 22 Q Was that the farm we'd spoken about earlier? 23 A That's correct. I 24 Q To your knowledge, did your son ever live on 25 a farm in Vermont? J K EI~ Cl LLI~T, Co%E2 No. ]55"2 74 7 A Not to my knowledge. 2 Q Now, yesterday I asked you about occasions on 3 which you had seen you~ son in between the time you visited ~ him for his wedding in Los Angeles and the time that he 5 reEurned home to Milwaukee after leaving the church in 6 about 1979. 7 Now, what's your recollection of how many occasions 8 you saw your son in that time period? 9 MS SCHLOSSER: May I have the question read back. 70 [The last question is read.] ~l THE WITNESS: I don't recall how many times. 72 Q BY MR. KROPP: -Do you know if you saw him on 13 more than one occasion? ;~ A I'm sure I did. ~5 Q Did you see him on any occasion in that time ~6 period at anyplace other than in Milwaukee? 17 A No. 18 Q Do you know at the present time the reason why 19 he was in Milwaukee on the occasions that you saw ~im 20 in this time period? 2; MS SCHLOSSER: Objection. Speculation, foundation. 22 THE WITNESS: I don't remember. 23 Q BY MR. KROPP: Do you recall if he indicated 2~ to you that he was passing through on business? 25 A No, I do not remember. KERY GI LLET. CSR No. 3352 75 m ; Q Do you know if you saw your son in Milwaukee q 2 on more than five occasions in this time period? I 3 A I couldn't give you an honest answer. ~ MS SCHLOSSER: I'd like to interpose an objection. ~ 5 Vague and ambiguous. 6 Are you talking about five occasions at one 7 time or five occasions during the course of those years, 8 or perhaps that he could have visited at two or three I 9 days at a time and would have seen him multiple times 70 during the visit? II MR. KROPP: Five occasions is five occasions, seeing 12 him five times. It seems to me pointless to continue 73 on your purported clarification if the witness can't tell 7~ me anything about how many times she saw him. 75 MR. SCHLOSSER: I'd like to keep the record clear, ~6 Mr. Kropp. My objection is it's vague and ambiguous for I 17 the reason I have explained. And you've just answered ~8 the question in such a way as to make it obvious that I 79 my objection was well taken. I 20 Q BY MR. KROPP: On any of the occasions when 2; you saw your son in this time period we're talking about, I 22 did you and he ever talk about Scientology? 23 A Not that I recall. I 2~ Q At any time after your son left Scientology 25 iand returned to live with you in Milwaukee, did you and I KERY GI LLET. CSR No. 3352 76 your son ever talk about Scientology? I A Yt:~s-, we did. ~ 2 Q Do 'you remember anything that your son said about 3 ~ Scientolog3' on those occasions? 4 MS SCHLOSSER: You're Talking about after he left ~ 5 or broke with the Church of Scientoiogy? 6 MR. KROPP: That's what my question was. That's ~ 7 correct. 8 ~ THE WITNESS: That he finally made me very happy 9 about. getting out. 10 Q Is there anything else your son told you about If his experiences with Scientology while he was involved 12 in Scientology after he'd left? 13 MS SCHLOSSER: Objection. You're asking the witness 14 to distill something that occurred over the course of 15 time a number of years ago. 16 MR. KROPP: That's correct. 17 MS SCHLOSSER: If you asked her specific questions 18 about it, I think you'd get a much more accurate picture 19 of what she recalled. 20 THE WITNESS: I don't remember. 21 ~ 22 Q BY MR. KROPP: You don't remember anything that your son told you about his experiences with Scientology 23 ~ after he had left Scientology; is that your testimony? 2~ 25 MS SCHLOSSER: Please interpose my same objection. ~[~ KERYGILLET. CSRNo, 3352 IIIIIIIIII r~s .......~,~,,,o,,,.~s ...... IIII I THE WITNESS: Ne was unhappy with it. 2 O BY HA. KROPP: Why did he say he was unhappy ~ 3 with Scientology? ~ A He found the life wasn't as good as he expected I 5 it to be. 6 Q What did he find about the life that wasn't 7 as good as he expected it to be? 8 A I don't know. I 9 Q Did he say an}7thing about why the life wasn't I 70 the way he expected it to be to you? II A No, he didn't. I12 Q Is there anything else your son said to you ;3 about his experiences in Scientology after he left Scientology [ ;~ that you can recall today? [ ~5 MS SCHLOSSER: You're changing the question. You ~6 spoke about him originally coming back to Milwaukee after he broke with Scientology, in that time period. You're ~8 now making it a broader time period? [ 79 MR. KROPP: Would you p16ase go back and reread my ~ 20 last four questions. 2~ [The record is read.] 22 MS SCHLOSSER: I'd like to state for the record that 23 you prefaced this line of questioning with the conversation 2~ or directing the witness to the time period directly after ~ the plaintiff left Scientology and returned to Milwaukee. KERY GILLET. CSR No. 3352 IIIIIIIIII ,~ s~o,,~.~ '~o,,,~ s ..... ~ I 78 I And you have changed the ambit of your question to a much 2 broader time period now. And i'm not sure that is totally i 3 clear on the record or totally clear to the witness. ~ MR. KROPP: I'm glad ~hat you finally have understood I 5 that I broadened the ambit of my question and that I will 5 repeat the last question I asked to the witness. ~ 7 MS SCHLOSSER: Well, it's not going to cure the defect ~ 8 in the record or make it any clearer. 9 MR. KROPP: Counsel, there's no defect, I believe, I ;0 in the record. There is perhaps a defect in your understanding II and recall of the line of questioning. But I think the I ;2 record speaks for itselF. 13 MS SCHLOSSER: I'd also like to object at this time I 1~ to the fact that the witness told me yesterday after the I 15 conclusion of yesterday's session of this deposition that 16 she found your jumping around in time periods confusing. I17 And again you're going to have to make a more complete 78 statement about a particular time period instead of jumping [ 19 back and forth as you did yesterday through about five ~ 20 " t~me periods within a very short number of minutes. 27 You're going to have a very unclear record. ~ 22 But that's -- 23 MR. KROPP: You've made your statement for the record. [ 2~ Q I will repeat to you, Eleanore, that if any [ ~ question I ask of you is unclear, I am requesting that KEPY GI LLET. Cc$17 NO. 3352 I 77 ~ you ask me to rephrase the question. I have no desire 2 to get an answer which doesn't fit with the question that 3 I asked; and I have no desire to confuse you. L As you can see, your son's counsel has no reluctance 5 to intercede objections and to make comment on my questions. 6 And you should feel no greater reluctance than she does 7 to indicate if there's any problem with the question that 8 I've asked you. 9 Now, could we go back to the last question I ;0 asked before we began this interchange. ~l [The question at Page 14, Line 12 ;2 is read.] ;3 MS SCHLOSSER: That question goes to any time after ;L Larry, Jr., left Scientology. 15 Q BY MR. KROPP: That was exactly the question; ~6 that's right. 77 A He was very unhappy with it. 78 Q What did he say to you about why he was unhappy 79 about his time in Scientology? 20 A It was not what he had expected of Scientology. 21 Q Did he indicate to you what he had expected 22 of Scientology? 23 A That it would do all the things that they told 2~ him it would do for him. 25 Q Did your son tell you what Scientology had told KEPY GILLET. C&I:2 No. 3352 I ~ him it would do for him? ~ 2 MS SCHLOSSER: Objection. You already went through 3 some testimony yesterday. Other than what she testified I ~ to yesterday? B 5 MR. KROPP: Anything. 6 THE WITNESS: Success. Better person. B 7 Q BY MR. KROPP: Is there anything else that your a son told you Scientology would do for him aside from giving I 9 him success and making him a better person that he felt I 10 Scientology had not accomplished for him? 11 MS SCHLOSSER: Again, including what she mentioned I~2 yesterday, where she sp'oke about IQ points and specific 13 representations yesterday? I 1~ THE WITNESS: No. I 15 Q BY MR. KROPP: Is there anything else that your ;6 son mentioned to you after he left Scientology about his I 17 experiences with Scientology that made him unhappy? 18 A No. I 79 Q Can you describe for me what-your son's personality i 2D was like when he returned to your house in Milwaukee immedi- 21 ately after leaving Scientology? I 22 MS SCHLOSSER: Objection. Assumes facts not in evidence. 23 THE WITNESS: Cold. I 2~ Q BY MR. KROPP: Anything else you can describe i about him? KERY GI LLET. CSR No. 3352 81 I A Not caring. 2 Q Anything else? 2 A No. ~ Q Has your son at any time ever spoken with you 5 about a business called Beautiful Pictures, Beautiful 5 Gifts? 7 A Not that I recall. 8 Q You don't recall ever at any time having any 9 discussion with your son about Beautiful Pictures, Beautiful r 10 Gifts? 1; A I knew that he was in the business. 12 Q How did you know he was in the business? ~ 13 A Well, he -- he talked about going into that 1L business. ~ 15 Q Did he talk to you about the business after 15 he was in the business? p 17 A That's correct. 18 Q What did he say to you about the business after 19 it was in operation? 20 A That it was going to be a very successful and 21 a good business. 22 Q What sort of a business was ~eautiful Pictures, 23 Beautiful Gifts? 2Z A Sold pictures to various people, companies. 25 Q Did your son ever tell you anything else about KERY GILLET, CSR No. 3352 I 82 I Beautiful Pictures, Beautiful Gifts aside from what you've I 2 told me now? 3 A blot that I know of. I ~ Q Do you know if in the late spring, early summer I 5 of 1976 there was a family reunion in Milwaukee for your 6 mother? 7 A We had many family reunions. I don't recall 8 any specific one. I 9 Q Was there any specific reumion that you recall I ;0 for your mother's 80th birthday? 11 A That I recall. 12 Q Do you recall what month your mother's 80th 13 birthday was in? I~ A Yes, I do. i 15 Q What month was that? 16 A July. 17' Q And was your mother's 80th birthday in 19767 18 A Let's see. I have to think. I 19 Q Okay.,. i 20 A That would be the year. 21 Q Do you recall what day in July of 1976 to '80 22 the birthday reunion was? 23 A July 6th. 2~ Q Do you recall if your son was present at the 25 reunion? KERY GILLET. CSR No. 3352 IIIIIIIIII ~ sno~,~ ~o~.~ s ...... II II I 7 A He was the only one that wasn't present. i 2 Q Do you recall if at any time before the reunion i 3 took place you in any way communicated to your son that 4 a reunion was going to be taking place? I 5 A I did. 6 Q How did you communicate that to him? I7 A I wanted him to make his grandmother's 80th 8 birthday. I 9 Q What vehicle of communication did you use? I 70 Did you tell him in person, telephone, letter? 11 A I wanted him to come to my mother's birthday I12 because I knew she was ikl. 13 Q You want to take a break for just a minute, I 14 Eleanore? I 15 A I would like to. 16 MS SCHLOSSER: Let the record reflect that Mrs. I 17 Wollersheim is quite upset, on the verge of tears. 18 [A brief recess is taken.] I 19 [The question at Line 9 is read.] I 20 Q BY MR. KROPP: Let me ask a new question. 21 I'll move to strike the last two responses to my last ~ 22 two questions as being nonresponsive. I'll ask a new 23 question. ~ 2~ Eleanore, how did you communicate to your son 25 your interest in having him come to your mother's 80th KERY GILLET, CSR No. 3352 IIIIIIIIII ,~ s.o.,~.~ ~o,,,.~ s ..... ~ IIII I I I birthday reunion? 2 A I didn't. My thusband communicated with him. 3 Q Do you know how your husband communicated with ~ your son on that? 5 A Telephone. 5 Q Were you present when the telephone call took 7 place? 8 A No, I was not. 9 Q Did your husband tell you the result of that 10 telephone conversation or what Larry's response was to 11 that telephone conversation? 12 A He said that he would try to get to Grandma's 13 reunion -- I mean birthday party. 1~ Q Did your son at any time ever give you any indication 15_ of why he didn't come to the birthday party reunion? 16 A No, he didn't. 17 Q Have you ever read a publication called The 18 Scandal of Scientology? 19 A No, I haven't. 20 Q Have you ever heard of that book? 21 A No, I haven't. 22 Q Have you ever heard of an individual named Eddie 23 Waltors? 2~ A No, I haven't. 25 Q Have you ever heard of an individual named Dr. KERY GI LLET, CSR No. 3352 85 ; David Hutchison? 2 A No, I haven't. 3 Q Have you ever heard of an attorney named Michael ~ Flynn? 5 A No, I haven't. 6 Q What understanding do you have at the present 7 time, if any, regarding the beliefs and practices of Scien- 8 tology? 9 MS SCHLOSSER: Objection. Overbroad, vague and ambi- 10 guous. Lack of foundation. 71 THE WITNESS: I don't know. ;2 Q BY MR. KROPP: As you sit here today, do you ~3 have any knowledge of any practice or belief of Scientology? ;~ MS SCHLOSSER: Same objections. You're asking her ~5 to distill a course of many years. You're not giving 16 her any specific references. ~7 MR. KROPP: That's correct. ~8 THE WITNESS: I don't know. ~9 Q BY MR. KROPP: Do you have any knowledge of 2O any statements made to your son at any time that Scientology 21 would make him a more stable, confident, healthy, or pro- 22 ductlye member of society? 23 MS SCHLOSSER: Objection. Compound. Foundation. 2~ THE WITNESS: Yes. Q BY MR. KROPP: Okay. What information do you KERY GI LLET, CSR No. 3352 86 ~ I have regarding that? I 2 A That he -- that they would do that. ~ 3 Q Your son told you that someone had made such ~ a representation to him? ~ 5 A Uh-huh. 6 Q Was that yes? ~ 7 A Yes. 8 Q When did your son tell you that? ~ 9 A I don't recall. 10 Q Did your son tell you who had made such represen- 11 tations to him? 12 A No, he didn't_. 13 Q Did your son tell you where he was when such I~ representations were made to him? 15 A No, he didn't. 16 Q Did.your son ever tell you that he had ever 17 been told that Scientology would speed the recovery from 18 diseases? 19 A I don't recall. 20 Q Do you recall if your son ever told you that 21 he was ever told that Scientotogy would cause the decline 22 of body disfunctions such as pain? 23 A I don't recall. 2~ Q Just so you're clear on what I'm asking you, 25 I'm asking you if you recall your son telling you that KERY GI LLET. CSR No. 3352 87 ; he was told this by someone else. 2 A I understand fully. 3 Q Okay. Good. ~ Has your son, to your knowledge, ever referred 5 to a Scientology term of Level 17 5 A I don't recall. 7 MS SCHLOSSER: I'd like to interpose an objection. 8 Assumes facts not in evidence. I move to strike the answe: 9 to do so. ~O Q B~/MR. KROPP: Now, earlier you testified that 7~ your son told you he was unhappy about Scientology because 12 he was told that Scientol'ogy could raise his IQ or that ~3 Scientology could make him a success. ~ Did your son ever tell you how he came to learn 15 that these representations were untrue? 15 MS SCHLOSSER: Objection. Argumentative. f7 THE WITNESS: I don't know. ~8 Q BY MR. KROPP: Did your son at any time ever ~9 tell you that anything happened to him in September or 20 October of 1979 that affected his view of his involvement 2~ in Scientology? 