------------------------------------------------------------------- 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. ===================================================================== fishman\Nov24-93 notice of Depo\Page.00001 1 GRAHAM E. BERRY GORDON J. CALHOUN 2 LEWIS, D'AMATO, BRISBOIS & BISGAARD 221 North Figueroa Street, Suite 1200 3 Los Angeles, California 90012 Telephone: (213) 250-1800 4 Attorneys for Defendant, 5 UWE GEERTZ, Ph.D. 6 UNITED STATES DISTRICT COURT 7 FOR THE CENTRAL DISTRICT OF CALIFORNIA 8 9 CHURCH OF SCIENTOLOGY Case No. 91-6426-HLH(Bx) INTERNATIONAL, ) 10 ) NOTICE OF TAKING DEPOSITION OF Plaintiff, ) DESIGNEE(S) OF RELIGIOUS 11 ) TECHNOLOGY CENTER vs. 12 STEVEN FISHMAN and UWE GEERTZ, 13 Defendants. 14 15 16 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 17 Please take notice that defendant Uwe Geertz will take the 18 deposition of the designee Religious Technology Center on Friday, 19 December 10, 1993 commencing at 9:00 a.m. at the law offices of 20 Lewis, D'Amato, Brisbois & Bisgaard, 221 North Figueroa Street, 21 Suite 1200, Los Angeles, CA. The deposition will continue from 22 day to day, excluding Sundays and holidays only, until concluded. 23 In accordance with the court's order dated November 1, 1993, the 24 deposition may be videotaped. 25 Religious Technology Center ("RTC") is requested, pursuant to 26 F.R.Civ.P. Rule 30(6), to designate and produce one or more of its 27 officers, directors, managing agents, or other persons (including 28 LEwis. D'AMATO :RISSOIS ~ BISGAARD LAWrERS 77 99.1 1 SUITE 1200 Ir N. FIGUEROASTRE~ 35ANGELE5.CABOO12 (2~3) 25D1BOO fishman\Nov24-93 notice of Depo\Page.00002 1 but not limited to David Miscavige) who can testify on its behalf 2 as to the following matters known or reasonably available to the 3 organization/corporation: 4 1. The authenticity of L. Ron Hubbard's final wills written 5 before his death; and 6 2. Who it was who first called by Pat or Anne Broeker to be 7 told that L. Ron Hubbard was dead and who called Earl Cooley and 8 others to tell them that they would go to L. Ron Hubbard's ranch 9 in Creston that night; and 10 3. The authenticity of L. Ron Hubbard's signature on a 11 document filed with a probate court in Riverside, California, 12 circa 1983, challenging the claims of L. Ron Hubbard, Jr.; and 13 4. The authority for David Miscavige's assumption of the 14 position of Chairman of the Board, Religious Technology Center; 15 and 16 5. The manner in which communications were assembled and 17 transmitted to and receive from Pat Broeker in bankers boxes on a 18 weekly basis from 1982 until death in 1986; ) 19 6. The conversation(s) between Mary Sue Hubbard and David 20 Miscavige which caused her to relinquish control of the Guardian's 21 office in 1981 to David Miscavige; and 22 7. The conversations between David Miscavige and Pat 23 Broeker in 1987 that caused Broeker to leave and caused Miscavige 24 to issue a directive stating that Broeker had falsified a message 25 from Hubbard that appointed Broeker a "Loyal Officer;" and 26 8. All post titles that David Miscavige has held including 27 but not limited to Chairman of the Board of Religious Technology 28 Center ("RTC"), or to which he has received or from which he has LEwis. D'AMnro IRiseois a BISGnARO LIWrERS 7i ~9.1 2 svlrr 1200 ~1 N.F(GUEROASTREET 3SANGELES.CA90012 (213) 2501800 fishman\Nov24-93 notice of Depo\Page.00003 1 issued communications, whether in writing or on the Mercury INCOMM 2 system in the past 48 months, and all posting orders for any of 3 these posts and the full hat check sheets and facts for any and/or 4 all of these posts ; and 5 9. The Org. Board that shows David Miscavige's relation to 6 RTC, CSI, CST, ASI, CMO Int., Office of Special Affairs and any 7 other Scientology or Scientology or Scientology-related 8 organizations over which David Miscavige has any authority 9 whatsoever. ("Scientology organization" shall herein be defined 10 as any person, group or organization, whether incorporated or 11 unincorporated, that has a trademark licensing agreement with 12 RTC); and 13 10. The duties, responsibilities and/or functions David 14 Miscavige has had in RTC or any other Scientology-related 15 organization in the past 48 months including all LRH policies, 16 Flag orders (FOs), Central Bureau Orders (CBOs), Scientology 17 Policy Directives (SPDs), LRH advices and orders, Guardian's 18 Orders (GOs) and any other issues, orders, orders logs or tapes 19 relating thereto; and 20 11. All Evals, Strategic Plans, Tactical Plans, Programs 21 and/or Projects on which any of the posts for which David 22 Miscavige has been directly responsible for the past 48 months are 23 named or have targets; and 24 12. All orders David Miscavige has issued to Heber Jentsch, 25 Lynn Farney, Kurt Weiland, Norman Starkey, Marc Yaeger, Greg 26 Wilhere, Ray Mithoff, Marty Rathbun, Rick Moxon, Tim Bowles or any 27 other RTC CSI or OSA executive or staff member whether directly or 28 via the standard command lines, in the past 48 months; and LEwis. D'AMArO :RISeOIS ~ BISGAARD LnWVERS 7; 39.1 3 sulrr ~200 !1 N. FIGUEROA STREEI ~SANOELES.CABOO12 1213) 250-1800 1 fishman\Nov24-93 notice of Depo\Page.00004 1 13. All weekly reports David Miscavige has received from all 2 sectors of Scientology including all weekly reports and weekly 3 report summaries from Greg Wilhere, Ray Mithoff, Marc Yaeger, 4 Marty Rathbun, Norman Starky, Heber Jentsch, Lynn Farney, Jonathan 5 Epstein, Rick Moxon, Tim Bowles, Kurt Weiland and David 6 Butterworth for every week in the past 48 months; and 7 14. Any and all statistical graphs and statistical analyses 8 sent to David Miscavige from Greg Wilhere, Ray Mithoff, Marc 9 Yaeger, Marty Rathbun, Norman Starkey, Heber Jentsch, Lynn Farney, 10 Kurt Weiland, Rick Moxon and Tim Bowles for every week in the past 11 48 months; and 12 15. All communications, whether in writing on the INCOMM 13 computer system, on the Mercury system, by phone or by any other 14 means, which David Miscavige has had in the past 48 months with 15 Gene Ingram or any other private investigator or security 16 personnel in the employ of any Scientology Organization or any 17 private investigator or security personnel in the employ of any 18 attorney in the employ of any Scientology organization; and 19 16. All orders David Miscavige has issued in the past 48 20 months concerning anyone related to or involved in any Scientology 21 or Scientology-related litigation, whether or not a Scientology 22 organization is actually named in the suit as either plaintiff or 23 defendant; and 24 17 All cramming orders David Miscavige has issued to any 25 one in any Scientology or Scientology-related organization in the 1 26 past 48 months including full compliance results from the cramming 27 officers who did the crams either on David Miscavige or on those 28 whom he issued crams; LEwis. D'AMATO ~RISSOIS ~ BISGAARD inwrERs 77 B9.1 4 SUITE 1200 !1 N FIGUEROASTREET ~SANGELES.CA90012 (213) 25~1eOO fishman\Nov24-93 notice of Depo\Page.00005 1 18. All conditions Orders in which David Miscavige has been 2 assigned or had assigned himself and all Conditions Write-ups he 3 has done including weekly postcondition write-ups and condition 4 write-ups he has done for any ethics situation on any of David 5 Miscavige's eight dynamics, particularly his first, second and 6 third dynamics, in the past 48 months; and 7 19. All Committees of Evidence in which David Miscavige has 8 been an interested party and the findings and recommendations of 9 such Committees of Evidence which he has personally ordered or has 10 ordered others to convene, and the findings and recommendations of 11 such Committees of Evidence in the past 48 months; and 12 20. Any and all Courts of Ethics in which David Miscavige 13 has been an interested party and the findings and recommendations 14 of such Courts of Ethics, and any and all Courts of Ethics in 15 which David Miscavige has personally ordered or had others ordered 16 to convene and the findings and recommendations of such Courts of 17 Ethics; and ~8 21. All Boards of Investigations in which David Miscavige 19 and his post area has been the subject of investigation and the 20 findings and recommendations of such Boards of Investigation and 21 any and all Boards of Investigations which David Miscavige has 22 personally ordered others to convene and the findings and 23 recommendations of such Board of Investigation; and 24 22 All RPF assignments David Miscavige has received since 25 being in the Sea Organization and all RPF assignments he has 26 ordered on others, whether directly or indirectly, through orders 27 to CMO, RTC, ASI, OSA, CSI, or any other Scientology or 28 Scientology-related organization, since he has been in a position LEwis. D'AMATO IRiseors a BISGnARO LIWVERS 7; 89 1 5 SUITE 1200 ~1 N. FIGUEROA STREET 3SANGELES.CA90012 (213) 25~1 BOO fishman\Nov24-93 notice of Depo\Page.00006 1 of authority to do so, and all RPF graduation CSWs which pertain 2 to such RPF assignments; and 3 23. All Suppresive Person Declares and Non-Enterbulation 4 orders David Miscavige has ordered on others including any such 5 Declares issued during the 1982 Mission Holders Conference in San 6 Francisco; and 7 24. All security checks David Miscavige has received in the 8 past 48 months and any and all O/W write-ups he has done in the 9 past 48 months; and 10 25. All Errands which David Miscavige has either been on as 11 a missionaire or has been responsible for as the Mission Ops or 12 about which others have reported to David Miscavige, or to which 13 he has had access as COB RTC, including any and all missions, 14 projects, or errands related in any way to the following: the 15 Cult Awareness Network, the handling of any plaintiff or defendant 16 (or their legal counsel) in Scientology or