22 MS SCHLOSSER: Objection. Vague and ambiguous. 23 THE WITNESS: No, he didn't. 2~ Q BY MR. KROPP: Did your son at any time ever 75 tell you that he believed that Scientology counselling, KERY GI LLET, CSR No. 3352 IIIIIIIIII ~ s~o,,~.~ r~o,,,.~ s ..... I auditing, or programming were dangerous? 2 A He kept a lot of Ehings away from me because 3 of my physical health. ~ Q' Do you have any recollection of your son ever 5 telling you that he believed that Scientology counselling, 6 auditing, or programming were dangerous? 7 A I don't recall. 8 Q Did your son ever use a term that he indicated 9 was a Scientology term known as disconnect? 10 A I'm not familiar. 11 Q Did your son ever tell you that he was told 12 by anyone to disconnect With you? 13 A No. ;~ Q Did your son ever tell you that he was told 15 by anyone to disconnect with your husband? 15 A No. 17 Q Did your son ever tell you that he was told 18 by anyone else to disconnect from Edie? 19 MS SCHLOSSER: Object to the last few questions. 20 You continually use the term instead of the meaning behind 21 the term even though she indicates no particular knowledge 22 of the term. 23 MR. KROPP: I'm using the term because that's precisely 2Z what I want to do. 25 MS SCHLOSSER: That's your choice, Mr. Kropp. KERY GI LLET, CSR No. 3352 s9 MR. KROPP: 'Phat's correct. 2 'PHE WITNESS: No. 3 Q BY MR. KROPP: Did your son at any time ever I ~ tell you that he t~ad been told by anyone not to have any 5 further dealings with you? 6 A Not that I recall. 7 Q Did your son at any time ever tell you that 8 he had been told by anyone else to have no further dealings 9 and to cut himself off from his father? 70 A Not that I recall. ;~ O Did your son ever tell you at any time that 72 he had been told by anyone else to have no further contact ~ 13 with Edie and to cut himself off from Edie? . ;~ A My son didn't tell me, but Edie told me. 75 Q What did Edie tell you? 16 A That they separated the two of them when they 7Z were in California. ;8 Q That who had separated the two of them? ~9 A Scientology did. 2Z2 Q And did Edie ever tell you if she was told why 2~ the two of them were separated? 22 MS SCHLOSSER: Objection. Vague and ambiguous as 23 to time and foundation. 2~ THE WITNESS: She told me that they didn't like people 2~ being married. K ERY GI LLET. CSR No. 3352 90 ~ I Q BY MR. KROPP: Did Edie ever tell you who told ~ 2 her this? 3 A I don't recall. W~ Q' Has your son at any conversation he's ever had I 5 with you referred to something called Fair Game Doctrine? 5 A I don't recall. 7 Q In any conversation you-ever had with your son, 8 has he ever referred to a term suppresslye person, to 9 your knowledge and recollection at the present time? 10 A I don't recall. 11 Q Did your son ever tell you that Scientology 12 ever destroyed any business of your son's? 13 A Not that I recall. lZ. Q Did your son ever tell you that Scientology 15 o~ any Scientologist had ever adversely or negatively ~6 affected any business of you~ son's? 17 A Not that I recall. 18 MR. KROPP: Let me go off the record for a minute 19 or two. 20 [A brief recess is taken.] 21 MR. KROPP: Okay. Back on the record. I 22 Q To your knowledge, has your son ever sought 23 the assistance of any psychiatrist? I 2Z MS SCHLOSSER: Objection. Foundation. I 25 THE WITNESS: Not that I recall. I KEI~'~' GILLET. C~I~ No. 335V. 91 7 Q BY MR. KROPp: To your knowledge, has your son 2 ever sought the assistance of any psychologist? 3 MS SCHLOSSER: Same objection. ~ THE WITNESS: Not that I recall. 5 Q BY MR. KP, OPP: To your knowledge, has your 6 son ever used the services of any mental health professional? 7 MS SCHLOSSER: Objection. Vague and ambiguous -- 8 THE WITNESS: I don't know. 9 MS SCHLOSSER: -- as to mental health -- 10 What was the term that you used? Mental health...? 11 MR. KROPP: Professional. 12 MS SCHLOSSER: Professional. 13 And foundation. 1~ THE WITNESS: I don't know. 15 Q BY MR. KROPP: Do you have within your possession, ~6 not at the present time, but in Milwaukee, any letters your son has ever written to you? MS SCHLOSSER: Objection. You asked for a specific 19 place; and I thought you weren't going to do that. 2O MR. KROPP: That was just one location where I asked 21 where something might be. 22 MS SCHLOSSE~: Well, why don't you remove that. 23 MR. K~OPP: Okay. That's fine. Let me rephrase 2~ the question. Q Do you have anywhere in your possession, custody, KERY GI LLET. CSR No. 3352 1111111111 ~A s~o,,~.~ ~o,,,~ I I or control any letters that your son has ever written I 2 to you? m 3 MS SCHLOSSER: Objection. Calls for a legal conclusion. ~ THE WITNESS: A lot of cards and a lot of letters. i 5 Q BY MR. KROPP: Do you have any cards and letters 6 that your son wrote to you in the period of 1970 to 19797 I 7 A I'm sure I have. i 8 Q Now, I'm not sure if this is something you and 9 I went over at the beginning of the deposition; but one I 10 of the agreements that your son's counsel made with my 11 office in taking your deposition was that I was not at I 12 any time going to ask you where you lived. 13 You were made available here at your son's counsel's I 14 office for this deposition. And I'm not going to ask I 15 you where you live. 16 However, what I do want to ask y, ou-is: The I 17 cards and letters that you believe you 'have from your 18 son, would those cards and letters be at your house? I 19 A I'm sure they are. i 20 Q Okay. 21 I have no further questions. ~ 22 23 EXMINATION ~ 2~ BY MS SCHLOSSER: ~ 25 Q Mrs. Wollersheim, at some point in time, were KERY GI LLET. CSR No. 3352 I 93 you asked by your son to undergo auditing? 2 A Uh-huh. 3 Q And you understand auditing is a Scientology m ~ term of a type of programming -- I 5 A Uh-huh. 5 Q -- that they engage in? I 7 A Uh-huh. 8 Q Where did you undergo that auditing? I 9 A Curiosity. I 70 Q Not why. Where. 77 A In California. I72 Q In Los Angeles? 73 A Uh-huh. I I~ Q Which one of the Scientology centers do you I 75 recall going to? 75 A I don't recall. I 77 Q For how long had Larry been after you to undergo 18 the auditing? I 79 MR. KROPP: Objection. Mischaracterizes the witness's i 20 testimony that Larry had ever been after her to undergo 21 auditing. I 22 THE WITNESS: When we went out to the wedding. 23 Q BY MS SCHLOSSER: Did your son ask you numerous I 2~ times to undergo that auditing on that occasion when you ~ 25 came out to Los Angeles for the ceremony? KEI~Y CI LLET. Ce%l~ No. 94 I A He did. 2 Q Would you say that he pushed you toward auditing? 3 A Yes, I would. I ~ Q Would you say that he was wrapped up in Scientology I 5 at the time -- 6 MR. KROPP: Objection. Vague and ambiguous as to I7 what's meant by "wrapped up." 8 Q BY MS SCHLOSSER: -- that he repeatedly asked I 9 you to undergo the auditing? I 10 A He did. 11 Q Did Scientology and the auditing process used I12 in Scientology at the time you came out to Los Angeles 13 for this ceremony occupy a great deal of his conversation? I I~ A No. I 15 Q Would you describe the way he looked and acted 16 when he spoke about you undergoing the auditing. I 17 A He wanted me to go to -- into auditing to find 18 out what it was all about. I ;9 MR. KROPP: Objection. Motion to strike as nonresponsive. i 20 Q BY MS SCHLOSSER: Can you describe the way he 21 looked and acted about the whole subject of you undergoing 22 auditing. 23 A Very serious. 24 Q Did you find him staring at you a great deal 25 at the time you came out to that ceremony in Los Angeles? KERY GILLET. CSR No. 3352 I 95 A Yes, he did. 2 Q Did that make yolJ uncomfortable? 3 A Vet}, uncomfortable. I Z O For how long had he engaged in that staring 5 behavior with you before you came out to the wedding? 6 MR. KROPP: Objection. Vague and ambiguous as to I7 what's meant by staring behavior. 8 THE WITNESS: Many times. I 9 Q BY MS SCHLOSSER: Can you describe his staring I 70 at you any more specifically than staring at you a great ;1 deal? I12 A Not really. ~3 Q So you're comfortable with my use of that? I ;~ A Uh-huh. i ~5 Q Had you noticed him staring at any other indivi- ~5 duals at that time or before that time? I ~7 A His wife. ;8 Q Edie? I 19 A Correct. ~ 20 Q Anyone else? 27 A His father. ~ 22 Q Was there something unusual about the staring? 23 A It wasn't my son. ~ 2~ Q At the time did you attribute it to Scientology 25 and Scientology's influence on him? KERY GI LLET, CSR No. 3352 fi 96 ; MR. KROPP: Objection. Vague as to when. This apparently fi 2 was a course of conduct which existed over a course of 3 time. fi ~ THE WITNESS: Yes, I did. fi 5 Q BY MS SCHLOSSER: And for how long before you 6 came out to Los Angeles for that ceremony had you attributed fi 7 this unusual staring behavior pattern of Larry's to his 8 involvement with Scientology? fi 9 A I don't recall that. ~ ;0 Q Did you find your auditing experience with Scientology 1; upsetting? ~ ;2 A Very. 13 Q You mentioned earlier that they asked you questions I 1~ about your childhood and about your family life and your i 15 relationships with the people who are most intimate to 15 you. I 17 MR. KROPP: Objection. Vague and ambiguous as to 18 what's meant by "they." I 19 Q BY MS SCHLOSSER: You mentioned earlier that 20 the Scientologist who was conducting the auditing that O 21 you underwent on this one occasion asked you numerous I 22 questions about your early childhood and your relationship 23 with the people who were most intimate to you. I 2~ Did they repeatedly ask the same question about 25 those intimate areas of your life? KERY GILLET. CSR No. 3352 I | 97 ~ MR. KROPP: Objection. Vague and ambiguous since t 2 you're referring to a single auditor; and now you've gone 3 back to referring to they. I ~ THE WITNESS: Over and over. I 5 Q BY MS SCHLOSSER: Was it one individual who 6 questioned you? I7 A One individual. 8 {} When you say over and over, did they repeat I 9 the same question over and over? I ;0 A Correct. ;~ Q How did the individual act toward you while I ~2 questioning you? 73 A Puzzled. 7~ Q A puzzled look on the person's face? ~5 A Uh-huh. ~6 Q Is that a yes? 77 A Yes. ;8 Q Were they searching your face for a response? ;9 A I'm sure. ~ Q Do you remember the person looking at you very 2~ intensely? 22 A Staring. 23 Q Was it a similar stare to the way Larry stared? 2~ A Yes, it was. ~ E Q Did you feel that you were being interrogated? KERY GI LLET, CSR No. 3352 4. ~ m 98 ; A Yes. I 2 Q Since you had that experience, have you thought 3 of it many times? ~ A' Yes, I have. 5 Q Has it upset you when you thought of it? 5 A Yes, i't has. I 7 MR. KROPP: I would object to this line of inquiry 8 as not being calculated to lead to the discovery of admissible i 9 evidence. i 10 MS SCHLOSSER: I thought you were interested 11 in what information she had about Sciento!ogy, Mr. Kropp. I 12 MR. KROPP: Indeed t am, but I don't understand any ;3 relation between the witness's emotional reactions to I I~ an experience and the allegations in the second amended I 15 Complaint. 16 MS SCHLOSSER: Yesterday you were interested in personal I;7 knowledge of Mr. Wollersheim. I'm surprised you didn't 18 ask about the personal knowledge of Mrs. Wollersheim in I 19 this regard. i 20 Q At the time you underwent this experience and 21 when you thought about it since, was it your belief and I 22 still your belief that they were attempting to find a 23 handle on you during that auditing? ~ 2Z MR. KROPP: Objection. Vague as to when -- ~ 25 THE WITNESS: Yes. KE1)YGILLET. C&R No. 3352 I 99 MR. KROPP: -- and what is meant by "handle." 2 Q BY MS SCHLOSSER: When I use the term "a handle 3 on you," can you explain how you understand that. ~ ~ A- I would take that as unhappiness and control ~ 5 with the family. 6 Q It was you~ understanding that the auditor dealing ~ 7 with you was attempting to find an area of your life which 8 would give him. control? 9 A Uh-huh. 10 Q Is that a yes? 11 A Yes. 12 Q And is that still your opinion today? 13 A Yes, it is. I~ Q And you base that opinion on the fact of the 15 way he behaved with you? 15 A Yes,. 17 Q On the fact of the type of questions he asked? 18 A Yes. 19 Q On the way he continually repeated the same 20 questions? 2~ A Yes. ~ 22 Q And the fact that he was dealing in intimate 23 areas of your life? 24 A Correct. 25 Q Anything else? I KERY GI LLET. CSR No. ~352 IIIIIIIIII,A s~ ......~ ,~.,,o~,,.~ s ....., IIII . ~ 100 I A No. ~ 2 Q Have you ever had auditing done again? 3 A Never. ~ ~ Q' Have you made any effort to have auditing again? ~ 5 A No, I haven't. 6 Q When was the last time you saw Larry? ~ 7 A A month ago. 8 Q Could you describe his personality for us a i 9 month ago. I ;0 A Beautiful. Warm, back to the family. 11 Q Was he energetic? I12 A Very. 13 Q Enthusiastic? I 1~ A Very. I 15 Q Looking to the future? 15 A Very much so. I 17 Q Was he compassionate about family members? 18 A Very much so. I 19 Q Did he engage in any of the staring behavior i 20 that you mentioned earlier? 21 A None at all. I 22 Q You just mentioned that you considered him to 23 be back tothe family; however, he does not live in the I 2~ same town as you and his father live, does he? i 25 A No, he doesn't. I KEDY Gl LLET, Cc~D No. 3352 101 7 Q You meant that in a psychological sense? 2 A That's correct. 2 Q From your experience in auditing, is it your opinic ~ that Scientotogy is dangerous? 5 MR. KROPP: Objection. Lack of foundation, this 6 witness has any ability from one experience to draw any 7 conclusions as to whether any technique is dangerous or 8 not. 9 THE WITNESS: Very dangerous. 10 Q BY MS SCHLOSSER: Why do you say that based 11 upon your own experience? 12 MR. KROPP: Same-objection. 13 THE WITNESS: Because they dwell into personal families 1~ and are seeking for things that are unhappy in your life. 15 Q BY MS SCHLOSSER: And in your opinion, why are 15 they seeking things that are unhappy in your life? 17 A Because they can probably -- my analysis, that 18 they would be able to make your life a lot better in being i 19 in Scientology. 20 Q I'[n sorry. I don't think that was clear, Mrs. 2V Wollersheim. Could you explain to us why you think they ~ 22 are looking for a means of controlling an individual through 23 the auditing -- 2~ MR. KROPP: Objection. Calls for speculation. 25 Q BY MS SCHLOSSER: -- from your experience, now? KERY GI LLET, CSR No. 3352 102 ~ MR. KROPP: Same objection. Calls for speculation. 2 THE WITNESS: I don't know that. 3 MS SCHLOSSER: Could I have my next-to-the-last qu~stic 4 read back. 5 [The question at Page 101, Line 15 6 is read.] 7 THE WITNESS: I really don't know why they're seeking 8 that. 9 Q BY MS SCHLOSSER: But you felt that they were l0 probing into areas of your life that were intimate looking II for some sort of a handle on you? 12 A Uh-huh. ~3 Q Is that a yes? ;4 A Yes. ;5 Q When I use the term "looking for a handle on ;6 you," do you understand that I mean looking for a means ~7 to control? ~8 A Uh-huh. ;9 Q Yes? A Yes. 21 MS SCHLOSSER: For the record, the reason I'm saying 22 "yes" is because Mrs. Wollersheim has just responded severaS 23 times withan uh-huh. 2~ MR. KROPP: It's not the way we're used to talking 25 in everyday life. KERY GILLET, CSR No, 3352 I 103 I Q BY MS SCHLOSSER: At some point in time, did ~ 2 you and your husband take into your home Edie Wollersheim 3 and her son? M 4 A' Yes, I did. I 5 Q Was there a particular purpose in your taking 6 the two of them in? 7 A They were bottn physically and mentally ill. 8 MR. KROPP: Objection. Move to strike the response. I 9 The question calls for a yes or no response. ~ 10 Q BY MS SCHLOSSER: There was a purpose behind 11 taking them in? A That's correct-, 13 Q And the purpose behind taking them in was they ~ ;~ both needed your help because they were physically and I 15 mentally ill? 16 A That's correct. ~ 17 Q And for how long did Edie and Buff live with 18 you? 19 A Between nine months to.a year. 20 Q And where did the two of them come from b~~nre 21 ~~ I 22 A California. 23 Q -- living with you? I 2~ A L.A. I 25 Q Did Edie mention to you what they were doing I KERY GI LLET, CSR No. 3352 IIIIIIIIII r~ s~o~,~ ~.,,o,,,.~ s ..... I 104 I in Los Angeles just before they came? 2 A She was in the hospital. 2 Q Did she mention to you where Buff was directly ~ before'them coming out to you? 5 A Some home for children. 6 Q Was it a Scientology home? 7 A That's correct. 8 MR. KROPP: Let me interpose my objection that it's 9 vague and ambiguous as to what's meant by. a Scientology ~ 10 home. ~1 Q BY MS SCHLOSSER: Did Edie tell you when she 12 came to live with you that she and her son had been living 13 in a Scientology house or community house just before 1~ she went into the hospital? 15 A Correct. 15 Q And will you understand from this point on that 17 my Use of Scientology house is meant to refer to that 18 building that Edie told you about when she came to live 19 with you and your husband? 20 A Yes. 21 Q Why did Edie say that she had been in the hospital 22 directly before coming out to stay with you? 23 MR. KROPP: Since I anticipate it'~ going to'be a' m 2Z. long line of questionihg, let me just at this point make 25 what will be a continuing objection as to this line of K ERY GI LLET. CSR No. 3352 IIIIIIIIII ~ s ....... ~ ~o~,,.~ s 105 ; inquiry being beyond tbe scope of direct examination and 2 not calculated to lead to the discovery of admissible 3 evidence. ~ MS SCHLOSSER: Could ! have the question read back 5 and if there was an answer. [The question at Page 104, Line 21 i7 is read.] 8 THE WITNESS: Burned. m 9 Q BY MS SCHLOSSER: Was she badly burned? i 10 A Very badly burned. 11 Q Were you able to see the results of her burns 12 yourself when she got there? 13 A Yes, I was-. ~ 1~ Q Did Edie tell you that, while she was in Los ~ 15 Angeles, that all the time that she was out here with ;6 your grandson that she had lived at the Scientology house ~ 17 and had worked for the Chu'rch. of Scientology? ;8 A Yes. ~ 19 Q Did she mention to you that she had worked for 20 the Church of Scientology of California? ~ 21 A Yes, she did. ~ 22 Q Did she tellyou that, between the time of the 23 ceremony that you and your husband came out for in Los ~ 2~ Angeles and the time that she was burned, that Larry no 25 m longer lived at the Scientology house with she and Buff? KERY GI LLET. CSR No. 3352 Illlllllll r~ s~ ......d ~,~o~,,~ s ...... II II ~ 106 I A Correct. ~ 2 Q Now, when I use the term "she told you after ~ 3 she came out to live with you and your husband," what 4 I'm speaking of is just that nine-months-to-one-year time. ~ 5 A That's correct. 6 Q Do you have a recollection of that nine-months- ~ 7 to-One-year time that you and your husband took her into 8 your home with your grandson being in 19747 ~ 9 A I would say around that time. l0 Q Did she tell you then that she had been badly ~ burned on the premises of the Scientology house? ~ 12 A She did. ~3 Q Did she tell you that Larry had been living I ~ on a Scientology boat for the last -- I ~5 A A ship. ~6 Q -- three weeks To a month before she was burned? I~7 MR. KROPP: Objection. Vague and ambiguous as to 18 what's meant by a Scientology boat. I ;9 THE WITNESS: Ship. i 20 MS SCHLOSSER: Ship. Okay. 2V Q Did she tell you that it was a ship that belonged I 22 to the Church of Scientology? 23 A She did. ~ 2~ Q When you got to see her and Buff when they arrived ~ 25 back in Milwaukee, can you describe Buff's physical appearance. i i 107 A Pale, thin, unkept. 2 Q Did he have any boils or scabs or anything unusual 3 or his skin? 4 A' Scabs all over his mouth, sores on his rectum. 5 Q Anything else? 6 A Are you referring to Edie? 7 Q No. Just to Buff right now. 8 A That was about all. 9 Q Did he seem to be nervous to you? ~0 A I would say he was nervous. ~ Q Emotionally upset? 12 A Emotionally [nods head]. And he clung onto ! 13 his mother. ~ Q He was about three years old at the start of ~5 this period, wasn't he? ~6 A Or two and a half. ~7 Q Was there any medical treatment given to Buff? 18 A Yes, there was. 19 Q What was that? 20 A Edie's doctor prescribed something for his sores. 2; Q Some sort of ointment or salve? 22 A Or some medication. I don't recall. 23 Q And did you take care of him yourself? 2~ A Yes, I did. 25 Q How long did it take before his condition cleared KERY GI LLET, CSR No. 3352 ~ 108 1 up, if it did? ~ 2 A Oh, about two weeks. 3 Q Did the doctor tell you what had caused the ~ ~ sores and the scabs on your grandson? I 5 A I didn't communicate with the doctor. Edie 6 did. I don't know. I7 Q Did Edie describe to you, then, when she was 8 living with you that it was difficult for her to get Buff I 9 out of the Scientology house to bring him to Milwaukee? I ;0 A She did. II Q Could you describe to us what she told you. I;2 A She had to get-either a sheriff or a policeman ;3 to go with her to get him out of the house. I 1~ Q Did she describe why it was necessaryto do i 15 that? 16 A No, she didn't. She needed help. I 17 Q Did she describe why she needed help? 18 A No, she didn't. I ;9 Q Did she tell you that Scientology people at 20 the house would not release Buff? I 2~ A She did. ~ 22 Q And that was why she needed the local Los Angeles 23 authorities to get Buff back? ~ 2~ A Uh-huh. And fear. 25 Q Did she describe her financial condition to KERY GILLET. CSR No. 3352 109 1 you at the time of the burn incident? 2 A Yes, she did. 3 Q And what did she say? ~ A' She had some money hid somewhere in the commune 5 and was able to make all the calls, the necessary calls, 6 because she had no money at all. 7 Q Necessary calls for what? 8 A Calls to the hospital to talk to the nurse and 9 calls to the sheriff's department or the police department. 10 I don't recall which one it was but either one of them. Q And that she had to make these calls once she ;2 made the decision to come to Milwaukee? 13 A Correct. I ;~ Q In the course of your conversations with her I ~5 during the time she lived with you and your husband, did 15 she tell you how much an hour she had been making with m 17 the Church of Scientology of California? 18 A My recollection was 25 cents an hour. 19 Q And in exchange for the 25 cents an hour she 2D worked -- 2~ A She was to get board and room.' 22 Q At the Scientology house? 23 A At the Scientology house. ~ 2~ Q Anything else? Did she get services from them 25 m such as auditing? KERY GILLET. CSR No. 3352 IIIIIIIIIIr~, s~o,,~ ~.~o,,,.~ s ...... ~ ~s~.~ ~ 110 I A I don't recall that. I think she paid for the I 2 auditing. 3 Q How did you first learn about the burn incident? ~ z A The call from L.A. The nurse called my husband. I 5 Q There was a nurse? 5 A At the hospital. They called my husband direct. 7 Q Was that County USC Medical Center? 8 A I don't recall because they talked to Larry. I 9 Q And the nurse asked you to take Edie into your I ~0 home? ~ A Correct. ~2 Q Did you speak fo Edie directly at that time? 13 A No, I didn't. 14 Q Did your husband that you're aware of? 15 A Not that I recall. ;6 Q So your dealings were through the nurse at that ~7 time? ;8 A He dealt mostly with the nurse. ;9 Q Did the nurse tell you that Edie was listed 20 as a charity case at the hospital? 2; A Not that I recall. 22 Q Did she tell you that no one in Los Angeles 23 would take Edie in for her care? 24 MR. KROPP: Objection. Lack of foundation. The 25 witness hasn't testified that she talked to the nurse. KERY GI LLET. CSR No. 3352 I 111 I Q BY MS SCHLOSSER: I'm sorry. Did your husband I 2 relate to you that the nurse s~id that no one would take i 3 Edie in in Los Angeles? ~ A' I don't recall. I 5 Q Was it your understanding when Edie came out 5 to Milwaukee that she had no one in Los Angeles who would I 7 take her in? i 8 A Yes. That was my understanding. 9 MR. KROPP: Objection. Calls for speculation. B 10 Q BY MS SCHLOSSE]~: And where did you get that 11 understanding? A From my husband: 13 Q What did he say? ~ 1~ A He thought we had to help her. She needed help. ~ 15 Q But he also told you that no one in Los Angeles 16 would take her in? ~ 17 A Correct. 18 Q Did you get a firsthand look at the burns that 19 Edie had when she lived with you? 20 A Yes, I did. 21 Q were you primarily the person who was taking ~' 22 care of her? 23 A Yes, I was. 2~ Q Did you change her bandages every day? 25 A Yes, I did. KERY Gl LLET. CSR No. ~52 ~ 112 I Q Could you describe for us how much of her body ~ 2 was burned and where. 3 A The upper part of her chest and around 28% of 4 her body was burned. ~ 5 Q Was that a third-degree burn? 6 A First, second, and third degree. 7 Q For how long did she require continuous care 8 from you? I 9 A I don't recall, but it was several months; several I 10 months. 11 Q She also had trips to the hospital? I12 A Twice a week, 13 Q And what treatment did she receive at the hospital? I 1~ MR, KROPP: Objection, Lack of foundation, Calls I 15 for speculation as to whether this witness has any knowledge 16 about what treatment was received at the hospital., I 17 Q BY MS SCHLOSSER: Do you know what treatment 18 she received at the hospital? ~ lg A No. They changed her bandages and put their i 20 medication on it. 21 Q How do you know that? I 22 MR. KROPP: Motion to strike as nonresponsive. 23 THE WITNESS: Edie conveyed that to me. I 2~ Q Edie told you that, when she went to the hospital 25 twice a week, that they changed her bandages and the dressing K ERY GI LLET, CSR No. 3352 I 113 ; on the bandages? 2 A Uh-huh. 3 Q Were those markings that she had on her upper ~ torso,'did they go around to the back as well? 5 A Partially. 6 Q Did they also involve both arms? 7 A Correct. 8 Q How much of the arms? 9 A Up to the elbow. l0 Q So basically the burns went from her waist to l; her neck? 12 A From the top of her breast to the upper part 13 of her arms around this area [indicating]. I ;z Q Did you watch the burn marks healings? I 75 A Yes, I did. T6 Q They left scars? I ~7 A Very badly. ~8 Q Could you describe the way her skin looked after I 19 the healing was over. 20 A Large indentations in her arm, almost holes I 2V in her arm. ~ 22 Q And also bubbly? 23 A Yes. 2~ Q Did you ever have a description from any medical 25 person of what her condition was called? KERYG~LLET. CSRNo. 3352 IIIIIIIIII ,~s~o~,~o.~o~o,..~.~,~ Illl 114 I A Well, not medically. 2 Q Did you hear anyone describe it? 3 A No. ~ Q Are you familiar with the term keloiding? 5 A Yes, I am. 6 Q Did it appear -- 7 A She had large keloids all over her body. 8 Q And they have been permanent ever since? 9 A That's correct. 10 Q I'm going to go on to a little bit of a delicate 11 area. 12 You tell me if it gets too sensitive for you; 13 all right? 1/-. A Yes. 15 Q Being a person who changed her bandages on a 16 daily basis, can you describe for us what Edie's reaction 17 was to being touched. 18 A Painful, very painful. 19 Q She visibly winced? 20 A Cried. 21 Q So it was difficult to change her bandages? 22 A It was. 23 Q And you had to be extremely tender in doing 2~ it? 25 A She had to soak in the tub for approximately KERY GILLET. CSR N~. 3352 115 ~ half an hour. And I had to remove them very gently. 2 It was difficult. 3 Q And how long did this process take very day? ~ A' I changed them twice a day when she -- other 5 than when she went to the hospital at about 1:00 o'clock 5 and then when I got home from work at about 7:00 every 7 day. 8 Q And this was very difficult on you? 9 A It was difficult for me because of the pain ;0 that she endured while I was doing it. ;l Q Would you like to take a little break? ~2 A I would. 13 MS SCHLOSSER: Let the record reflect again that ;~ Mrs. Wollersheim is on the verge of tears; and I'm going ~5 to call a break. 16 [A b~ief recess is taken.] ;7 Q BY MS SCHLOSSER: Did Edie describe to you that, 18 after she initially went into the hospital, that she went back to the Scientology house for some care? ~ 20 A Yes, she did. 2~ Q Did she describe to you what happened while 22 she was there for care? 23 A Yes, she did. 2~ Q Did she tell you when she lived with you and 25 your husband that she received poor care at the Scientology 'l ,~ KEDY GI LLET, CSR No. 3352 IIIIIIIIII ~ s.o.,~..~ ~..o,,,~ s.,~,~ IIII 1 house? ~ 2 A She did. 3 Q And the care was so poor that she had to sign ~ ~ herself back into the hospital? I 5 A Correct. 6 Q And that she had a fear of being hurt at the I 7 Scientology house? 8 A Yes, she did. I 9 Q Did she mention to you how long she was at the I 10 Scientology house in between visits to the hospital? 11 A I don't recall. I 12 Q Did she tell you the name of the individual 13 who was given the job of' caring for her at the Scientology I 1~ house? I 15 MR. KROPP: Objection. Lack of foundation that any 15 individual had such a job. I 17 THE WITNESS: I don't recall. 18 Q BY MS SCHLOSSER: Did she mention to you whether I 19 it was a man or a woman who took care of her at the Scien- i 20 tology house? 21 A I don't recall. I 22 Q Did she tell you that, instead of tenderness 23 and physically caring for her, that she received bad treatment I 2~ at the Scientology house? t 25 A She did. I KERY GI LLET. CSR No. 3352 117 ~ Q Did she specifically describe to you that her 2 bandages had been ripped off of her painful burns by an 3 individual at the Scientology house? ~ A She said that they weren't careful in removing 5 her bandages. 5 Q Did she use any words such as "ripped off," 7 "pulled off," or indicate to you that the bandages were 8 not being properly removed? 9 A They weren't properly removed. ;0 Q And that it was extremely painful to her -- ~l A Very painful. ;2 Q -- that treatment they were -- ~3 Let me finish the question. I know again it's ;~ a sensitive area. And it's very natural that you would 15 answer as you are, but the record won't be clear -- ~5 A All right. 17 Q -- if we don't wait until each other finishes. 18 Did she describe to you that their treatment 19 of her specifically -- strike that. 20 Did she describe to you that the Scientologists' 2/ house treatment of her burns was particularly painful 22 to her? 23 MR. KROPP: Objection. Asked and answered. 