Scientology-related 17 litigation, whether or not any Scientology organization was named 18 as either plaintiff or defendant, any individual psychiatrist, 19 group of psychiatrists, psychologists, group of psychologists, or 20 any other individual or group in the field of mental health or 21 mental healing; the handling of any one who has been critical of 22 Scientology or who has been considered a threat to Scientology in 23 any way; and 2r2 26. All reports, debriefs, CSWs, Mercury messages, orders or 25 any other forms of written, oral, taped or videotaped 26 communications that David Miscavige has sent to others or others 27 have sent to David Miscavige or to which David Miscavige has had 28 access as COB RTC concerning Bowles & Moxon "Plan 100"; Steven LEwis. D'AMATO ~RISeOIS b BISGAAAD L*wrERs 7: B9.1 6 sulrr ~200 '1 N. FIOUEROA STREET )SANGELES.CA90012 (213) 25(11800 1 fishman\Nov24-93 notice of Depo\Page.00007 1 Fishman, Uwe Geertz, Gary Scarff or Ron Nordquist; and 2 27. All plans, programs, projects, evals, orders, reports, 3 newsletters, brochures, or any other documents concerning the Cult 4 Awareness Network, Priscilla Coates, Cynthia Kisser, or any other 5 individual in any way related to CAN to which David Miscavige has 6 had access as COB RTC; and 7 28. Any and all press, books, magazine articles, TV and 8 Radio and any other form of media (both theta and entheta, meaning 9 positive and negative Scientology and/or Scientologist) that has 10 been counted on the RTC and/or OSA statistics over the past 48 11 months; and 12 29. Any and all communications and agreements and/or 13 contracts made with any media, specifically but not limited to 14 ABC-TV (Nightline), Premium Magazine, financial network news, 15 regarding David Miscavige's appearance or the publication or use 16 of materials under David Miscavige's name; and 17 30. All communications by David Miscavige with the Internal 18 Revenue Service regarding previous or ongoing investigations into 19 David Miscavige's and/or his wife Shelley's personal finances and 20 or his role(s) in any Scientology or Scientology-related 21 organization; and 22 31. David Miscavige's knowledge of the details and 23 circumstances regarding the grant of Internal Revenue Code Section 24 501(c) exemption status to RTC, CSI and various other Scientology 25 organizations and the circumstances and details regarding any 26 sealed documents which have not been made public in relation 27 thereto; and 28 32 David Miscavige's communications and knowledge of LEW(S. D`AMATO IRiSeois a BISGAnRO LIwrERs 7: B9.1 7 SUITE 1200 !1 N. FIGUEROA STREET 3SANGELE4CA90012 (2~3) 25D(B00 fishman\Nov24-93 notice of Depo\Page.00008 1 communications with any representatives of the Department of 2 Justice, Federal Bureau of Investigation and/or other law 3 enforcement agency, with a local, state, federal or foreign, 4 regarding previous or ongoing investigations into David 5 Miscavige's and/or his wife Shelley's personal finances and/or his 6 role(s) in any Scientology or Scientology-related organizations; 7 and 8 33 David Miscavige's correspondence with foreign and/or 9 overseas banking entities for the purpose of personal and 10 corporation financial transactions for David Miscavige and his 11 wife Shelley; and 12 34 David Miscavige's knowledge and participation in any and 13 all agreements with Pat Broeker at Preston, California, or any 14 other location regarding the estate of L. Ron Hubbard and the 15 handling of final communications from L. Ron Hubbard; and 16 35. David Miscavige's knowledge and receipt of all moneys 17 spent by the International Association of Scientologists (IAS) for 18 his legal defense; and 19 36 David Miscavige's receipt of any gifts with a value 20 greater than $100 and given to him and/or his wife Shelley by any 21 Scientology group or person under his command; and 22 37 David Miscavige's knowledge's knowledge and receipt of 23 all financial awards or bonuses paid to him and/or his wife 24 Shelley by Scientology organization; and 25 38. David Miscavige's knowledge of the details of Author's 26 Family trust A and Author's Family Trust B including all past and 27 present executed either of those acts and the renumeration and/or 28 compensation of all present and past executives of both trusts; LEW(S. D'AMATO R158015 b BISGAARD L*WUERS 7. 