2~ THE WITNESS: Yes, she did. 25 Q BY MS SCHLOSSER: And it was particularly painful KERY GILLET, CSR No. 3352 4s .~ I 118 I because the bandages were improperly removed with roughness? I 2 A Correct. i 3 Q Did she describe to you that, while the bandages ~ were being roughly removed, that she was told that such I 5 an accident would not have occurred to her if she was 6 a good person? ~ 7 A Yes, she did. 8 Q Did she say anything else about being told that? ~ 9 A No, not that I recall. ~ ;0 Q Did she use the word "pulled in" in describing I; what the Scientologist person caring for her had said? A I don't recall._ 13 Q Do you recognize the statement that you pull ~ 1~ in what you deserve as a Scientologist statement? ~ 15 A I don't recall. 16 Q Did she relate to you while she was being treated i 17 at the Scientologists' house, if I can use that word loosely, 18 that they continually told her what a bad person she was? 19 A Yes, she did. 20 MR. KROPP: Objection: Vague as to what period of 2V time we're talking about and who "they" are. 22 MS SCHLOSSER: I think the period of time is clear. 23 But let me go over it once again. 2~ Q What we're talking about here and what was told 25 to her about being a bad person occurred in the time between KERY GI LLET. CSR No. 3352 119 the hospital visits after the burn incident? I A Yes. 2 Q And she related to you that the persons who 3 were telling her what a bad person she must be or this whole burn incident would not have happened to her were 5 Sciento!ogists at the Scientology house? 6 A Yes. 7 MR. KROPP: Objection. Mischaracterizes the testimony '~ 8 in that I don't believe the witness has testified that 9 more than one individual made such a statement to her. l0 Q BY MS SCHLOSSER: Did Edie relate to you that II a number of people had made this statement to her at that ;2 time? 73 A No. ;~ Q Did she relate one individual in particular? 75 A Yes. ;6 ~7 Q And that was the same individual who had been 78 taking care of her at the -- ~9 A Correct. 0 -- Did she relate to you that the reason that Larry 2~ 22 was not living at the Scientology house at the time of 23 the burn incident was because he had been separated from her by Scientology? 2~ 25 A Correct. KERY GILLET. CSR No. 3352 IIIIIIIIII ~A s~,or,,,.,,,,~ ,:,e~,or,,,,g Se,,,,ce~ IIII 4s~ 120 ; Q Did she relate to you that the Church of Scientology 2 was deliberately separating Larry from her in an attempt 3 to break up their relationship? ~ MR. KROPP: Objection. What's meant by deliberately; 5 what's meant by deliberately separating them; and 6 objection, calls for speculation as to motivation of any 7 conduct engaged in by any persons; and it's also vague 8 and ambiguous as to what's meant by Scientology, who did 9 whatever it is the question is seeking information about. ;0 THE WITNESS: That's what she thought. 11 Q BY MS SCHLOSSER: Did she relate to you that 12 Scientology was separating her from Larry because she 13 was not a good Scientology believer? 1~ A Correct. 15 Q Did she relate to you that she had questioned 16 the beliefs or doctrines of Scientology before Larry and 17 she were separated? 18 A She did. ~ 19 Q Did she relate to you that she had been told 20 by people at the Scientology house that she was not a ~ i~ good Scientologist? ~ 22 A No. I don't recall. 23 Q Did she relate to you that she had been abused ~ 2~ by the Scientologists at the Scientology house for her 25 questioning of Scientology? ~ KERY GI LLET, CSR No. 3352 IIIIIIIIII ~,~ s~o~,~ ~o.,,',~ a .....~ 121 7 MR. KROPP: Objection. Lack of foundation. This 2 whole line of quest'ioning has been, "Did she relate to 3 you that/'which infers that a foundation has been laid ~ for this line of questioning rather than a question which 5 says "Did she relate to you whether something happened," 6 which doesn't infer that an' event had in fact occurred. 7 MS SCHLOSSER: Could you read the question back to 8 us, please. 9 [The last question is read.] 70 THE WITNESS: I don't recall 77 Q BY MS SCHLOSSER: However, from the time that 72 Larry was quartered at the Scientology ship through the 73 present day, she and he have never been together again 7~ in a husband-wife relationship? 75 A Correct. 76 Q Did she describe to you that or whether she 77 had problems in accepting auditing which is part of Scien- 78 tology? 79 A Yes, she did. 20 Q And what did she say? 27 A She was unhappy with it. 22 Q Do you recall her mentioning that she fell asleep 23 during auditing? 2~ A Yes, I do. 25 Q Do you recall her saying that she never progressed 122 ; very far in the auditing levels because she found it boring? 2 A She found it boring. 3 Q Did she say those things to you before she left ~ Milwaukee to go out to Los Angeles? 5 A No. 6 Q She said those things to you -- 7 A After. 8 Q -- after when she came to live with you and 9 your husband? 10 A When ! took care of her. 11 Q At your house? 12 A At my home. 13 Q Do you recall Larry before they left for Los I~ Angeles to live out here to be with Scientology telling 15 you that Edie had problems in auditing? 16 A I don't recall. 17 Q Did Edie tell you whether Larry visited with 78 her in the hospital after the burn incident? 19 A Yes, she did. 20 Q And what did she tell you about that? 2V A She told me that he visited her once and that 22 he did not believe she was ill. 23 Q He said Ito her he did not believe she was ill? 2~ A Correct. 25 Q Did she mention to you that, on that visit, KERY GILLET. CSR No. 3352 ~ 123 ~ that he failed to show any compassion for her? ~ 2 A None whatsoever. ~ 3 Q He was cold? ~ A Very cold. ~ 5 Q That he specifically asked her not to sue the 6 Church of Scientology over the burn incident? ~ 7 MR. KROPP: Objection. Lack of foundation. 8 THE WITNESS: He did. ~ 9 Q BY MSSCHLOSSER: And that he was told by Scientologiststhat ~ l0 if he allowed her to sue the Church of Scientology over II the burn incident, that he would be thrown out of Scientology? ~ 12 MR. KROPP: Objection. Lack of foundation. And objectio~ ~3 What is meant by Scientologists. I ;~ Eleanore, when I interpose an objection, we're I 75 going to have a difficult record if we both talk at the ;6 same time. I understand the question's being asked of I ;7 you. But in the interest of a clear record, I need to 78 interpose an objection. And since I'm across the table, I 19 I can't put my hand on your arm as counsel did and ask i 20 you to wait until I finish. 2V MS SCHLOSSER: Objection. I haven't touched Mrs. I 22 Wollersheim's arm. In fact, I'm three or four feet away 23 from her. ~ 2~ MR. KROPP: That's right. You have not done that ~ 25 during cross-examination. But during the direct examination KEllY Gl LLET. C&D No. 3352 I 124 I on several occasions, when Mrs. Wollersheim was asked a 2 question, counsel would put her arm on yours as a suggestion 3 that you wait until the objection was made. ~ MS SCHLOSSER: I object to what you're saying. I 5 object to your characterization unless you're a mind reader, ~ 6 Mr. Kropp. 7 MR. KROPP': Let me indicate, nonetheless, that I 8 observed that there were hand gestures given to you which 9 aided you in not -- 10 MS SCHLOSSER: Now we're going into the signal corps, 11 Mr. Kropp? 12 MR. KROPP: Mrs. Wollersheim, did counsel ever put 13 her arm on your arm when'I asked you a question as an ~ indication that perhaps you should wait until the objection ~5 as made before you answered my question? ~6 MS SCHLOSSER: Objection, Mr. Kropp. Again you're F ~7 asking a question that requires Mrs. Wollersheim to read ;8 my mind. You're indicating physical events that I don't ;9 recall occurring. 20 MR. KROPP: Okay. MS SCHLOSSER: And you're also taking up my questioning b 22 time. '~ 23 MR. KROPP: I'm sorry that you don't recall. But 2~ I'm going to nonetheless ask that, if I make an objection, 25 So the record is clear, to wait until I finish making ~ KERY GI LLET. CSR No. 3352 IIIIIIIIII ~ s .........o~or,,ng s .....~ II II ~ 125 I the objection. Then once you begin answering, I won't' ~ 2 interrupt you either. Okay? 3 THE WITNESS: I'll try. ~ ~ MR. KROPP: Okay. ~ 5 Q BY MS SCHLOSSER: Did she tell you that Larry 6 had asked how she was feeling on this one hospital visit? 7 A He didn't =sk. 8 MR. KROPP: Objection. Motion to strike as nonrespon- ~ 9 sive. ~ ;0 Q BY MS SCHLOSSER: She related to you that Larry 11 had not even asked how she was feeling at the hospital ~ 12 visit? 73 A Correct. ~ 7~ Q Did she tell you that he did not take her in ~ 75 when she needed treatment -- 16 MR. KROPP: Objection. Vague and ambiguous -- ~ 17 Q BY MS SCHLOSSER: -- following the burn incident? 78 MR. KROPP: I apologize, counsel. 19 Objection. Vague and ambiguous as to what's ~ 20 meant by "taking her in." 21 THE WITNESS: She did. ~ 22 MS SCHLOSSER: Can I have the question read back, 23 please. ~ 2~ [The last two questions are read.] 15 Q BY MS SCHLOSSER: Can you answer the question? KERY GILLET, CSR No. 3352 ~ 126 7 A Yes. ~ 2 Q And she specifically told you that he refused 3 to take her in or to give her any treatment? ~ ~ MR. KROPP: I'll renew my objection as being vague ~ 5 and ambiguous. 6 THE WITNESS: That he didn't ask about any care other 7 than the care that she had received in the hospital. 8 Q BY MS SCHLOSSER: During the time that she lived ~ 9 with you and your husband, did she speak about couples ~ ;0 being deliberately broken up by Scientology? ;l A She did. ~ ;2 Q Did she state that it was her opinion that that ;3 was a Scientology policy? ~ ;~ A She did. 15 Q Did she state to you, while she lived with you 16 and your husband, that Scientology deliberately broke I 17 up these couples when one of the couples questioned the 18 worth of Scientology? I 19 MR. KROPP: Objection. Vague and ambiguous as to 20 what's meant by breaking up couples and what's meant by ~ 2V questioning Scientology. ~ 22 THE WITNESS: She did. 23 Q BY MS SCHLOSSER: Did she relate to you that ~ 2~ these couples were deliberately separated by Scientology 25 when one of the parties to the relationship had doubts J KER~' Cl LLET, CSR No. 3352 127 I or questions about Scientology? 2 MR. KROPP: Objection. Vague and ambiguous as to 3 what's meant by Scientology undertaking an action since ~ Scientology is a system of beliefs and not an individual. 5 MS SCHLOSSER: Could I have the question read 6 back, please. 7 [The last question is read.] 8 THE WITNESS: She did. 9 Q Did she mention any instances of that happening 10 other than her own relationship with Larry? 11 A No. 12 Q After she obtained treatment in Milwaukee for 13 her burns, did she undergo any other therapy for her burns? It A She had physical therapy on her arm. She didn't 15 have the movement of one of her arms, and she did go through 16 therapy. 17 Q And you were aware of her going through therapy 18 while she lived with you and your husband? 19 A Yes. 20 Q She spoke about it and what it was like? 2; A [Nods head.] 22 Q That is a yes? 23 A Yes. 2~ Q And for how long did she have therapy that you were aware of? KERY GILLET. CSR No. 3352 128 I A She went to the hospital for several weeks that 2 I recall. 3 Q Does she still have a problem with her arm that ~ you're aware of? 5 A Not that I'm aware of. 6 Q Does she have difficulty raising one of her 7 arms over her head the same distance that the other arm 8 can be raised? 9 A Yes. i'm sure she has. 10 Q And it was that way when she lived with you? 11 A Correct. ;2 Q And in the years after when you saw her? 13 A Yes. ;~ Q What was Buff's relationship with his mother ;5 while the two of them lived with you and your husband? ~6 A It was a beautiful relationship. 17 Q Did you have to make special arrangements in 78 your household so that he would never be very far from 19 her because he was apprehensive about what would happen 20 to her? 21 A They slept in the same bed. 22 Q And he got visibly upset -- 23 A When they were separated [nods head]. 2L Q A certain amount of that is usual in a small- 25 child-mother relationship from what you've observed in KERY GILLET, CSR No. 3352 129 I your own children; isn't that correct? 2 A That's correct. 3 Q But in your mind, this went beyond what was ~ normal? 5 MR. KROPP: Objection. Calls for speculation. There's 5 been no indication that this witness has any particular ? expertise in child psychology. 8 MS SCHLOSSER: She's raised two children, Mr. Kropp. 9 THE WITNESS: Very much' so. ;O MR. KROPP: I commend her for that. But that doesn't 11 necessarily mean she qualifies as an expert witness on 12 the subject of child psychology. 13 MS SCHLOSSER: She can certainly talk about what she 1~ observed, Mr. Kropp. 15 Q And that apprehension on the part of your grandson ', 16 for his mother, how long did that last that you're aware 17 of? 18 A Quite some time. I don't recall, but quite 19 a while. 20 Q He would cry if she left? 27 A He -- he seemed very emotionally disturbed when 22 he came. 23 Q You used the words "when he came." 2~ A When he came to the house. 25 Q And Edie in turn was highly protective of her KERY GILLET, CSR No, 3352 IIIIIIIIII~ s~o-~ ~.,~o~,,~ s.,~i~.~ Illl I ~ ~ 130 son while she lived with you? I A Very much. 2 3 Q Afraid something might happen to him? 4 A Very much so. 5 Q That someone would perform some violence against 6 him? 7 A Yes, she was. 8 Q And who was she afraid would do that, from what 9 she expressed to you? ;0 A Scientology. 11 Q Does she still have this opinion from your conver- 12 sations with her? ;3 A Yes, she does. ;~ Q She's still quite afraid of some sort of physical 75 violence by Scientologists on your son? 16 A Correct. ~7 Q And that lasted through January of 19847 18 A Correct. 19 Q During the time that Edie lived with you and 20 your husband, did she receive correspondence from the 27 Church of Scientology? 22 A She did. 23 Q Did you ever notice where those letters had been sent from on the envelope? 25 A From Los Angeles. KERY GILLEl CSR No. 3352 IIIIIIIIII ~ ~ ......d ~po~,,~g s .....~ IIII ~ 131 7 Q They started amouta few weeks after Edie first ~ 2 started to live with you? 3 A Correct. ~ L Q Did she ever discuss those letters with you? ~ 5 A She did. 5 Q And did she tell you what those letters contained? 7 A Yes, she did. 8 What did they contain? ~ 9 A She owed a lot of money for auditing. ~ ;0 Q And do you recall the amount? 71 A Thousands of dollars. I don't recall the specific 12 amount, but it was thousands of dollars. 73 Q And all the while she lived with you, how often ~ ;L did these letters requesting money for auditing arrive? ~ 15 A I would say weekly. 76 Q In your family are you usually the person 17 that picks the mail up -- 78 A I am. 79 Q -- at delivery time? 20 A [Nods head.] 2~ Q And were you at that time as well the person 22 who picked the mail up? 23 A Yes, I was. 2~ Q Did you notice on the outside envelope of these 25 letters that you picked up for Edie from Scientology the KEI~ G1LLET. C&i~ No. 3352 132 I name of the Church of Scientology of Califormia? 2 A Correct. 3 Q Did the letters disturb her? ~ A Very much so. 5 Q Can you describe for us how she looked when 6 she'd get the letters? 7 A Very upset. 8 Q Did she tell you she believed she didn't owe 9 any money to the Church of Scientology of California? 10 A She did. 11 Q Did she explain why? 12 A Because she felt strongly that she had given 13 part of her trust fund, if I recall, and had given quite 1~ some -- a large sum of money. 15 Q And she had worked for very small wages? 16 A Correct. 17 Q She specifically mentioned the very small wages? 18 A Correct. 79 Q And working for small wages -- 20 A Correct. 21 Q -- in connection with auditing? 22 A Correct. 23 Q In other words, she felt she didn't owe the 2~ money? A Yes. KERY GI LLET, CSR No. 3352 133 I Q To your knowledge, has she ever paid any of 2 that money? 3 A She didn't. ~ Q Starting from the time that Edie and Buff began 5 living with you and your husband, did you get any unusual 5 phone calls? 7 A Yes, I did. 8 Q What sort? 9 A Calls in the middle of the night, anonymous ;0 phone calls, and hanging up on me or on the other line. ;I Q And you considered them unusual? 12 A Very much so. At 2:00 o'clock in the morning ~3 I would say would be very unusual. ;~ Q Do you recall anything in particular that the 15 person said on the other side of the phone to you? 16 A No. Q was it your opinion that those calls were from ;8 Scientologists? A It was both our opinions that it was Scientology. Q Who was the other person? 2~ A Edie. 22 Q Did some of those callers specifically ask for 23 Edie? 2~ A No. Q Did Edie discuss with you, whatever words she'd KERY Gl LLET. CSR No, 3352 I 133 ; Q To your knowledge, has she ever paid any of I 2 that money? 3 A She didn't. ~ Q Starting from the time that Edie and Buff began 5 living with you and your husband, did you get any unusual 5 phone calls? 7 A Yes, I did. 8 Q What sort? I 9 A Calls in the middle of the night, anonymous I ;0 phone calls, and hanging up on me or on the other line. ~1 Q And you considered them unusual? A Very much so. At 2:00 o'clock in the morning ;3 I would say would be very unusual. ~ ;~ Q Do you recall anything in particular that the ~ 15 person said on the other side of the phone to you? 16 A No. ~ 17 Q Was it your opinion that those calls were from 18 Scientologists? ~ 19 A It was both our opinions that it was Scientology. 20 Q Who was the other person? ~ 2; A Edie. ~ 22 Q Did some of those callers specifically ask for 23 Edie? ~ 2~ A No. ~ 25 Q Did Edie discuss with you, whatever words she'd KERY CILLET. CSR No. 3352 IIIIIIIIII ,A Sh0,,n.n~ Re,o.,.g S ..... Illl I I ~ 134 7 use, something called the Fair Game Doctrine, Scientologists ~ 2 have a policy that it is permissible to attack or trick 3 or cause harm to an individual who is against scientology? ~ ~ A Yes -- ~ 5 MR. KROPP: Objection. Lack of foundation. 6 THE WITNESS: Yes, she did. 7 Q BY MS SCHLOSSER: And she knew of that policy 8 at the time she lived with you? ~ 9 A Correct. ~ 70 Q And she was afraid of Scientologists because ;l of that policy? 12 A Correct. 13 Q She considered herself as having left Scientology; ~ ~ and therefore, she could have the policy applied to her i 15 and her son? 16 A Correct. ~ ~7 Q And she specifically told you that? ~8 A She did. I ~9 Q Did she tell you that she considered those letters 20 asking for money that she believed she didn't owe was part 2V of this Scientology policy of punishing her because she 22 left Scientology? 23 MR. KROPP: Objection. Lack of foundation. 2~ THE WITNESS: I don't recall that. 25 Q BY MS SCHLOSSER: Other than letters requesting KERY GILLET. CSR No. 3352 135 I money from the Church of Scientoiogy of California, do 2 you recall her discussing any other written communica'tion 3 from Scientology with you while she lived with you? ~ A No, I don't. 5 Q Were there any other telephone calls or type 6 of telephone calls that were made to your home from the ? time that Edie began living with you that you and she 8 believed were connected to Scientology? 9 A No. 10 Q From the time Edie told you about the Scientology l~ policy of attacking people that they believe are against ~2 them, did you yourself have fears about the rest of your 13 family in addition to Edie and Buff? ;~ MR. KROPP: Objection. Mischaracterizes the witness's 15 testimony to the extent that the witness gave any testimony ;6 at all, which was to simply agree with what counsel said. ;7 I don't b~lieve counsel had used the word "attacking" 18 in the question that had been asked before. That's why 19 it mischaracterises the previous testimony. 20 MS SCHLOSSER: Could I have the question read back, 2V please. 22 [The last question is read.] 23 THE WITNESS: Yes, I did. 2~ Q BY MS SCHLOSSER: What were your fears? 25 A Being hurt by Scientology. KERY GILLET. CSR No, 3352 136 ? Q And what about other family members; what 2 were your fears about them? 3 A I was -- I also felt the same thing, that they ~ would be hurt by Scientology. 5 Q Did you ever read anything in the newspaper 6 about Scientology from that point on that Edie had lived 7 with you that added to or increased your fears above and 8 beyond what Edie had said? 9 MR. KROPP: Objection. Not calculated to lead to 70 the discovery of admissible evidence. Vaque and ambiguous ~ as to when. ;2 THE WITNESS: Yes, I did. ~3 Q BY MS SCHLOSSER: What did you read? ~ A Of the attacks on people when they got out of 15 the church. 16 Q Of Scientology? 77 A Uh-huh. 18 Q Do you have a recollection of where you read 19 that? 20 A The Milwaukee Journal. 21 Q Do you have any approximation of around when, 22 how soon after Edie lived with you, that you -- 23 A I don't recall that. 2~ Q Sometime after 19747 A I would say [nods head]. KERY GI LLET, CSR No, 3352 4se~pr ~ 137 ; Q And they were ne~.-s stories that you read? ~ 2 A Correct. 3 Q And these stories that you read heightened your ~ L fear for yourself, your husband, your son? ~ 5 A Family. 6 Q All of your family? ~ 7 A [Nods head.] 8 Q And you include Edie and Buff in that? ~ 9 A Correct. ~ ;0 Q And you still have that -- II A Yes, I do. ~ 12 Q -- feeling of Scientology and what it would ;3 do to you and your family? ~ ;~ A I do. MS SCHLOSSER: All right. I think that it's about time for the lunch break that we agreed on. ~ 17 MR. KROPP: Sure. Sounds fine. ;8 [The lunch recess is taken.] ~ ~9 Q BY MS SCHLSOSER: Mrs. Wollersheim, you realize i 20 you're still under oath? 2; A Correct. I 22 Q Have you seen any television programs dealing 23 with the subject of Scientology? I 2~ MR. KROPP: Objection as not being calculated to 25 lead to the discovery of admissible evidence. I ~ 138 I Q BY MS SCBLOSSER: You can answer, Mrs. Wollersheim. ~ 2 A Yes, I did. 3 Q And what programs in particular stick out in ~ ~ your mind? ~ 5 A 60 Minutes. 6 Q And what was the 60 Minutes program that you're ~ 7 referring to? 8 A On Scientology. ~ 9 Q What aspect of Scientotogy? ~ 10 A Pardon? 11 Q What aspect of Scientology? ~ 12 A The problems they had with Scientology. 13 Q You're talking about a particular group of people I I~ who had problems with Scientology? 15 A Yes. 15 Q What group? ~ ;7 A The part that I had seen was from Clearwater, 18 Florida where they had called the mayor's wife in regard 19 to the mayor having some association -- was associated 20 with some woman, had an affair with another woman. 2/ Q In other words, the part of the program that 22 you saw was Scientologists calling the wife of the mayor 23 of Clearwater to inform her that her husband was running 2~ around with another woman? 25 A Correct. KERY GI LLET, CSR No, 3352 IIIIIIIIII ~ s~o,,~..~ ~o'~ ~ ..... I 139 1 Q And did the program tell you that that occuIrred ~ 2 because he was considered a problem or an enemy to Scientology? 3 A Yes, it did. ~ ~ Q And that this was a pattern of Scientologists? ~ 5 MR. KROPP: Let me note my continuing objection to 6 this line of questioning. [got being calculated to lead I7 to the discovery of admissible evidence. 8 THE WITNESS: Correct. I 9 Q BY MS SCHLdSSER: Did anyone else that you're I ;O aware of in your family watch this program as well? 7~ A Yes. 12 Q Who? 13 A Edie. ~ ;~ Q And what was her reaction to the program? ~ 15 A Upsetting. 16 Q Why was it upsetting to her that she stated? ~ 77 A Because of the association that she had with 18 Scientology, her fear. ;9 Q Her fear was based upon the fact that, because 20 she had left Scientology, that she was concerned that 21 Scientologists would pull some tricks on her like they 22 had on the mayor of Clearwater? 23 MR. KROPP: Objection. Calls for speculation. 2~ THE WITNESS: Correct. 25 Q BY MS SCHLOSSER: Did she state something like KERY GI LLET, CSR No. 3352 ~ 140 ; what i just stated? ~ 2 A Yes, she did. 3 Q And you yourself heard it? ~ ~ A Yes, I did. ~ 5 Q And has that television program, what it revealed 6 about Scientologists, caused you worry? I7 A Correct. 8 Q And why are you worried? i 9 A I thought they would do the same to me. 70 Q And to anyone else? 17 A And to any members of my family. I12 Q Because...? 13 A Because of what happened in Clearwater, Florida. I 7~ Q And your family's connection with Scientology? i 75 A Correct. ;6 Q While you may not have heard the term Fair Game I ;7 Policy that you can recall, can you state for us ~8 your understanding of what happens to ex-Scientologists I 79 by the Church of Scientology. i 20 MR. KROPP: Objection. Vague and overbroad. 2V THE WITNESS: Destruction of the person that was I 22 in Scientology, destruction of the family with the former 23 Scientologist. I 2~ Q BY MS SCHLOSSER: And you worry about this for B 25 you and your own family? KERY GI LLET, CSR No, 3352 [ 141 I A For my family. [ 2 Q Around the time of late January 1984, did you. 3 have occasion to talk to Edie again? ~ z, A I've talked to her many times, yes. 5 MR. KROPP: Objection. Nonresponsive. 6 Q BY MS SCHLOSSER: But at that particular time? 7 A Yes, I did. 8 Q And did you talk to her about her upcoming depo- I 9 sition at that time? ~ ;0 A No, I didn't. 71 Q Did she express any fears to you about her deposition? 12 MR. KROPP: Objection. Not calculated to lead to 13 the discovery of admissible evidence. ~ ~ THE WITNESS: I wasn't aware of a deposition until ~ ~5 she was subpenaed. ;6 Q BY MS SCHLOSSER: And at that time, what did ~ 77 she say to you? ;8 A She was very upset about it. ~9 Q Why, from what she expressed to you? ~ 20 A Because she wasn't aware that anybody had her 21 address, her new -- her married name, her new name, and ~ 22 for fear-of her and her son's life. 23 Q And did she express to.you why she had all those I 2~ fears concerned with her deposition? 25 A Because of the involvement that she had with KERYGILLET. CSR No. 3352 142 I Scientology. 2 Q And she was afraid that Scientologists would 3 do her harm? i ~ A Correct. 5 Q And all of her fears in regard to the deposition 6 " i 7 A Correct. 8 Q -- had to do with fear of harm from Scientologists? i 9 MR. KROPP: Objection. Calls for speculation. I ;0 THE WITNESS: Yes. 11 Q BY MS SCHLOSSER: And did she express this directly I 12 to you? 13 A She did. ;~ Q Do you have a recollection of approximately I 15 how long Larry stayed with you and your husband when he 16 returned to Milwaukee after leaving Scientology? I 17 A I don't remember how long. 18 Q we're talking about several weeks; or we're talking I 19 about several months? i 20 A I would say several weeks. 21 Q I'm going to ask you now to focus on his personality i 22 at that time. 23 From watching him at that time, would you say i 2~ that he was upset? m 25 A Yes, he was. KERY GI LLET. CSR No. 3352 I ~ 143 I Q Confused? ~ 2 A Yes. 2 Q He had trouble focusing on a single topic during ~ ~ the course of a discussion you had with him? ~ 5 A Many times. 6 Q Did he exhibit signs of wide mood swings? ~ 7 A I would say he did. 8 Q was he still using Scientology terminology? ~ 9 A Not to my knowledge. ~ ;0 Q Earlier you mentioned that he had stopped his 11 staring behavior -- ~ ;2 A Yes, he did. 13 Q -- by that time? ~ 1~ From what you could see, did he have a low level ~ 15 of energy? 16 A I would say he did. ~ 17 Q Would you say from observing him that he was 18 at times depressed? A Very depressed- 20 Q His personality was generally on the low end ~ 21 of the scale? ~ 22 MR. KROPP: Objection. Vague and ambiguous, what 23 low end of the scales means. ~ 2~ Q BY MS SCHLOSSER: On one end of the scale we've 25 got energetic; on the other end of the scale we've got KERYGILLET. CSRNo. 3352 144 complete lethar~.y. Which end of the scale was he closer to '? 2 A Low level. 3 Q Did he have trouble eating? A Z would say yes. 5 Q Did you notice or did he complain of trouble 6 sleeping? ? A No. 8 Q Did he have trouble thinking of future goals? 9 MR. KROPP: Objection. Lack of foundation; calls ;0 for speculation. Q BY MS SCHLOSSER: From what be expressed. ~2 A I would say he did. 13 Q was there anything unkempt about him at that time? A He seemed very nervous. 17 Q About his person, was he as neat as he usually 18 had been? Or did he have a problem in that area? 19 MR. KROPP: Objection. Vague and ambiguous as to what is meant by usually has been inasmuch as they apparently hadn't been together for six years. It's unclear what 2~ 22 time you're talking about when you say usual. 23 THE WITNESS: Yes. 2Z Q BY MS SCHLOSSER: Just to make the record clear, 25 you had from your years of knowing Larry developed an KERY GILLET, CSR No. 3352 I I opinion that he was generally meat about his person? I 2 A Very neat. 3 Q And you noticed a change in that when he came 4 to stay with you and your husband in Milwaukee after leaving 5 Scientology? 6 A Yes, he was. I 7 Q And the change was that he became 'less careful 8 about his personal appearance? I 9 A I would say [nods head]. I ;0 Q The last time you saw him, how was his personal ~; appearance? I12 A Excellent. 13 Q How did his nerves appear to be? I ;4 A Very relaxed. I 15 Q His'conversation now goes in a single direction? 16 A Yes. I 17 Q Through your communications with him from the 18 time that he left Scientology, did he ever express to ~ ;9 you that, especially right after he left Scientology, ~ 20 a sense that he needed outside help to cope? 21 A No. ~ 22 Q So he never told you the name of anyone that 23 he might have consulted? 24 A No. Q To make my question complete: that he might KERYGILLET. CSR No. 3352 146 have consulted for psychological services? 2 A No. 3 Q At or before the time be stayed with you and ~ your husband after leaving Scientology, had you expressed ~ 5 your fears to him about Scientology? 5 A Yes, I did. 7 Q And potentially what Scientologists had done 8 or would do to your family? ~ 9 A Yes, I did. ~ ;0 Q So he was aware of that at the time he was staying l; with you in Milwaukee? A Correct. 13 Q At some point in time, did individuals start ~ l~ showing up at your house asking strange questions about ~ ~5 where Larry was? 16 A Yes. ~ ;7 MR. KROPP: Objection. Vague as to when. ;8 Q BY MS SCHLOSSER: We're speaking now about the ~ ;9 same time period, after the time that Larry left Scientology. ~ 2D A They did not come to the house. However, they 2/ did come to the restaurant and question our employees. ~ 22 MR. KROPP: Motion to strike as nonresponsive. 