89 1 8 sulrr 1200 !1 N.FIGUEROASTREET )5 ANGELES. CA 90012 (21S) 25(t18M) fishman\Nov24-93 notice of Depo\Page.00009 1 and 2 39. All private contracts and agreements made between David 3 Miscavige and L. Ron Hubbard; and 4 40. All occasions on which David Miscavige has departed from 5 and entered intG any country including the United States since he 6 became one of the commodore's messengers; and 7 41. All monies and funds David Miscavige couried or carried 8 out of the United States or into any other country either before 9 or after he became a commodore's messenger; and 10 42. All "special properties" that David Miscavige and/or his 11 wife Shelley have bought, borrowed or in any way obtained from 12 Author Services, Inc. and/or Bridge Publications; and 13 43. All "special properties" that David Miscavige and/or his 14 wife Shelley has personally sold or received commissions on and 15 the persons to whom they have been sold to, the price and special 16 commission and dates and all jewels and precious metals given or 17 awarded to David Miscavige and or/his wife by Author Services, 18 Inc.; and 19 44. All stock and bonds and any other investments given or 20 awarded to David Miscavige and/or his wife Shelley by Author 21 Services, Inc. including their original value and current value; 22 45 All improvements made to David Miscavige's personal 23 living spaces at Gilman Hot Springs and in Los Angeles by 24 Scoientology personnel including but not limited to, members of 25 Rehabilitation Project Force (RPF) and /or Estates Project Force 26 (EPF), the estimated value of those improvements and the wages 27 paid to those people by whom and when if any; and 28 46. All clothing and personal items bought for David LEwis. D'AMATO iRISSOIS 6 BISG~ARD 9 LIwrERs 7~jB9.1 Sulrr 1200 It N.FIGUEROASTREET 3SANGELE~CA90012 (213) 25DleOO fishman\Nov24-93 notice of Depo\Page.00010 1 Miscavige and/or his wife Shelley from funds of Author Services, 2 Inc. and the Religious Technology Center and the date, cost of 3 each item and whether such items are still in David~Miscavige's 4 possession or the possession of his wife Shelley; and 5 47. All weapons in the possession or under the control of 6 David Miscavige or owned by David Miscavige, including all rifles, 7 pistols, handguns, knives, martial arts weapons, teargas, 8 ammunition and any required licenses for same; 9 48. David Miscavige's knowledge of the details and 10 circumstances of the death of Mary Florence Barnett a.k.a. Miller 11 including the ownership of any rifles or other guns involved in 12 same and the 'handling' of any investigation of involving the 13 death of Mary Florence (Flo) Barnett a.k.a. Miller; and 14 49. All trips undertaken by David Miscavige and/or his wife 15 Shelley at the expense of or paid by Author Services, Religious 16 Technology Center, and/or any Scientology organization especially 17 those for recreation such as skiing trips in California, Utah and 18 or Colorado mountain resorts; and 19 50. All financial loan agreements or contracts where a 20 Scientology organization loaned money to David Miscavige and/or 21 his wife Shelley; and 22 51. All real property, whether developed or undeveloped, 23 that David Miscavige and/or his wife Shelley has purchased or paid 24 monies toward in the United States and/or Mexico, Venezuela, the 25 Carribean Islands or any other country, nation, sovereignty or 26 possession and the amount of monies paid by David Miscavige and/or 27 his wife Shelley or by another on behalf of either or both of 28 them; and LEwis. D'AMArO ]RISSOIS 6 BISGAARD 1 0 LIwvEns 71 89.1 SUITE 1200 ?( N. FIOUEROA STREFl. 35~NGELEQC~8OO,2 (213) 25~1800 fishman\Nov24-93 notice of Depo\Page.00011 1 52. All automobiles and/or boats bought by David Miscavige 2 and/or his wife Shelley or by another that is under the control 3 and/or ownership of David Miscavige and/or his wife Shelley; and 4 53. Any secular Scientology organizations, enterprises and 5 or business, including but not limited to Sterling management or 6 members of the World Institute of Scientology Enterprises in which 7 David Miscavige and/or his wife Shelley own or control stocks or 8 investments and the value of same and dates of purchase, gifts or 9 other transfer; and 10 54. David Miscavige's knowledge or any Scientologist(s) 11 being physically assaulted, beaten, harrassed or otherwise 12 physically or psychologically abused or ordered to be physically 13 or psychologically abused by Scientology staff members or those in 14 the employ of any Scientology or Scientology-related organization, 15 especially but not limited to private investigators; and 16 55. David Miscavige's knowledge of all reports, proposals, 17 orders and/or notes concerning Steven Fishman becoming a 18 stockbroker ; and 19 56. Any and all meetings between David Miscavige and Steven 20 Fishman including but not limited to a meeting in Clearwater on 21 November 9, 1980; and 22 57. David Miscavige's factual basis or otherwise for the 23 various statements he made on the Nightline interview with Ted 24 Koppel and in his rebuttal letter to Premium Magazine in 1993 and 25 David Miscavige's knowledge of any damage caused to any 26 Scientology entity or Scientology related entity ~as a result of 27 the publication of the Time Magazine article on May 6, 1992 and 28 entitled "Scientology, the Thriving Cult of Greed and Power," and LEwis. D'AMATO ~Rissors a BISGnARO I*WVERS 7. j89 1 11 suirr r200 ?r N. FIGUERO~ STREET 3SANOELES.CA90012 (213) 