23 Q BY MS SCHLOSSER: At some point in time after ~ 2~ Larry left Scientology, you became aware of unusual inquiries ~ 25 being made about where he was of your restaurant employees? J KERY G1LLET. CSR No. 3352 147 I MR. KROPP: Objection. Vague and ambiguous as to what 2 is meant by unusual inquiries. 3 THE WITNESS: Yes. 4 Q BY MS SCHLOSSER: Why did you consider them ~ 5 unusual? 6 A Because the employees stated that they were 7 asking about our son instead of asking about Larry or 8 I. And this was very unusual. ~ 9 Q Do you have a recollection about how often that ~ I0 happened after Larry left Scientology? 11 A I would say three or four times, questioning different employees. 13 Q Did you ever re~ceive a communication from some ~ 14 detective bureau stating that they were look. ing for Larry i 15 after he left Scientology? ;6 A Not to my recollection. i17 Q Did you have inquiries made of you that you 18 considered out of the ordinary after Larry left Scientology I 19 about his whereabouts? i 20 A Yes. 21 Q And what did they inquire? I 22 A They wanted to know where Larry was. 23 Q And why did you consider them out of the ordinary? I 2~ A Well, because he had been gone away from home i 75 for so long. I KED GI LLET. CSR No. ~52 I ~ 148 7 Q And a number of those inquiries came within ~ 2 a close period of time? 3 A Uh-huh. ~ ~ C And did that make you suspicious as well? ~ 5 A Correct. 6 Q Did you ever learn after Larry left Scientology 7 of unique or unusual inquiries being made about Larry's 8 whereabouts from other family members? ~ 9 A Yes. I 70 Q And what were they? 7~ A They were --'my nieces's friend at one time was I72 in Scientology. And I don't recall her name. And they 73 called my niece and asked her -- asked my niece the whereabouts I' Z~ of Larry. I 75 Q How did you find out about this? _ 16 A My niece called me. I 77 Q If you could focus again on another time period, 78 Mrs. Wollersheim, going back to the time when Larry started I 79 setting up his business Blacksmith & Son in Milwaukee i 20 and in the six months before his son was born and the 2; time period following the birth of his son until he, his I 22 son, and Edie left for California .... 23 A I didn't have much knowledge on what they I 2~ were doing before he went to California other than running I 25 the business. They had a very successful business. They I KERYGILLET. CSR No. 3352 I 149 I kept very -- everything secretive; and I -- I wasn't aware 2 of anything, you know, anything that -- anyt~ing that 3 they did. ~ Q You mean involving Scientology? 5 A Correct. 6 My first knwoledge was through Cindy, is when 7 I found out that they were into Scientology. 8 Q Your daughter Cindy? 9 A M~ daughter Cindy. 10 Q She had a conversation with you about Larry 11 and Edie being into Scientology? 12 A Correct. 13 Q Using the time period of when Larry set up his 1~ business in Milwaukee through the time that they moved 15 to Los Angeles to be closer to Scientology, did you have ~6 a recollection of when in there that Cindy spoke to you? 17 A She spoke to me while they wer~ at Blacksmith 18 & Son. 19 Q So it was during that time period that she spoke 20 to you? 2; A Uh-huh. ~ 22 Q And she told you that -- 23 A They were into another religion which was Scien- ~ 2~ tology. 25 Q Right. I KERYGILLET. CSR No. ~352 I 150 I A Larry and Edie at no time conveyed to me that 2 they were in Scientology. I got that through Cindy only. 3 Q You're talking about now in this time period ~ that we're speaking about? 5 A That's correct. 5 Q At the time that they moved out to California, 7 you became aware that they were doing it to get more involved 8 in Scientology? 9 A Correct. 10 Q And from where did you get that awareness? l~ A From -- from Cindy. ;2 Q And that was confirmed in your mind when you ;3 came out here to Los Angeles and saw where they were living ;~ and the ceremony they had performed between the two of ~5 them? 15 A [Nods head.] 17 Q Is that a yes? 18 A Yes. ;9 Q Again, I did that because you were just shaking 20 your head. 2V A Yes. 22 Q And at first, you were open minded about what 23 Scientology was when you came out to California? 2~ A I would say no. 25 Q What had caused you to develop -- was it a ~ KERY GI LLET, CSR No. 3352 IIIIIIIIII r,, a~o~,~ ~o~,,~ s .....~ 151 I bad opinion? 2 A My concern about coming out here was simply 3 because Larry's my son; and I wanted to attend the wedding, ~ nothing else. 5 Q Did you have a bad opinion at that time of Scien- 6 tology? 7 A No. I didn't because I didn't know anything 8 about the religion. 9 Q Why didn't you have an open mind then on Scientology? l0 A Because of my own religious beliefs. I have II -- I'm not open minded to other religions. I just firmly ~2 believe in my own religion. ;3 Q And then at some point in time you had the personal ~ experience of being audited in Scientology? ~5 A That's correct. 16 Q And from that you developed your own personal ~7 opinion about -- 18 A That's corect. ~9 Q -- Scientology? , 20 If now we could focus on the time period just 2~ before Larry, Edie, and Buff moved to California, the ~ 22 period of time following the three months when Larry was 23 in California and you and your husband pulled together ~ 2~ to run his business for him .... A Correct. KERY GI LLET. CSR No. 3352 Illl ! 152 Q You mentioned a.t an earlier time period, now, 2 when yot~ were speaking earlier in your deposition, that 3 Larry's personaiit.x was not as warm as it had been or ~ what you were used to. 7. s that a yes? 5 A Yes. 6 Q However, there are levels or degrees that a 7 personality may have. 8 Excuse us. Outside noise. If we can just wait 9 a minute. l0 [A discussion is held off the record.] II Q BY MS SCIiLOSSER: In your life expc~rience, you're 12 aware of a fact that a personality may have levels or ;3 degrees of warmth or coldness; is that true? 1~ A Correct. 15 Q Can you compare for us Larry's personality at ;6 the time he came back from California and went about selling 17 Blacksmith & Son 'to what he had been when he was at school 18 at Madison, Wisconsin? ~9 Can you focus on that for us. 20 A After he came back from Scientology? 2; Q In California, and set about selling his business; 22 and look at his personality at that time and compare it, 23 since we weren't there, to what his personality had been 2~ when he was at the University of Wisconsin in Madison. 25 A I would say it was equal. KERY GILLET. CSR No. 3352 IIIIIIIIII I~ s .......~ ,~ .......~ s .....~ II II I i 153 I Q I haven't asked the question yet. I 2 A All right. 3 Q Will you strike the answer as nonresponsive I ~ since there was no question pending. I 5 Just having those two things in your mind, now, 6 if you couid focus again on Larry at the University of I 7 Wisconsin, what he was like at that time, you earlier 8 described shifts in his personality from what he had been fi 9 at the time he graduated from high school. fi ;0 A Uh-huh. 11 Q Is that a yes? fi ;2 A Yes. 13 Q Do the changes that you have expressed in Larry's I It personality from the time he graduated from high school 15 and when he was at the University of Wisconsin at Madison fi 16 revolve in your mind around Larry taking.up Scientology I 17 rather than Larry going to the university and being physically 18 separate from you? 19 A Yes. 20 Q So that the changes in the level of his warmth fi 21 and his sensitivity are in your mind connected to the I 22 time when he first took up Scientology rather than his 23 going to the university? I 2~ A Yes. 25 Q And looking at the personality that he had at KERYGILLET, CSRNo. 3352 154 I the time he went to university and again con!paring it 2 to the way he was when he first came back from California 3 and set about selling his business, can you describe his ~ level of involvement with Scientology at the time he came 5 back to Milwaukee to sell the business. 6 MR. KROPP: Vauqe, ambiguous, incomprehensible. 7 MS SCHLOSSER: Could i have it read back. 8 [The last question is read.] 9 MS SCHLOSSER: I'll break it down. 10 THE WITNESS: Very equal. 11 Q BY MS SCHLOSSER: There's no question pending. 12 I just struck the. question; and strike the answer since 13 there was no question pending. Okay? 1~ Now, from the time he first got back from California 15 and went about selling his business, you knew he was in 16 a great rush ~o sell the business. 17 A Correct. 18 Q How did you pick that up? 19 A He wanted -- he came home and talked to his 20 father about taking it over. And he wanted to sell the 21 business fast and get back to California. 22 MR. KROPP: Objection. Motion to strike it as non- 23 responsive as there was no indication it was a communication 2~ between the witness and her son. 25 Q BY MS SCHLOSSER: Was that communicated to you? KERY GI LLET. CSR No. 3352 155 1 A No, it wasn't. I 2 Q How do you know that, then? i 3 A Through my husband. ~ Q He spoke to you about it, then? I 5 A Correct. 5 Q When I say "communicated,', ! mean somebody told ~ 7 you or somebody wrote it down or in some cases in sign ~ 8 language, whatever method of communication it was. 9 Your husband conveyed to you the fact that Larry ;0 was in quite a hurry to sell the business? 71 A Correct. ~ ~2 Q You had contacts with your son during this specific 73 time period? 7~ A Not really, [ 75 Q You did see him? ;6 A Yes, I did. 77 Q was he burning to get to California; would you 78 say that's an accurate description? 79 A .Very accurate, 20 Q And how did you determine that he was burning 2V to go to California? 22 A Because I -- he was insistent on selling the 23 business fast and getting back and taking almost anything 2Z for the business, Q Did his staring behavior at that time increase KERY Gl LLET. CSR No. 3352 156 I over what it had been when he left? 2 A I thought so. 3 Q Did you notice him particularly using it with fi ~ you? fi 5 A At times. 5 Q With whom else? 7 A His father. 8 Q Anybody else? I 9 A His sister. I !0 Q Did he appear to you to have a desire to dominate 11 conversations at that time? I 12 A I would say he did. 13 Q How did you notice that; what was it about his I 1~ behavior that gave that impression to you? 15 A Because when we objected to him going out to 16 California, he gave us every excuse on why he should go I 77 back to California; and his insistence on selling the 18 business so fast and taking almost nothing for the business which he built up in the time he was in the business made I 20 me feel that way. 21 Q Did he thank you for your working on the business I 22 for the three months he was in California? 23 A No, he didn't. I 2~ Q Did he make any sort of gesture in gratitude 25 for your spending those three months working on his business? KERY GI LLET. CSR No, 3352 157 I A Not really. D 2 Q Did Edie discuss with you about this time period 3 when she lived with you and your husband whether Larry D ~ was prepared to go to Los Angeles himself without her D 5 if that was the only way he could get to Los Angeles? 6 MR. KROPP: Objection. Vague and ambiguous as to 7 the time period since if I understand it right you're 8 talking about a conversation that happened with Edie after m 9 she got back from Los Angeles about what motivations were ~ 10 of Larry before they went to Los Angeles. II Q BY MS SCHLOSSER: Not motivations, what he told you. Not motivations. ~3 A He did. I ;~ Q You have an express recollection of Edie saying i ~5 to you at the time that she lived with you and your husband ~5 that Larry told her that, if she wouldn't come with him I ~7 to Los AngeleS, that he was going anyway? ;8 A Correct. Q Did she say that that was because he was extremely ~ 20 involved in Scientology? 2V A She did. ~ 22 Q Did she describe to you personality changes 23 that she felt he underwent at the time that he came back ~ 2~ to sell the business? ~ A No. J KERY GI LLET, CSR No. 3352 IIIIIIIIII ,A sho,,...d ~e~o,,i.g s .....~ IIII 158 1 Q Did she express to you when she lived with you 2 and your husband how unusual she thought that behavior was 3 of Larry's in saying that he would leave her in Milwaukee ~ if she would not come to Los Angeles with him because 5 he was going to Los Angeles come hell or high water? 6 A Yes, she did. 7 Q So she expressed to you that it was unusual 8 in her opinion? 9 A She expressed to me that it was unusual in her ~ 10 opinion when she came back to live with Larry and I. ;I Q Did she express to you when she came pack to ~ 12 live with you and Mr. Wollersheim, Sr., that this was 13 a break in her normal pattern with Larry up to that point? ~ I~ MR. RKOPP: Objection. Vague and ambiguous as to 15 what we're talking about was a break in her normal pattern ~ 16 with Larry. ~ ;7 MS SCHLOSSER: Strike that. 18 Q Did she express to you when she came to live I;9 with you and your husband that at the time Larry went I 20 about selling his business, that she went with Larry to 21 Los Angeles to be together with Larry rather thanlbeing I 22 motivated by the desire to get closer to Scientology? 23 A That's correct. I 2~ Q That she wanted to keep the family unit together? 25 A Correct. KERY GILLET, Cc%R No. 3352 159 ; Q Could you describe Larry's relationship with 2 his son Buff from the time the boy was born until they 3 moved to Los Angeles. ~ A They seemed very close. 5 Q What to you signaled that they were close? 6 A Very good father-and-son relationship. 7 Q Is there anything that you observed in particular 8 that comes to mind about that time perid? 9 A His clinging onto his father, closeness. ;0 Q And the same is true of Larry's relationship ;; with the boy? 12 A I would say. 13 Q That Larry also had a sense of closeness with ;~ his son at that time? 15 A I would say. ;6 MR. KROPP: I think the question and the answer were ;7 relatively clear. The only confusion I'm starting to ;8 pick up is the witness will refer to Larry meaning Mr. 79 Wollersheim, Sr.; and sometimes the question you ask, 20 counsel, will mention Larry; and I'm not sure we're always 27 talking about the same Larry between the question and 22 answer. I think that's why there may have been a hesitation 23 in your last answer. 2~ MS SCHLOSSER: May I have the last question read 25 back, please. KERY GI LLET. CSR No. 3352 160 [The last question is read.] Q BY MS SCHLOSSER: Is it clear to you, ~',Irs. Wollersheir that what we're speaking about is your son Larry and his son Buff? I 5 A Yes, I am. 5 Q And these last few questions and answers have I 7 been based upon Larry, Jr.'s, relationship with his son 8 Buff? I 9 A Correct. i 10 Q I believe it's been my pattern to speak of your II husband or your son in general rather than Larry and Larry. ~ ~2 But -- ;3 MR. KROPP: Right. I think that did help the clarity; I ~ but since there was a small digression, that's why I mentioned i 15 it with regard to those last couple of questions. 16 THE WITNESS: Right. Larry and Buff. I~7 Q BY MS SCHLOSSER: If I can go back and synthesize ;8 your testimony about your son's personality at various I;9 points in time and ask a few questions about it, that's 20 what I'm going to be doing next. I 21 Did Larry maintain the personality that -- I 22 MR. KROPP: Excuse me. I think they just called 23 my name over the loudspeaker. I 2~ [A discussion is held off the record.] I 25 Q BY MS SCHLOSSER: Again focusing on the time I KERY Gl LLET, CSR No. 3352 I I 161 I period from the time that Larry returned from Los Angeles 2 to sell Blacksmith & Son, did the personality he displayed 3 to you at that time remain essentially the same until ~ he left Scientology? 5 A He was very cold when he came back from California. 6 Q Particularly cold? 7 A Very cold. 8 Q Unusually cold? 9 A Unusually cold. l0 Q Domineering? ;; A Yes. ;2 Q Controlling of situations? ;3 A Self-control, yes. l~ Q Controlling of other people? ~5 A Very much. ~6 Q Would stand for no interference in conversations? ! MR. KROPP: Objection. Mischaracterizing the testimony. 18 I don't believe that's been testified to. 19 THE WITNESS: I would say yes. 20 Q BY MS SCHLOSSER: A desire for money to give 2; to Scientology? 22 A Yes. 23 Q Heavy use of Scientology terms and jargon? 2~ MR. KROPP: Objection. Mischaracterizes the previous 25 testimony. Lack of foundation. KERY GI LLET. CSR No. 3352 I 162 I THE WITNESS: i'm not familiar with Scientology terms. I 2 ~ BY MS SCHLOSSER: Use of that staring technique 3 that you described earlier? I ~ A [Nods head.] w Is that yes? 6 A Yes. I7 Q All of those qualities he maintained whenever 8 you saw him or communicated with him from the time he I 9 returned to Milwaukee to sell Blacksmith & Son until you I 10 saw him after he had -- up to the time that you saw him 11 -- strike that. That could end up being confusing. I12 Let me restate it again. ~3 He maintained those qualities that you have I ;~ just described whenever you saw him or communicated with i ~5 him from the time he came back to Milwaukee to sell Blacksmith 16 & Son until the last time you saw him or spoke with him I ~7 before he left Scientology? 18 MR. KROPP: Objection. Vague and ambiguous as to I19 when. The witness has not been able to recall any particular 20 occasion on which she saw her son in the time period you're I 21 talking about. ~ 22 THE WITNESS: Yes. 23 MS SCHLOSSER: For the record, she mentioned communicating ~ 2~ with him a number of times, Mr. Kropp. ~ MR. KROPP: Vague and ambiguous as to when. KERY GILLET, CSR No. 3352 163 I Ms SCHLoSSER: Doesn't matter when. it's before I 2 she was aware of his leaving Scientology. 3 Q Is family and closeness to family of paramount ~ ~ importance to you in life? I 5 A Very much. 6 Q And to your husband? 7 A Very much. 8 Q To your daughter? ~ 9 A Very much. a 10 Q And to Larry before he got involved in Scientotogy? II A Correct. 12 Q And to Larry now that he has left Scientology? 13 A Yes. I 1~ Q And did you feel that from the time Larry became i 15 involved in Scientology that it drove a wedge between 16 Larry, your son, and your family? I 17 A It did. 18 Q And the greater his involvement in Scientology, I19 the more of a wedge? I 20 A Correct. , 21 Q And that wedge is gone now? ~ 22 A Yes, it is. 23 Q And has been gone since he left Scientology? ~ 2~ A Yes, it has. ~ Q Your husband had a heart attack in late January KERY GI LLET. CSR No. 3352 164 I of 19717 I A Correct. 2 Q And Larry made trips to the hospital to see 3 I your husband? A Correct. 5 Q Did Larry tell you that he believed his father was not sick? A Yes, he did. g Q Did he say that same thing to your husband's 9 doctor? ;0 A Correct. Q And you were with Larry and your husband's doctor at the time he said that?' 13 I A No, I was not. MR. KROPP: Move to strike the previous answer as speculative. Q BY MS SCHLOSSER: How did you learn of it? A Through Larry's doctor. 18 I 19 Q And the doctor's name...? A Dr. Clasen. I Q Could you spell that for the court reporter s 2; ' convenience. A C-l-a-s-e-n. 23 D 2~ Q At the time that your husband had his heart 25 attack, Larry was concerned with what would happen to I KERY GILLET. CSR No. 5352 I I 165 I your husband's health? I 2 A Correct. 3 HA. KROPP: Objection. Calls for speculation. I ~ Q BY MS SCHLOSSER: How were you aware of him 5 being concerned for your husband's health? 6 A I was aware of him being concerned to the point 7 that he felt his father was not ill. 8 MR. KROPP: Motion ~o strike as nonresponsive. ~ 9 Q BY MS SCHLOSSER: Could you explain what you 10 mean by that. 11 A That the care that Dr. Clasen was giving him I 12 was not helping his father, that he could do more for 13 his father than Dr. Clasen. I I~ Q And how did he say he could do more? ~ 15 A If I recall, by touch assist. Is that correct? ;6 Touch assist? ~ 17 Q There is such a term. What is your understanding 18 of touch assist? 19 A I don't know. i'm not aware. 20 Q Are you aware of touch assist being a Scientology ~ 2~ term? ~ 22 A NO, I'm not. 23 Q Did you ever see Larry put his hands on your ~ 2~ husband while your husband was in the hospital in an attempt 25 to heal your husband? ~ K ERY GI LLET. CSR No. 3352 I I ]66 I A No, I -- I was never in the room at the same I 2 time. 3 Q Did you learn at some point in time that Larry ~ had done that? i 5 A After my husband got out of the hospital. 6 Q And how did you learn that? 7 A Through my husband. 8 Q He told you that Larry had several times come i 9 to his hospital room and put his hands -- m ~0 A On him and gave him a touch assist. ~ Q And do you recall your husband using the term m 12 touch assist? ~ 13 A Correct. I ;~ Q Do you recall Larry using the term touch assist? ~ ~5 A No. 16 Q Did you discuss this with your son? m ~7 A No. 18 Q Did you discuss this with your husband's doctor? a ~9 A No. m 20 Q When you mentioned earlier that your husband's 2~ doctor told you that Larry believed that his father was a 22 not actually sick -- 23 A That's what his doctor told me. Q What else did his doctor discuss with you about m 25 Larry's involvement in your husband's recovery? e KERY GI LLET. CSR No. 3~52 I 167 I A That was all -- I2 MR. KROPP: Objection. Lack of foundation. 3 THE WITNESS: That was all the discussion. He had I ~ told me that my son did not believe his father was ill. I 5 Q BY MS SCHLOSSER: Was your husband's doctor, 6 did he appear to be angry at the time he was speaking I 7 to you? 8 A Very angry. I 9 Q Did he say why he was angry? i 10 A He felt Larry was incapable of making that judgment. 11 Q When you say "Larry," you mean your son? I 12 A Larry, Jr. 13 Q And did he say that he thought that what your ~ 1~ son had done was an interference with medical science? 15 A Correct. ~ ;6 Q However, you yourself did not discuss that with ~ 17 your son at that time? 18 A No, I didn't. 19 Q Perhaps you should take a couple-of-minute 20 break for a moment. ~ 27 [A brief recess is taken.] ~ 22 Q BY MS SCHLOSSER: Since Larry, your son, left 23 Scientology, what is his relationship like with his son ~ 2~ Buff? 25 A Excellent. Good father-and-son relationship. I KERY GI LLET. CSR No. 3352 IIIIIIIIII ,A shor,...~, ~por,,.g a..,c.~ IIII I 169 I Q They do not live in the same city? 2 A Correct. 3 Q And yet you still find their relationship warm ~ and close? 5 A Very close. 6 Q And that's been true since he lef: Scientology? 7 A Correct. 8 Q At one point in time earlier on, you mentioned 9 Edie's upsetment about a trust fund. 10 A Uh-huh. 11 Q From your discussions with her, what was this I 12 trust fund that you refer to? ;3 A It was money ~hat her dad or mom -- I don't recall exactly -- had left her or a grandfather. It was ;5 somewhere in the family. And it seems that the amount I ;6 was around 11 -- $10,000 to $11,000 that she had given I 17 to Larry for Scientology. ;8 Q She specifically told you that she liquidated I19 the trust fund -- 20 A Correct. I 2; Q -- and gave the money to your son for Scientology? i 22 A That's correct. 23 Q Did she speak about all the money going to Scien- I 2~ tology? 25 A She did. i KERY GI LLET. CSR No. 3352 IIIIIIIIII ~ s.o.,~.~ ,~.~,o,,,.~ s .....~ II II 170 7 r~; Would you characterize your husband's attitude 2 toward Scientology from the time he first learned of what 3 Scientology stood for as skeptical? ~ MR. KROPP: Objection. Lack of foundation that her ~ 5 husband e\;er understood what Scientology stood for. 6 THE WITNESS: Yes. 7 Q BY MS SCHLOSSER: And that there was a change 8 in your son's relationship with your husband from the ~ 9 time your husband expressed that skepticism to your son? ~ ;0 A Yes. l; Q And the more skepticism your husband expressed, the more effect it had in a bad way on his relationship ~3 with your son? ~ 1~ A Correct. ~ ~5 Q And is it your opinion that your son had less ~5 and less of a relationship with his father, especially ~ 17 from the time he came back to sell the business, because 18 Scientotogists are taught to separate from those that ~ ;9 are against or do not like Scientology? i 20 A Correct. 21 MR. KROPP: Objection. Lack of foundation, calls ~ 22 for speculation. 23 Q BY MS SCHLOSSER: Well, you were there for those ~ 2~ years. Can you tell us why you felt that way. ~ 25 A Because of the closeness that they had before KERY GILLET, CSR No. 3352 IIIIIIIIII r~ ~ ...... d ,~,o~,i.~, ~ ..... ~ ~ 171 I he got into Scientology. They were very, very close. ~ 2 They did many things together, skiing, go-carting, just 3 everything from fishing to anything a father and son would ~ ~ like to do. ~ 5 Q And from looking at your husband and your son 6 in those year's after your son left high school, was it 7 your impression that your husband was willing to allow 8 your son to grow into adulthood? ~ g A. I would say definitely yes. 10 Q And that he fully expected Larry to become an 11 autonomous adult? i12 A He did. ;3 MR. KROPP: Objection. Calls for speculation. I 1~ Q BY MS SCHLOSSER: And that he was pleased when i 15 your son functioned as an adult? 16 A Correct. ~ 17 Q And Larry, Jr., your son, is very much a mature 18 adult who makes his own decisions at this time? A Correct. 20 Q And your husband and your son have a warm rela~ion- ~ 21 ship at this time? ~ 22 A Very much. 23 Q Even though Larry, Jr., is a mature adult? ~ 2~ A Correct. 25 MS SCHLOSSER: I don't think I have any further questions KERY GILLET. Cc~R No. 3352 I i 172 at the moment. I2 MR. KROPP: I think I just have a few. 3 I ~ FURTHER EXAMINATION I 5 BY MR. KROPP: 6 Q Can you describe for me in any fashion what I 7 you meant earlier on when you were talking about your 8 son's staring behavior. I 9 A In a conversation, he would stare. ;0 Q You mean he would look someone in the eye when l; he was talking to them? a 72 A Correct. ;3 Q Anything more than that, than looking someone I ;~ in the eye? ~5 MS SCHLOSSER: Staring is a word we're all familiar I ~6 with, Mr. Kropp; and it means more than just looking someone I 17 in the eye. 18 THE WITNESS: Just a blank stare look. Q BY MR. KROPP: You testified earlier that Edie 20 told you -- I believe it was after she came back to live I 2V with you in Los Angeles -- that she'd been working for i 22 the Church of Scientology of California. 23 Is it your specific recollection that she said e 2~ her employer was the Church of Scientology of California 25 as opposed to Scientology or the Church of Scientology? KERY GILLET. CSR No. 3352 i 173 A The Church ~ ' c~ Scientology specifically. 2 Q Your best recollection, thSn, is that Edie said 3 her employer was the Church of Scientology? I ~ A Yes. I 5 Q You fee] that you and your son have a good relation- 6 ship at the present time? I 7 A Excellent. 8 Q And do you feel that you and your son can talk I 9 freely about what's on either of your minds? ~ ;0 A I'm sure we can. 11 Q At the present time, I'm talking about. I 12 A At the present yes 13 Q And you feel ~hat your husband has a good re!ation- ~ 1~ ship with your son at the present time? i 15 A Excellent. 16 Q And is it your feeling that the two of them I 17 can converse freely about things that are on their minds? 18 A Yes. 19 Q And it's not your feeling that geographical I 20 separation from your son at the present time has a negative 21 effect on your relationship; it's still a good relationship? 22 A It's still a very good relationship. 23 Q And how was your relationship with your son I 2~ when he was at the University of Wisconsin? I 25 MS SCHLOSSER: I think we've been over this, Mr. Kropp. 174 I Mrs. Wollersheim has already testified that she had a 2 good relationship. 3 MR. KROPP: That's not her testimony, and that's ~ why I'm going over it. 5 MS SCHLOSSER: You can characterize as you like. 6 It stands on its own. 7 MR. KROPP: I've done a good job of suggesting an 8 answer that is inconsistent with the previous one; but 9 T'd like to hear what the witness's recollection is, w~pt ;0 her relationship was with her son when he was at the University ;; of Wisconsin. 12 THE WITNESS: I had an excellent relationship with 13 my son when he was at home, and it was a good relationship 1~ when he was at the University of Wisconsin. 15 Q BY MR. KROPP: How was your relationship with 15 your son when he was on the farm? 17 A T never really had a bad relationship with my 18 son. 19 Q Have you ever at any time talked with your son 20 about the incident where Edie got burned? 21 A When we found out about it, when he came back 22 to visit her. ,23 Q What was the conversation you had with him at 2~ that time about the burn situation? A About him not visiting her at the hospital, KERY GI LLET, CSR No. 3352 I 175 ~ his not being compassionate; and it wasn't the same son I 2 ! had when he was at home; I couldn't believe that my 3 son would not visit and care for her when she was in - ~ ~ - so very ill at the hospital. ~ 5 Q What did your son say in this conversation? 6 A Absolutely nothing. 7 Q After your son left Scientology, have you and 8 he had any conversations about this burn incident? m 9 A Yes, I did. m ;0 Q And what's the essence of any of those conversa- II tions been? ~2 A He was very ashamed to think that he didn't ;3 realize that Edie was this ill and that I -- he had put I ~ me through quite a period of eight months where I had I ~5 to care for her and go through this very traumatic experience. ;6 Q And when did he mention this to you? 17 A When we conversed -- Oh, ! don't recall the 18 date. 19 Q In the last year? 20 A I would say. I iV Q Did he e~:press that to you before the last year? I 22 A No, he didn't. 23 Q Now, you indicated when he returned to live with you after he left Scientology ~hat he appeared disorien- W 25 ted; is that correct? m KERY OI LLET, CSR No. 3352 I 176 ; A When he first came home, he was. I 2 Q I'm talkimg about when he first came home. 3 Did he appear confused? I 4 A Yes, he did. I 5 MS SCHLOSSER: Are you going to go back over everything 6 we already talked about, Mr. Kropp? I7 MR. KROPP: I don't think I'm going to go over everything. 