2501800 fishman\Nov24-93 notice of Depo\Page.00012 1 the statements attributed to any person therein; and 2 58. David Miscavige's knowledge and participation in the 3 disbanding of the Guardian's office, and David Miscavige's 4 knowledge of any carryover of personnel from the Guardian's office 5 to any other Scientology or Scientology-related entity; and 6 59. David Miscavige's knowledge of how policy letters are 7 adopted as Church policy by either RTC or CSI; and 8 60. David Miscavige's knowledge of whether RTC has received 9 any complaints regarding possible fraud by Author Services Inc in 10 the handling of "special properties"; and II 61. David Miscavige's knowledge of whether anyone has filed 12 suit or threatened suit regarding possible fraud by Author 13 Services Inc in the handling of "special properties"; and 14 62 David Miscavige's knowledge of any RTC or CSI staff who 15 bought "special properties" as part of an ASI push; and 16 63. David Miscavige's knowledge of any investigations 17 regarding possible fraud by ASI in the handling of "special 18 properties"; and 19 64. David Miscavige's knowledge of any complaints regarding 20 the financial conduct of Michael Baybak; Ken Gerbino; the Feshbach 21 brothers, Sterling Management and any lawsuits, threats of lawsuit 22 or investigations regarding the same; and 23 65. David Miscavige's knowledge of any financial scams or 24 irregularities regarding individual Scientologist's use of the 25 American Express card for the benefit of any Scientology entity or 26 Scientology-related entity in Los Angeles or elsewhere; and 27 66. David Miscavige's knowledge of any Scientologist 28 misusing the proceeds of student loans, or other loans, including LEwis. D'AMATO IRISSOIS ~ BISGAARD L~wrERs 7.d89.1 12 sulrr ~200 ?( N. FIGUEROA STREET 3SANGELES.CA900(2 (21 3) 25018M) fishman\Nov24-93 notice of Depo\Page.00013 1 the misuse of loan and student loan proceeds (by using the 2 proceeds for purchase of Scientology processing, services and 3 publications) at any Scientology mission or org. including but nct 4 limited to the Portland Mission, the Fort Lauderdale Mission and 5 the Riverside Mission including any police investigation(s) into 6 the same; and 7 67. David Miscavige's knowledge of any investigation of two 8 Scientologists who went to jail in Germany for financial scams; 9 and 10 68. David Miscavige's knowledge of whether Fran Harris, Fred 11 Harris, Richard Tinkelnbarg and Terry Gamboa are in good standing; 12 and 13 69. David Miscavige's knowledge of any investigation into 14 allegations of fraud that recently prompted the arrest of 15 Scientology officials in France; and 16 70. David Miscavige's knowledge of an investigation into the 17 firm of Bernstein, McCaffrey and Lee in Clearwater which was 18 raided by authorities in December, 1989; and 19 71. David Miscavige's knowledge of any concession by RTC, 20 CSI or any other Scientology related entity or official that L. 21 Ron Hubbard had broken the law as part of a concession for tax 22 exemption and that this concession and admission is being kept 23 under seal; and 24 72. Whether David Miscavige has ever been at a property in 25 Baja, Mexico owned by Eugene Ingram; and 26 73. David Miscavige's knowledge of any storage facility 27 operated by Eugene Ingram that Eugene Ingram alleges has "enough 28 to send [a top Scientology executive] to jail;" and LEwis. D'AMATO IRiseois a BlSGn~AD 1 3 LIWVEnS 7;j89 1 sulrr r200 ?1 N. FIGVEAOA STREET 3SANGELE8CA90012 (213) 25~1800 fishman\Nov24-93 notice of Depo\Page.00014 1 74. David Miscavige's knowledge of any RTC, CSI or other 2 Scientology entity investigations into any suicides or wrongful 3 deaths including but not limited to the death of Susan Meisner; 4 and 5 75. David Miscavige's knowledge of "overboarding" and "off 6 loading"; and 7 76. David Miscavige's knowledge of certain Scientology 8 scriptures, policy letters and Hubbard lectures dealing with 9 suicide, end of cycle, total knockout, R2-45, etc.; and 10 77. David Miscavige's knowledge of any investigation of the 11 death of Quentin Hubbard in 1976; and 12 78. David Miscavige's knowledge of the alleged involvement 13 of Rick Moxon in the killing of Judge Swearinger's dog ("Duke"); 14 and 15 79. David Miscavige's knowledge of the manner and 16 circumstances of L. Ron Hubbard's death, cremation and the results 17 of the blood tests that were taken from the dead body of L. Ron 18 Hubbard; and 19 80. David Miscavige's knowledge of all persons who were 20 present at the time of L. Ron Hubbard's death and David 21 Miscavige's knowledge of any new will or trust arrangements that 22 were made by L. Ron Hubbard within the 7 days preceding his death; 23 and 24 81, David Miscavige's knowledge of the conviction of Milan 25 Nekuda who tried to kill a woman in 1988; and 26 82. David Miscavige's knowledge of any investigation into 27 the death of Pedro Rimando who fell from