8 Q That he appeared to be at, I think, what counsel I 9 called the low end of a scale of energy from high energy I ;0 to lethargy. ;; A He was very, very nervous. I ;2 Q And did he appear to be lethargic? ;3 A I would say so. I 1~ Q And this was a change from the way he'd been 15 previously? 16 A Before he went to the University of Wisconsin, I 17 yes. 18 Q The last time you saw your son before he left I~9 Scientology and came to live with you, did he appear disoriente~ 20 A Repeat that question. I 2~ Q On the last occasion that you saw yourson in I 22 person -- 23 A A month ago? I 2z Q No. Before he left Scientology and came to 25 live with you. So this would have been before the latter KERY GILLET. CSR No. 3352 177 ; part of 1979 while he was still involved in Scientology, 2 At that point, did he appear disoriented? 3 A I still don't understand the question- ~ Q Let's step back in time. 5 When you came out to Los Angeles for your son's 6 wedding -- 7 A Yes. 8 Q Okay? ~ 9 .-- at that time did he ap~D~r to be disoriented? ~ 10 A Very much so. 11 Q Did he appear confused? ~ 12 A I thought so. 13 Q Did he appear lethargic? ~ I~ A I would say so. 15 Q And on the occasions that you saw your son in 16 between the time you came out for his wedding and the I t7 time he left Scientology, did he remain the same; that ;8 is to say, disoriented, confused, and lethargic? I 19 A I would say for several months after he came 20 back and when he left Scientology, he seemed the same. I 2V Q What I'm asking about, though, is the times I 22 you saw him in the period in between when you came out 23 for his wedding and before he left Scientology- I2~ You said you saw him on a few occasions in that i25 period. KERY GI LLET. CSR No. 3352 I 178 ; In thatperiodof time, did he also seem disoriented, confused, I 2 and lethargic? 3 A While he was in Scientology, he was-confused. fi ~ Q Lacked enthusiasm? ~ 5 A I would say. 6 Q He was lethargic? 7 A Lethargic. 8 MS SCHLOSSER: A good old greek word. fi 9 Q BY MR. KROPP: Now, you indicated that you ~ ;0 talked to Edie about her deposition before it took place ;l in late January of '84. That's when the deposition took ~ 12 place. And you indicated that she had some fears about 13 the deposition. I ;~ Did you talk to Edie after the deposition took i ~5 place? ;6 A No, I didn't. ~7 Q Okay. ;8 MS SCHLOSSER: You mean about the deposition, Mr. ,~ ;9 Kropp? I 20 MR. KROPP: Yes. I meant about the deposition. 2~ THE WITNESS: No, I didn't. I 22 Q BY MR. KROPP: Have you talked to Edie at any 23 time since the deposition took place? I 2Z A I talked to Edie at the time that she received I 25 the subpena. And I was called, and Edie was very upset KERY GI LLET. CSR No, 3352 179 I about it and wanted to know why -- how they found out 2 about her address, her married name, and was very fearful 3 for herself and for her son. i ~ MS SCHLOSSER: When you say "they," you mean the ~ 5 Church of Scientology? 6 THE WITNESS: The Church of Scientology. Q 7 MR. KROPP: Motion to strike as nonresponsive. 8 Q Have you talked to Edie at any time since the ~ 9 conversation you just d~scribed? ~ 10 A No, i haven't. 11 Q Do you know if she's gotten any -- strike that. I 12 If you haven't talked to her, I won't ask the question. 13 Now, when your son began staying with you after a 1~ he left Scientology and he exhibited this sort of personality 15 we've gone over a few times, did he appear in need of I ;6 psychological services? ~ 17 MS SCHLOSSER: Objection. 18 THE WITNESS: I would not know.' MS SCHLOSSER: I was just going to say: Expert testimony, 20 unless you can develop some sort of a basis. ~ 21 Q BY MR. KROPP: Did. you suggest to your son that i 22 he might seek out psychological or psychiatric care? 23 A No, I didn't. I 2~ Q It didn't appear to you that he needed it? A I thought he was extremely nervous and talked KER GI LI,ET. CSR No. 3352 I 180 I to my husband about it; but I did not convey this to my fi 2 son. 3 Q What was it you talked to your husband about? ~ ~ A About how nervous and how changed he was. I 5 Q Did you talk to your husband about whether you 5 thought it might help your son to see a psychologist or 7 a psychiatrist? 8 A No, I didn't. q 9 Q Did it ever enter your mind that it might be fi ;0 good for your son to see a psychologist or a psychiatrist ~l in this period of time when he lived with you after leaving fi 12 Scientology? 13 A No, I didn't. I l~ Q On a couple of occasions you've mentioned that ~5 you have strong feelings about maintaining your religion. I 16 What is your religion? I ~7 A Catholicism. ;8 Q You also testified earlier that, after Edie I;9 came to stay with you after the burn incident, that she I 20 got some bills from Scientology. I beAieve your testmony 21 was that the bills came from the Church of Scientology I 22 of California. 23 Is your specific recollection that she got bills 2~ from the Church of Scientology of California? i A Correct. KERY GI LLET. CSR No. 3352 i i 181 Q She didn't get any bills from the Church of 2 Scientology of Los Angeles? 3 MS SCHLOSSER: Objection. Lack of foundation and ~ ~ assuming facts not in evidence, that there is a Church I 5 of Scientology of i, os Angeles. 6 THE WITNESS: ! wouldn't know. fi 7 Q BY MR. KROPP: Do you recall if she'd. gotten 8 any bills from the Celebrity Center of Los Angeles? m 9 A That sounds familiar. m 10 MS SCHLOSSER: Celebrity Center or whether she got 1~ bills from the Celebrity Center? ~ 12 THE WITNESS: Bills from the Celebrity Center. 13 Q BY MR. KROPP: Do you recall if she got bills ~ I~ from any other Scientology organization while she was 15 staying with you? a 16 A No. fi 17 Q But you do have a specific recollection that 18 she got bills from the Church of Scientology of California? I19 A I had. 20 Q You also mentioned earlier that Edie had talked I 21 about Fair Game Policy to you. i 22 How would you describe Fair Game in your own 23 words? I 2~ MS SCHLOSSER: Objection. She's already gone into 25 this area in great depth. KERY GI LLET CSR No. 3352 182 I THE WITNESS: She never discussed Fair Game with ~ 2 me. 3 Q BY MR. KROPP: Edie never talked to you about Fair Game? 5 MS SCHLOSSER: About the policy. We made that very ~ 5 clear earlier on, Mr. Kropp. She talked in terms of how I 7 the policy worked, not the name of the policy; and that 8 was Mrs. Wollersheim's understanding, about how the policy I 9 worked. 10 Q BY MR. KROPP: You and Edie did talk about how I 11 a policy called Fair Game worked; is that correct? I 12 MS SCHLOSSER: Objection. Again, you're mischaracter- 13 izing her testimony. THE WITNESS: I don't know what Fair Game is. Edie 15 and I discussed policy of what happened to her when she I 16 was into Scientology; but I am not familiar wit~ Fair I 17 Game. 18 Q BY MR. KROPP: What's the policy that you and I19 Edie talked about? How did it work? i 20 MS SCHLOSSER: Objection. Asked and answered. We've gone into this in great depth. 22 MR. KROPP: What was asked and answered, counsel, 23 was your questions about wasn't the policy you talked i 2~ about X, Y, and Z, which elicited a yes answer. I'm real 25 interested in having the witness describe this policy KEllY Ol LLET. CSR No. 3352 IIIIIIIIII ~ s~o~,~.~ ~o~,,.~ s ..... 183 in her own words for the first time. fi 2 MS SCHLOSSER: She did. She summed up the fact that 3 Scientologists go after people that they think are hurting fi ~ Scientology or against the Church of Scientology. fi 5 MR. KROPP: Those were your own words once again. .6 But I'm interested in hearing this witness's words about i 7 the policy. 8 MS SCHLOSSER: She's already spoken about that, Mr. I 9 Kropp. You must have missed the question. I 10 THE WITNESS: What policy are you referring to? 11 Q BY MR. KROPP: The policy that you and Edie I 12 spoke about regarding people who leave the church, the 13 Church of Scientology. A That she had very much fear of people that talked 15 about the church. I 16 Q Edie had a fear of people that talked about a 17 the church? 18 A She had fear for herself. Q And why did she have that fear? 20 A Because of the -- because of Scientology itself. I 21 Q And was that because of some policy of Scientology i 22 that she had this fear? 23 MS SCHLOSSER: Again, askedland answered. We went U 2~ into this in great depth that Mrs. Wollersheim discussed 25 what Edie said and what they discussed. KERY GI LLET, CSR No. 3352 I 4s~ ~ 184 I THE WITNESS: She was very fearful of what they would I 2 do to her if she objected to any of their policies. 3 Q BY MR. KROPP: And was there a particular policy ~ ~ of the church's that you and Edie talked about that made ~ 5 her fearful? 6 A Her dislike for any of their policies. Q Was there any policy that Edie ever talked to 8 you about where the church would in some way come after I 9 people who left Scientology? 10 A Yes, she did. 11 Q And what's your understanding of what that p61icy B 12 was? 13 MS SCHLOSSER: She's already gone into this in great I~ depths again, Mr. Kropp. I 15 MR. KROPP: Not yet in her own words, counsel. 16 MS SCHLOSSER: Yes, she did. O 17 MR. KROPP: Would you repeat the question, please. 18 [The record is read from Line 7 through 19 line 12.] 20 MS SCHLOSSER: Again, same objection. It's been I 21 asked and answered and that your badgering the witness. i 22 Q BY MR. KROPP: What's your understanding of 23 what the policy was? 2~ A I don't want to repeat it. ~ 25 Q It should be easy to repeat it now because, i KERY GI LLET. CSR No. 3352 ~ 185 ~ in theory, your counsel says we've gone over it so many I 2 times. But I really want to hear it in your own words. 3 MS SCHLOSSER: You want to badger the witness. I ~ MR. KROPP: Absolutely not. ~ 5 MS SCHLOSSER: Your actions stand for themselves. 6 Q BY MR. KROPP: Are you able to describe this 7 policy for me in your own words? 8 I',IS SCHLOSSER: She already has done that, Mr. Kropp. I 9 MR. KROPP: That's your answer, not the witness's ~ 70 answer. ;~ MS SCHLOSSER: You're trying to badger her. 12 Q BY MR. KROPP: Are you able to describe this 73 policy to me in your own words? U 7~ MS SCHLOSSER: You're trying to elicit a no out of i 15 her. You're asking the same question over and over again ~6 hoping that sooner or later she'll say no; but she's already I ~7 discussed it. 78 MR. KROPP: Would you read the question back please. [The last question is read.] 20 MS SCHLOSSER: Any more than she did before? Q BY MR. KROPP: Are you able to answer my question? I 22 MS SCHLOSSER: Same objection for the record. 23 Why don't you just say no, Mrs. Wollersheim. I 2~ That's the purpose for this entire line of questioning. I MR. KROPP: Absolutely not. I only asked the question I KERY GI LLET, CSR No. 3352 186 I because I want an answer to the question. That's why 2 I'm going to keep asking it until ! get an answer 3 MS SCHLOSSER: If you were interested in the information, I ~ Mr. Kropp, it was contained in her discussion of Fair I 5 Game and what Fair Game policy means and what she discussed 6 with Edie that occurred during my examination of her. I 7 And you must have missed the question where 8 she described it in her own words. 9 MR. KROPP: I heard many times where you were putting ;0 words in this witness's mouth; and I want to hear the 11 words out of this witness's mouth without being prepped ;2 by you, counsel. 13 MS SCHLOSSER: She was not prepped by me at all, ! 1~ Mr. Kropp. 15 Q BY MR. KROPP: Can you describe for me in your own words what you believe the church policy is regarding people who leave thS Church of Scientology? ;8 MS SCHLOSSER: She already has, Mr. Kropp. i19 THE WITNESS: They go on after their family. i 20 Q BY MR. KROPP: How do they go after their families? , 2V A Hurt them in many ways ~ ~ i 22 Q What ways did Edie mention they tried to hurt i 23 them in? i2~ A Reputation. E e Q Any other ways? ! i KERY GI LLET. CSR No. 3352 1111111111 r~ s~o,,~.d ~o,,,.~ s .....~ ~ II II 187 MS SCHLOSSER: That Edie specifically mentioned? 2 Q BY MR. KROPP: Right. That Edie mentioned to 3 you. ~ ~ MS SCHLOSSER: Other than what we've already discussed? 5 Q BY MR. KROPP: That's correct. Anything other 6 than what we've' already discussed. Anything else that a 7 Edie mentioned to you? 8 A That's all. 9 Q Did Edie tell you that this was an official i 10 policy of Scientology? 11 MS SCHLOSSER: Again, that question has been asked 12 and answered where she said yes, that it was. 13 THE WITNESS: Yes. I I~ MR. KROPP: Thank you, counsel. I'm sure the witness 15 appreciated your help. 16 MS SCHLOSSER: I object to your characterization, I 17 Mr. Kropp. You're trying to badger her after a long 18 day. 19 MR. KROPP: I have no further questions. m 20 MS SCHLOSSER: Okay. I have no further questions. 21 Shall we enter into a stipulation on Mrs. Wollersheim 22 deposition? 23 MR. KROPP: No. MS SCHLOSSER: You're not going to make the accommodation i 25 you did on her husband's? ii KERY GI LLET, CSR No. 3352 I 188 MR. KROPP: No. I2 MS SCHLOSSER: Okay. In other words, you wish her 3 to sign the deposition transcript here? I 4 MR. KROPP: ~^.~ell, if that's what the law says when I 5 there's no stipulation. 5 MR. SCHLOSSER: Does it come as a surprise to you, I 7 Mr. Kropp? 8 MR. KROPP: ! don't think so. g 9 MS SCHLOSSER: That's your intent, then. 10 MR. KROPP: There is no stipulation; and hence, the 71 deposition is over. I ~2 MS SCHLOSSER: Thank you. 13 [The proceedings concluded at 3:18 p.m.] I 1/-, ---o0o--- 15 ELEANORE FRANCES WOLLERSHEIM 18 Subscribed and sworn to I before me on this 19 day of ', 1984. 20 i 22 Notary public in and for the State of California. 23 I KERY GILLET. CSR No. 3352 I 189 ~ 1 STATE OF CALIFORNIA ) 2 COUNTY OF LOS ANGELES ) I 3 i 4 ~, KERY GILLE? ,. CSR NO. 3352 , 5 a notary public i~ and for the State of Cali[ori~ia, do hereby 6 certify: ? That prior to beir~g exa~l~ined, the witness named in the m 8 foregoing deposition, . ELEANORE ~NCES WOLLERSHEIM , ~ 9 was by me duly sworn to testify the truth, the whole truth, 10 and nothing but the truth; M 11 That said deposition was take~.'~ before me at the ~ime 12 and place therein set forth and was take~ down by me ix~ ~3 shorthand and thereafter transcribed into typewriting under [ 1~ my direction and supervision; and I hereby certify the fore- 15 going deposition is a full, true, and correct transcript 16 of my shorthand notes so taken. 17 I further certify that I am neither counsel for nor ~ 18 related to any party to said action nor in any way interested ~ ~9 in the outcome thereof. 20 IN WITNESS WHEREOF, I have hereunto subscribed my name 21 and affixed my official seal this]9t~ day of n~.{~ , ~'~.:~'%j, Notary Public-California "~ / E ~ ~~ PRINCIPAL OFFICg IN ~ "//'~ THE STATE OF CALIFORNIA, 27 ~ 28 KE~CILL~.C~D No.~35'Z i ================================================================= If this is a copyrighted work, you are acknowledging by receipt of this document from FACTNet that on the basis of reasonable investigation, you have not been to obtain a copy elsewhere at a fair price, and that you are and will abide by the following copyright warning. 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