the roof of the Manor on 28 Franklin Avenue in 1986; and LEwis. D'AM~TO IRiseoiS a BISGnAAO 1 4 L~WrERS 7' iB9.1 Sulrr 1200 ?1 N. FIGVEROA STREO 35ANGELE8C*BOO(2 (213) 2501800 fishman\Nov24-93 notice of Depo\Page.00015 1 83. David Miscavige's knowledge of any lawsuit filed or 2 threatened by Irene Marshall; and 3 84. David Miscavige's knowledge of any investigation into 4 the suicide of Noah Lottick in 1990; and 5 85. David Miscavige's knowledge of whether or not Mary 6 Florence Barnett a.k.a. Miller was about to turn over confidential 7 material to perceived enemies of the church just prior to her 8 death; and 9 86. David Miscavige's knowledge regarding the sending of 10 Scientology personnel to Philadelphia about ten years ago to 11 handle a highly confidential family matter for David Miscavige; 12 and 13 87. David Miscavige's knowledge of policy that a CSW must be 14 approved for Sea Org. members to get pregnant; and 15 88. David Miscavige's knowledge of any orders by L. Ron 16 Hubbard or David Miscavige for staff to have abortions; and 17 89. David Miscavige's knowledge of any investigations by RTC 18 or CSI into sexual improprieties of top executives with staffs 19 from other organizations; and 20 90. Whether David Miscavige knows Paula Ross Dain; and 21 91. David Miscavige's knowledge of homosexuality in the 22 Hubbard family and material of Hubbard's that reveals bisexual 23 behavior; and 24 92. David Miscavige's knowledge of the influence, if any, of 25 Arthur Crowley, Occultists, and others on L. Ron's Hubbard's 26 writings; and 27 93. David Miscavige's knowledge of upsets with staff 28 regarding housing and living conditions and whether or not David LEwis. D'AMATO IRiseois a BIStnARO 15 LAWYERS 7' i89~1 sulrr 1200 '1 N.FIGUEROASTREEI 3S ANGELES. CA BOO12 (213) 2501800 fishman\Nov24-93 notice of Depo\Page.00016 1 Miscavige gave a talk to staff at Golden Era Productions about 2 eight months ago where he berated them for their attitude; and 3 94. David Miscavige's knowledge of upsets with staff for not 4 being able to see their children; and 5 95. David Miscavige's knowledge of whether sea org. members 6 are still transferred to non sea org. orgs when the wife gets 7 pregnant; and 8 96. David Miscavige's knowledge of any couple being ordered 9 to be divorced because one of them is not in the sea org.; and 10 97. David Miscavige's knowledge of the financial, corporate, 11 organization contractual and ecclesiastical relationships between 12 RTC, CSI and WISE; and 13 98. David Miscavige's knowledge of the truth or falsity of 14 all statements made in the Time Magazine article entitled 15 "Scientology -- The Thriving Cult of Greed and Power" published in 16 Time Magazine on May 6, 1991 and any and all damages caused to any 17 Scientology entity as a result thereof; and 18 99. David Miscavige's knowledge of allegations of financial 19 irregularities involving Scientologists and Scientology-related 20 entities by William Jordan of Athena Gold and others; and 21 100. David Miscavige's knowledge of Mission All Clear, 22 Project Quaker, TR-L, 'On Control and Lying,' Hatting the Witness, 23 the Witness College, Operation Paper Chase, Operation Pill Freak, 24 the Rehabilitation Project Force, the FBO network, The Ethics Bait 25 Project, Operation Acting Classes, Operation Financial Rescue, The 26 Student Assistant Project; Operation Piggy Bank, Operation Student 27 Loan, Operation Student Assistance Project, the Way to Happiness 28 Project, Operation Snow White, the Battle of Los Angeles, Psych LEwrs. D'AMATO IRIS~OIS ~ BISGAARD LIWUERS 7 j89 1 16 sulrr 1200 ~1 N. FIGUERO~ STREO 3SANOELES.C~90012 (213) 250-1 800 fishman\Nov24-93 notice of Depo\Page.00017 1 Busting, The DC-9, all unindicted co-conspirators associated with 2 the DC-9, the conviction and sentencing of Mary Sue Hubbard and 3 Jane Kember, the B-1 hat pack, Michael Meisner and the destruction 4 of documents by Scientologists following the FBI raids in 1977 and 5 1978; and 6 101. David Miscavige's knowledge of betting, killing, and the 7 removal of documents from Scientologist's files; and 8 102. David Miscavige's knowledge of the Religious Research 9 Foundation which has bank accounts in Luxembourg; and 10 103. David Miscavige's knowledge of the use of Religious 11 Research Foundation funds to purchase property in Clearwater and 12 provide monies directly to L. Ron Hubbard; and 13 104. David Miscavige's knowledge of the Mission Category 14 Corporate Sortout (MCCS) Objectives and Transactions; and 15 105. David Miscavige's knowledge of the composition (at 16 various times) and activities of the All Clear Committee; and 17 106. David Miscavige's knowledge of the removal from post of 18 David Mayo, Pat Broeker, Annie Broeker, Bill Franks, Alan Walters, 19 and their involvement in the RPF and running program; and 20 107. David Miscavige's knowledge of the circumstances 21 surrounding the incorporation of RTC and its powers and 22 authorities over other Church of Scientology missions, churches, 23 entities, organizations, parishioners and staffers etc.; and 24 108. David Miscavige's knowledge of the actual proceedings at 25 the San Francisco Mission Holders Conference and the subsequently 26 published transcript of those same proceedings; and 27 109. David Miscavige's knowledge of the establishment of I 28 HELP; and LEwis. D'AMArO RISSOIS L BISGA~RD 1 7 LIwrEnS 7ji8s 1 SUITE 1200 il N. FIGVEROA STREET )5ANGELESCA90012 (213) 25~1800 fishman\Nov24-93 notice of Depo\Page.00018 1 llO. David Miscavige's knowledge of the operations of and 2 finances of the World Institute of Scientology Enterprises and of 3 Sterling Management, Inc.; and 4 111 David Miscavige's knowledge of the establishment and 5 activities of the International Finance Police; and 6 112. David Miscavige's knowledge of the transactions that led 7 to the transfer of trademarks and monies as between L. Ron Hubbard 8 and RTC, the monies paid therefor or in relation thereto and the 9 income taxes paid thereon; and 10 113. David Miscavige's communications with L. Ron Hubbard 11 regarding David Mayo and his relay of communications between L. 12 Ron Hubbard and David Mayo; and 13 114 David Miscavige's knowledge of altered reports to L. Ron 14 Hubbard regarding sec checking of Pat Broeker by David Mayo; and 15 115. David Miscavige's knowledge of the Committee of Evidence 16 that found David Mayo to be a Suppressive Person and which 17 expelled him from the Church; and 18 116. David Miscavige's knowledge of the activities of 19 Scientology Missions International (SMI) between 1982 and 1986 20 with regard to mission investigations, mission closings, mission 21 fines and the sale of new charters; and 22 117 David Miscavige's knowledge of the birthday game played 23 by Scientologists generally and as played by Steven Fishman 24 specifically; and 25 118. David Miscavige's knowledge of the arrests and 26 investigation of Scientology officials (including but not limited 27 to the Reverend Heber Jentsch) in Spain, Italy, Greece, West 28 Germany, England, Canada, New Zealand, Australia, Israel, France, LEwis. D'AMATO IRISSOIS 6 BISGAARD L~wuEns 7. i89.1 18 SUITE (200 ?1 N.FiGUEROASTREET 3SANGELES.CA90012 (213) 25D1800 fishman\Nov24-93 notice of Depo\Page.00019 1 Germany and the United States; and 2 119 David Miscavige's knowledge of Black Dianetics, Reverse 3 Processing, the Use of Hypnosis in Scientology, the Fair Game 4 Doctrine or Policy, Suppressive Persons, Suppressive Acts and 5 Disconnection; and 6 120. David Miscavige's knowledge of the assignment of 7 trademarks between L. Ron Hubbard and RTC including but not 8 limited to the assignment of such trademarks on two documents 9 entitled Assignment Agreements, their examination by professional 10 questioned document examiners, their examination by john L. 11 Swanson, and Ermgart Wassard and the conclusions of such 12 examinations as to the authenticity of the signatures of L. Ron 13 Hubbard, David Miscavige and the official witnesst to those 14 questioned signatures; and 15 121. David Miscavige's knowledge of all ethics orders, sec 16 checking, suppressive person declares, and expulsions involving 17 Kingsley Wimbush and Steve Surrey and John Zegel and the various 18 committees of evidence convened regarding each; and 19 122. David Miscavige's knowledge of the OT Committee John 20 Cavan, Peers Gardtrum, and the alleged illegal activities of the 21 Church of Scientology in Spain; and David Miscavige's knowledges 22 of the details of Mission Category Corporate Sortout as handled by 23 Laurel Sullivan; and 24 123. David Miscavige's knowledge of the elimination of all of 25 LRH's comm lines except his own during the years 1977 and 1986; 26 and 27 124. David Miscavige's knowledge of the establishment of The 28 Watchdog Committee and CMO Int's responsibility for church LEwis. 0`AMATO 1Riseois a BISGnARO 1 9 LlWVERSiTRI 9.1 SUlrr 1200 rl N FIGU~AOA~ 3SANGELES.CABOO12 1213) 2501800 fishman\Nov24-93 notice of Depo\Page.00020 1 management as of September 1, 1979; and 2 125. David Miscavige's knowlege of the indictment of L. Ron 3 Hubbard by a Tampa Grand Jury in February 1980; and 4 126. David Miscavige's knowledge of the personal history of 5 L. Ron Hubbard insofar as it was involved in the Armstrong case; 6 and 7 127 The circumstances of the establishment of the All Clear 8 Committee, Project All Clear, the original composition of the All 9 Clear Committee and the circumstances of successive changes in the 10 composition of the All Clear Committee; and 11 128. David Miscavige's Communications in 1981 with Mary Sue 12 Hubbard regarding relationships and responsibilities of the CMO 13 and the Guardian's office, the takeover of the Guardian's office 14 by CMO and the telexes from L. Ron Hubbard to Jane Kember ordering 15 her to step down from the Guardian's Office; and 16 129. David Miscavige's knowledge of the circumstances 17 surrounding, and the purposes for, the establishment and 18 incorporation of Religious Technology Center and Author's 19 Services, Inc.; and 20 130. David Miscavige's knowledge of the relationship between 21 Religious Technology Center and the rest of the Churches of 22 Scientology; and 23 131. David Miscavige's knowledge of those persons who were 24 pulled off post in July and August in 1982; COMM EV'd, declared 25 and expelled; and 26 132 David Miscavige's knowledge of the handling of various 27 'squirrels', and that certain "EYES ONLY" dispatch from David 28 Miscavige to Marc Yaeger, the CO CMO INT that called for the LEwis. D'AMnro ~RISSOIS 6 BISGAARD LIwrERs 7 j89.1 20 sUlrr 1100 ~1 N.FIGVEROASTREE 3SANGELES.CA9001i (213) 25DleOO fishman\Nov24-93 notice of Depo\Page.00021 1 squashing of the squirrels; and 2 133. David Miscavige's knowlege of the amount of money spent 3 by RTC, CSI and other Church of Scientology churches on legal 4 expenses for the past ten years; and 5 134. David Miscavige's knowledge of the handling of 6 suppressive persons, potential trouble sources, enemies of the 7 church, adverse litigants and opposing counsel; and 8 135. David Miscavige's knowledge of the phrase "acceptable 9 truth" as used in Scientology; and 10 136. David Miscavige's knowledge of improper and/or illegal 11 financial activities on the part of Peter Letterese, Barbara 12 Letterese, Nancy Witkowski, Fred Hare, Michael Hambrick, Peter 13 Clouden and Steven Fishman and all vetting, culling, sec checs, 14 drilling, cramming or ethics orders in relation thereto; and 15 137. David Miscavige's knowledge of the deposition herein of 16 Timothy Bowles, Lynn Farney, Peter Letterese and Barbara Hambrick 17 and all hatting, cramming, drilling, sec checs, vetting or culling 18 in relation thereto; and 19 138. David Miscavige's knowledge of any and all murders, 20 suicides and/or financial scams involving Scientologists, 21 Scientology staff, sea org members, Scientology entities and 22 Scientology related entities or affiliates, fraternal 23 organizations or WISE members; and 24 25 26 27 28 LEwis. D'AMArO RISeOIS b BISGAARD 21 L~wrERs 7;i89.7 SUlrr 1200 11 N. FIGUEROA STREET 3SANGELEbCA90012 (213) 250-1eOO fishman\Nov24-93 notice of Depo\Page.00022 1 139. David Miscavige's knowledge of all 'red box data'; and 2 140. Any drilling, cramming, sec checs, orders, instructs, 3 dispatches, or sessions requested by, given to, ordered by David 4 Miscavige in connection with this notice of deposition. 5 6 Dated: November , 1993. GRAHAM E. BERRY GORDON J. CALHOUN 7 LEWIS, D'AMATO, BRISBOIS 4 BISGAARD /7 8 9 tiy ~£~nd~~~r ctz, 10 Attorneys for D Ph.D 11 L 12 13 14 15 16 17 18 19 20 21 22 23 2cl 25 26 27 28 LEwis. D'AMATO iRISSOIS 6 BISGAARD 22 L~WUERS 7;j89.1 SUITE 1200 !1 N.FlOVEROASTREET 35ANGELE5CABO012 (213) 25D1800 fishman\Nov24-93 notice of Depo\Page.00023 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES; 3 I am employed in the County of Los Angeles, state of California. I am over the age of eighteen (18) and not a party to 4 the within action; my business address is 221 North Figueroa Street, Suite 1200, Los Angeles, CA 90012 5 On November 24, 1993, I served the following document (s) 6 described as: NOTICE OF TAKING OF DEPOSITION OF DESIGNEE(S) OF RELIGIOUS TECHNOLOGY CENTER on interested parties in this action 7 by placing a true copy thereof enclosed in a sealed envelope addressed as follows: I 8 9 Jonathan W. Lubell, Esq. MORRISON, COHEN, SINGER & WEINSTEIN 10 750 Lexington Avenue New York, New York 10022 11 12 Steven Fishman 8851 Sunrise Lakes Blvd. 13 #116 Sunrise, Florida 33322-1413 14 15 ( ) (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and 16 correct. 17 (X) (FEDERAL) I declare that I am employed in the office of a member of this court at whose direction the service was 18 made. 19 (X) I declare under penalty of perjury under the laws of the State of California that the above is true and correct and that 20 this declaration was executed on November 24, 1993 at Los Angeles, California. 21 22 23 Type or Print Name (Signature) 24 25 26 27 28 LEwis. D'AM~ro IAISSOIS a BISGAARD 23 LIWUEnS 7 779.1 SUmr 1200 ?1 N.FIGUEROASTREET 3SANGELES.CABOO12 (2(3) 25DleOO ================================================================= 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. WARNING CONCERNING COPYRIGHT RESTRICTIONS: The copyright law of the United States (Title 17, United States Code) governs the making of photo copies or other reproductions of copyrighted material. Under certain conditions specified by law, libraries and archives are authorized to furnish a photocopy or other reproduction. One of these specified conditions is that the photocopy or reproduction is not to be "used for any purpose other than private study, scholarship, or research." 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